-------
sanding may occur at various points of the surface coating operation,
depending on the manufacturer. Application of sealants generally occurs
after the primer application; sealants are usually cured together with the
|
primer in the primer coat oven.
1
Touchup coating operations are conducted at various stages of the
application of the topcoat(s) to yield a uniform appearance of the coated
area. High bake touchup coating is performed prior to attachment of heat
sensitive materials and is cured in a high temperature oven. Final, or low
bake, repair generally uses a highly catalyzed air-drying coating. Air-
drying coatings are required, since at this stage heat-sensitive plastics
and rubber automotive parts have been built into the automobile, and the
vehicle can only tolerate a low bake temperature.
3.2.1.2 Preparation of Metal Prior to Coating
The automobile body is assembled from a number of welded metal
sections. The body and the parts that are coated all pass through the same
metal preparation process.
First, surfaces are wiped with solvent to eliminate traces of oil and
grease. Second, a phosphating process prepares surfaces for the primer
application. Since iron and steel rust readily, phosphate treatment is
necessary to prevent such rusting. Phosphating also improves the adhesion
of the coating to the metal. The phosphating process occurs in a multi-
stage washer in the following sequence:
1. Alkaline cleaner wash - 20 to 120 seconds
i
2. First hot water rinse - 60°C (140°F) - 5 to 30 seconds
1
3. Second hot water rinse - 60°C (140°F) - 5 to 30 seconds
3-16
-------
4. Phosphating with zinc or iron acid phosphate - 15 seconds
5. Water rinse, ambient - 5 to 30 seconds
6. Dilute chromic acid rinse - 5 to 30 seconds
7. Deionized water rinse - 5 to 60 seconds
The parts and bodies pass through a water spray cooling process and, if
solvent-based primer is to be applied, they are then oven dried.
3.2.1.3 Primer Coating
A primer is applied prior to the topcoat to protect the metal surface
from corrosion and to ensure good adhesion of the topcoat. Figure 3-3, a
flow diagram, shows process steps of both solvent-based primer and topcoat
applications. Approximately half of all finishing processes use solvent-based
primers and employ spray application. The rest use water-based primers.
Water-based primer is most often applied in an electrodeposition (EDP)
bath. The composition of the bath is about 5 to 15 percent solids, 2 to
10 percent solvent, with the remaining portion being water. The solvents
used are typically organic compounds of higher molecular weight, such as
ethylene glycol monobutyl ether. When EDP is used, a guide coat (also
called a primer surfacer) is applied between the primer and the topcoat.
This guide coat can be either solvent-based or water-based. Guide coat and
EDP are described in more detail in Chapter 4, Emission Control Techniques.
Solvent-based primer is applied by a combination of manual and automa-
tic spraying. Solvent emissions for solvent-based primer application were
derived from information collected from automobile manufacturers. Average
solvent emissions were calculated to be 5.71 liters per vehicle for the
primer application. Assuming that a car production line operates at a
production rate of 55 cars per hour and two (8-hour) shifts per day,
3-17
-------
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3-18
-------
880 cars are produced daily. Approximately 4,218 kilograms of solvent
(basis: density of 0.839 kg/liter) are therefore discharged daily from
the primer application process.
Yearly energy requirements for solvent-based primer application and
for EDP primer application are tabulated in Table 3-9 for a typical produc-
tion line. A material balance for a typical 24 volume percent solvent-based
primer is shown in Table 3-10, which includes the discharge of emissions at
different steps in the process. Discharge of solvents to the atmosphere in
the spray primer application is estimated as follows: 88 percent loss
during application and 12 percent loss during oven drying of the coating.
The information presented is from industrial surveys, 43 percent is used as
a representative transfer efficiency. A material balance is not presented
for an EDP prime system since virtually all solids are transferred to the
vehicle and VOC emissions are very low because the coating is a water-based
material.
3.2.1.4 Solvent-based Topcoat
The solvent-based topcoat is generally applied by a combination of
manual and automatic sprays. Average percent solids content in the paint
is in the range of 24 to 33 percent volume for solvent-based topcoat enamel
type automotive finish, and 12 to 18 percent volume for solvent-based top-
coat lacquer type automotive finish. A material balance for solvent-based
enamel topcoat application is shown in Table 3-11.
Because of-the time that the body is in the spray booth, 85 to
o
90 percent of the solvent evaporates in the booth and its flash-off area.
Solvent emissions vary with each automobile plant, depending mainly on the
number of units produced daily, the surface area of each unit, and the
3-19
-------
Table 3-9. ENERGY BALANCES OF PRIME COAT APPLICATIONS
FOR AUTOMOBILES
Coating
Application.
(106 Btu/hrD)
Cure .
(106 Btu/hrD)
Total
Solvent-based
Spray Pritner
EDP Pritner
15,167
58,223
76,187
73,723
91,354
131,946
This amount is highly dependent on climate since outside air must
be heated to comfortable temperatures. The amount of heat required
for this can be twice that required for curing.
Annual energy consumption calculations were based on 211,200 cars
produced per year, derived as follows: (1) Production rate -
55 cars/hr; (2) Time - 2 shifts (8 hrs/shift) per day, 240 days/yr;
or 55 cars/hr x 3,840 hrs/yr = 211,200 cars/yr.
3-20
-------
Table 3-10. MATERIAL BALANCE FOR SPRAY APPLICATION OF
SOLVENT-BASED PRIMER TO AUTOMOBILES
Item
Liters Per .
211,200 cars'
Coating applied (24% solids by volume)
• Coating (40% solids by volume as bought)
• Thinner
• Total coating applied
Material loss in the application
(43% transfer efficiency)13
• Solids
• Solvent discharge
• Total material loss
Total coating on body (after flash-off)
Oven evaporation loss
• Solvent discharge
Net dry solids on body
952,533
635,022
1,587,555
215,368
1,278,512
309,043
143,398
165,645
The annual production figure of 211,200 cars was derived as follows:
(1) Production rate - 55 cars/hr; (2) Time - 2 shifts (8 hrs/shift) per
day, 240 days/yr; or 55 cars/hr x 3,840 hrs/yr = 211,200 cars/yr.
Transfer efficiency is the percentage of the total coating solids used
that deposit on the surface of the object being coated.
3-21
-------
Table 3-11. MATERIAL BALANCE FOR SPRAY APPLICATION OF SOLVENT-BASED
ENAMEL TOPCOAT TO AUTOMOBILES
Item
Coating applied (25% solids by volume)
• Coating (31% solids by volume as bought)
• Thinner
• Total coating applied
Material loss in the application
(43% transfer efficiency)
• Solids
• Solvent discharge
• Total material loss
Total coating on body (after flash-off)
Oven evaporation loss
Liters Per
211,200 cars
1,881,053
451,451
2,332,504
328,327
1,545,718
1,874,045
458,459
• Solvent discharge 203,660
Net dry solids 254,799
3-22
-------
amount of solvent in the paint. The process steps of solvent-based topcoat
application were shown in Figure 3-3.
The loss of paint from overspray varies between 20 and 60 percent for
solvent-based topcoats. Most automotive companies use waterwall-type spray
booths. The used water from the spray booths goes to sludge tanks where
solids are removed, and the water is recirculated. The sludge tanks are
cleaned yearly.
Topcoat application is made in one to three steps to ensure sufficient
coating thickness. An oven bake may follow each topcoat application or the
paint may be applied wet on wet. The energy balance for solvent-based
topcoat application is shown in Table 3-12.
Following the application of the topcoat, the painted body goes to the
trim operation area where vehicle assembly is completed. The final step of
the surface coating operation is generally the final repair process in
which damaged paint is repaired in a spray booth and air-dried or baked in
a low bake oven to protect the heat-sensitive plastic and rubber parts that
were added in the trim operation area.
3.2.1.5 Equipment Characteristics
Automotive finishing process equipment from which VOC emissions emanate
consists of spray booths, dip tanks, flash-off areas, and bake ovens. Other
equipment includes specialized conveyors for moving the bodies and parts to
be finished through the process.
Solvent-based primer and topcoat are applied by a combination of
manual and automatic spraying techniques. Spray booth lengths vary from
100 to 200 feet. Because the bodies and parts are in the spray booth for a
relatively long time, the majority of solvents are emitted in the spraying
3-23
-------
Table 3-12. ENERGY BALANCE FOR APPLICATION OF
SOLVENT-BASED ENAMEL TOPCOAT TO
AUTOMOBILES
Operation Steps
106 Btu/Yr
Application
Cure
a
39,016
195,947
Total
234,963
aThis amount is highly dependent on climate since
outside air roust be heated to comfortable temperatures.
The amount of heat required for this can be twice that
required for curing.
3-24
-------
area. High air flows through the booths dilute the vapors to such an
extent that exiting concentrations of solvent vapor are very low.
To comply with the Occupational Safety and Health Administration
regulations, a minimum air velocity within the booth is usually specified.
As a result, organic vapors are in the vicinity of 50 to 150 ppm in the
spray area.* However, even though the solvent concentration is low, the
volume of exhaust is high and the total amount of solvent emitted can
easily exceed the limit of 3000 pounds per day required by many state
regulations. Temperature in the spray booths ranges from 15°C (60°F) to
35°C (95°F).
Spray booths of the waterwall type are most used in automobile produc-
tion facilities. In a typical booth design, the overspray paint particles
are removed by a curtain of water flowing down the side surfaces of the
booth enclosure. Waterwall systems in several booths are connected to one
or more large sludge tanks. The floating sludge is skimmed off the surface
of the water. The water is then filtered and recirculated to the booths.
Bake ovens for the primer and topcoats usually have four or more heat
zones. Oven temperatures range from 93°C (200°F) to 232°C (450°F), depen-
ding on the type of coating and the zone. A bake oven can safely operate
at 25 percent of the lower explosive limit (LEL), and in many industries
such concentrations are maintained. In the automotive industry, however,
concentrations are much lower. One reason is that ovens are very long with
large openings; hence, large amounts of air are pulled into them. Another
reason is that ovens are designed to provide a bake environment that is not
Threshold limit for toluene or xylene: 100 parts/million (ppm).
American Conference of Governmental Industrial Hygienists, 1973.
3-25
-------
saturated with solvent, as air pressures in the oven tend to force avail-
able solvent vapors into the panel insulation. The two major automobile and
light-duty truck manufacturers report solvent concentrations at five percent
of the LEL.10'11 According to another source, solvent concentration in the
12
oven may reach a maximum of about 10 percent of the LEL.
3.2.1.6 Emission Characteristics
The three types of solvent-based coatings used in the automotive
industry are paints, enamels, and lacquers. Paints represent a small
fraction of the total quantity of the coatings used in automotive surface
coating operations. Paints are highly pigmented drying oils diluted with a
low-solvency-power solvent known as thinner. Applied paints dry and cure
in the oven by evaporation of the thinner and by oxidation during which the
drying oil polymerizes to form a resinous film. Enamels are similar to
paints in that they cure by polymerization. Many automotive coatings
i
contain no drying oils but cure by chemical reaction when exposed to heat.
Applied lacquers are dried by evaporation of the solvent to form the coat-
ing film.
The amount of solvent and thinners used in surface coating composi-
tions varies, depending upon the plant in which they are used. The solvents
used in enamels, lacquers, and varnishes are aromatic hydrocarbons, alco-
hols, ketones, ethers, and esters. The thinners used in paints, enamels,
and varnishes are aliphatic hydrocarbons, mineral spirits, naphtha, and
turpentine.
As mentioned previously, solvent emissions occur at the application
and cure steps of the surface coating operation. Calculation of solvent
I
emissions from representative plants resulted in the emission factors for
3-26
-------
the primer (solvent-based spray and EOF with guide coat) and topcoat opera-
tions given in Table 3-13. Assuming that the production rate of a finishing
line is 880 cars per day (55 cars per hour, two 8-hour shifts per day),
10,329 kg of solvents (basis: density of 0.839 kg per liter) are discharged
daily from the finishing operation.
Solid waste generated by the automotive finishing process was also
determined based on data collected from the industry. Table 3-14 shows
solid waste factors for the automobile surface coating operations.
The spray booths' water effluent contains contaminants from overspray
of coatings. This effluent is discharged into sludge tanks, where solids
are removed, and the water is recirculated. The sludge tanks are cleaned
yearly when solvent-based coatings are used and four times per year for
water-based coatings.
3.2.1.7 Factors Affecting Emissions
Several factors affect emissions discharged by the automotive industry.
Naturally, the greater the quantity of solvent in the coating composition,
the greater will be the air emissions. Lacquers having 12 to 18 percent
volume solids are higher in solvents than enamels having 24 to 33 percent
volume solids.
Production affects the amount of discharge of solvent emissions—the
higher the production rate, the greater the emissions. This rate can also
* • " . -
be influenced by the area of the parts being coated.
Emissions are also influenced by the thickness of the coating and
technique used. There are no transfer problems when EDP is used; essen-
tially all the paint solids are transferred to the part. There can be
dripping associated with dragout, but this material is normally recovered
3-27
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Table 3-13. AVERAGE EMISSIONS FOR AUTOMOBILE SURFACE
COATING OPERATIONS
Application
Coating (liters/car)
Primer-
Sol vent-based spray 5.03
Topcoat-
Sol vent-based spray 7.32
Total9 12.35
Primer-
EDP 0.18
Guide coat-
Sol vent-based spray 1.24
Topcoat-
Solvent-based spray 7.32
Total b 8.74
Cure
(liters/car) Total
0.68 5.71
0.96 8.28
1.64 13.99
0.03 0.21
0.17 1.41
0.96 8.28
1.16 9.90
aTotal for spray primer and topcoat applications.
DTotal for EDP primer, guide coat, and topcoat applications.
3-28
-------
Table 3-14. AVERAGE SOLID WASTE GENERATED FOR AUTOMOBILE
SURFACE COATING OPERATIONS
Coating
Primer-
Sol vent-based spray
Topcoat-
Sol vent-based spray
Total3
Primer-
EDP
Guide coat-
Sol vent-based spray
Topcoat-
Sol vent-based spray
Total5
Average Transfer Loss of
Solids in Coatings
(liters/car)
1.02
1.55
2.57
0.002
0.250
1.550
1.802
Total for spray primer and topcoat applications.
Total for EDP primer, guide coat, and topcoat applications.
3-29
-------
in the rinse water and returned to the dip tank. Emissions of VOC from EDP
i
are, therefore, very low.
In the case of spray coating, the transfer efficiency varies, depen-
ding on the type of spraying technique used. Transfer efficiency for
nonelectrostatic spraying ranges from 30 to 50 percent; the range for
13
electrostatic spraying is from 68 to 87 percent.
I
State or intrastate regulations also influence emissions. Many States
have statewide or district regulations for the control of hydrocarbon
•
emissions from stationary sources.
3.2.2 The Basic Processes - Light-Duty Truck Industry
1
3.2.2.1 General
i
With little exception, the surface coating operations of a light-duty
••
truck body are the same as for an automobile body. The production rate
is usually slower than for automobiles, 35 to 38 units per hour versus 30
to 70 units per hour for automobiles. The process diagram in Figure 3-2
showed the consecutive steps of the light-duty truck surface coating opera-
tions. Unless otherwise noted, it may be assumed that statements regarding
automobiles also hold true for light-duty trucks.
i'
I
3.2.2.2 Primer Coating
Solvent emissions data for solvent-based primer were derived from
information collected from light-duty truck manufacturers. The average
solvent emissions of plants using solvent-based primer were calculated to be
5.31 liters per truck for the primer application. Assuming that a light-duty
truck production line operates at a production rate of 38 light-duty trucks
per hour and two (8-hour) shifts per day, 608 light-duty trucks are pro-
duced daily. This means that approximately 2,709 kg of solvent (basis:
3-30
-------
density of 0.839 kg per liter) are discharged daily from the primer appli-
cation process. A material balance showing the discharge of emissions at
different steps in the solvent-based primer application process is presented
.in Table 3-15. Discharge of solvents to the atmosphere during primer
application occurs as follows: 88 percent loss during application and
12 percent loss during oven drying of the coating. Energy requirements for
the primer application in a light-duty truck production line are shown in
Table 3-16.
3.2.2.3 Solvent-based Topcoat
Table 3-17 presents the base case material balance for solvent-based
topcoat application. The energy balance for solvent-based topcoat opera-
tions is shown in Table 3-18. The process steps of the solvent-based
topcoat operation were given in Figure 3-3.
Average percent solids content for solvent-based topcoat is 31 percent
volume for light-duty trucks. The amount of overspray ranges from 35 to
60 percent for solvent-based topcoating.
3.2.2.4 Emission Characteristics
The types of solvent-based coating solvents and thinners used in the
lioht-duty truck industry are essentially identical to those used for
automobiles and described in paragraph 3.2.1.6, except that lacquers are
seldom used for light-duty trucks.
As mentioned previously, solvent emissions occur at the application
and cure steps of the surface coating operation. Calculation of solvent
emissions from plants visited resulted in the emission factors for the
primer and topcoat operations given in Table 3-19. Assuming that the
production rate of a surface coating operations is 608 light-duty trucks
3-31
-------
Table 3-15. MATERIAL BALANCE FOR SPRAY APPLICATION OF
SOLVENT-BASED PRIMER TO LIGHT-DUTY TRUCKS
Item
Liters Per .
145,920 Trucks'
Coating applied (30% solids by volume)
* Coating (40% solids by volume as bought)
• Thinner
• Total coating applied
Material loss in the application step
(43% transfer efficiency)
* Solids
• Solvent discharge
• Total material loss
Total coating on body (after flash-off)
Oven evaporation loss
• Solvent discharge
Net dry solids on body
829,555
276,518
1,106,073
189,140
I
681,340
870,480
235,593
92,907
142,686
aThe annual production figure of 145,929 trucks was derived as follows:
(1) Production rate - 38 trucks/hr; (2) Time - 2 shifts (8 hlfs/shift)
per day, 240 days/yr; or 38 trucks/hr x 3,840 hrs/yr = 145,920 trucks/yr.
3-32
-------
Table -3-16. ENERGY BALANCE OF PRIME COAT APPLICATIONS
FOR LIGHT-DUTY TRUCKS
Coating
Application
(106 Btu/hr)
Cure
(106 Btu/hr)
Total
Solvent-based
Spray Primer
EDP Primer
12,403
39,135
38,818
49,965
52,221
88,100
aThis amount is highly dependent on climate since outside air must be
heated to comfortable temperatures. The amount of heat required for
this can be twice that required for curing.
3-33
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Table 3-17. MATERIAL BALANCE FOR SPRAY APPLICATION OF SOLVENT-BASED
ENAMEL TOPCOAT TO LIGHT-DUTY TRUCKS
Item
Liters Per
145,920 Trucks
Coating applied (28% solids by volume)
• Coating (31% solids by volume)
• Thinner
• Total coating applied
Material loss in the application step
(43% transfer efficiency)
* Solids
• Solvent discharge
• Total material loss
Total coating on body (after flash-off)
Oven evaporation loss
• Solvent discharge
Net dry solids on body
1,603,807
171,835
1,775,642
281,701
1,127,657
1,409,368
366,284
150,805
215,479
3-34
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Table 3-18. ENERGY BALANCE FOR APPLICATION OF
SOLVENT-BASED ENAMEL TOPCOAT TO
LIGHT-DUTY TRUCKS
Operation Steps
106 Btu/Yr
Application
Cure
31,796
102,388
Total
134,184
3-35
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Table 3-19. AVERAGE EMISSIONS FOR LIGHT-DUTY TRUCK
SURFACE COATING OPERATIONS
Spray Primer and Tocoat Applications
Coating
Application Cure
(liters/truck) (liters/truck)
Total
Primer-
Sol vent-based spray
Topcoat-
Sol vent-based spray
Total a
Primer-
EDP
Guide coat-
Sol vent-based spray
Topcoat-
Sol vent-based spray
Total b
4.67
7.73
12.40
0.18
1.24
7.73
9.15
0.64
1.03
1.67
0.03
0.17
1.03
1.23
5.31
8.76
14.07
0.21
1.41
8.76
10.38
aTotal for spray primer and topcoat applications.
bTotal for EDP primer, guide coat, and topcoat applications.
3-36
-------
per day (38 vehicles per hour, two 8-hour shifts per day), 7,167 kg of
solvent (basis: density of 0.839 kg per liter) will be discharged daily
from the surface coating operation.
Solid waste generated by the light-duty truck surface coating
operations was also determined based on data collected from the industry.
Table 3-20 shows solid waste factors for the light-duty truck surface
coating operations.
3-37
-------
Table 3-20. AVERAGE SOLID WASTE GENERATED FOR LIGHT-DUTY
TRUCK SURFACE COATING OPERATIONS
Coating
Average Transfer Loss of
Solids in Coatings
(liters/car)
Priraer-
Sol vent-based spray
Topcoat-
Sol vent-based spray
Total3
Printer-
EDP
Guide coat-
Sol vent-based spray
Topcoat
Solvent-based spray
Total5
1.300
1.930
3.230
0.003
0.310
1.930
2. 243
aTotal for spray primer and topcoat applications.
''Total for EDP primer, guidecoat, and topcoat applications.
3-38
-------
3.3 REFERENCES
1. Larson, C.J. Transportation and Capital Equipment Division. U.S. Indus-
trial Outlook 1975. Washington, D.C., U.S. Department of Commerce.
p. 133.
2. Motor Vehicle Manufacturers Association. Motor Vehicles Facts and
Figures, 1977 and 1978.
3. Wards Automotive Yearbook, 1978.
4. Wark, D. Automotive Study. Enfield, Connecticut, DeBell & Richardson,
1977. pp. 24-27.
5. Wards Automotive Yearbook, 1976.
6. Automotive News, 1975 Almanac.
7. Automotive News, 1976 Almanac.
8. Air Pollution Engineering Manual. Cincinnati, Ohio, U.S. Department
of Health, Education, and Welfare, 1967 p. 711.
9. Letter from Johnson, W.R., General Motors Corporation, to McCarthy,
J.A., EPA. August 13 1976. Comments on "Guidelines for Control of
Volatile Organic Emissions from Existing Stationary Sources."
10. Letter from Sussman, V.H., Ford Motor Company, to Radian Corporation.
March 15, 1976. Comments on report "Evaluation of a Carbon Adsorption/
Incineration Control System for Auto Assembly Plants."
11. Reference 9.
12. Conversation of J.A. McCarthy, EPA, with Fred Porter, Ford Motor
Company. September 23, 1976.
13. Waste Disposal from Paint Systems Discussed at Detroit, Michigan.
American Paint & Coating Journal. February 23, 1945.
3-39
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-------
4. EMISSION CONTROL TECHNIQUES
4.1 GENERAL
This chapter and Chapter 6 both analyze the available emission
control technology for the automobile and light-duty truck industry.
Chapter 4 defines the emission reduction performance of specific control
techniques; Chapter 6 evaluates complete emission control systems that
combine finishing processes with one or more emission reduction techniques.
The control techniques discussed in this chapter minimize emissions
of volatile organic compounds (VOC) to the ambient air. These VOC —
primarily ketones, alcohols, esters, saturated and unsaturated
hydrocarbons, aromatics and. ethers — make up most of the solvents used
for coatings, thinners, and cleaning materials in industrial finishing
processes.
Several types of control techniques are presently used within the
automobile and light-duty truck industry. These methods can be broadly
categorized as either add-on control devices or substituting new coatings
application systems. Add-ons reduce emissions by either recovering or
destroying the solvents before they are discharged into the ambient air.
Such techniques include thermal and catalytic incinerators and carbon
adsorbers. New coatings become control methods when coatings containing
relatively low levels of solvents are used in place of high solvent
content coatings. Such methods include electrodeposition of water-based prime
-------
coatings and air or electrostatic spray of water-based and powder coatings.
Because of the lower solvent content of the new coatings, these
application methods are inherently less polluting than processes that use
conventional solvent-based coatings.
The following discussion characterizes the control techniques and
defines the emission reduction associated with each technique in the auto
and light-duty truck industry.
4.2 THE ALTERNATIVE EMISSION CONTROL TECHNIQUES
4.2.1 Water-Based Coatings
Water-based coatings are the most common VOC control technique
currently used in the automobile and light-duty truck industry. Most
water-based coatings are applied as primers by electrodeposition; water-
based spray topcoats and surfacers are used considerably less often than
water-based primers.
The terminology for water-based coatings is confusing ~ the names
of the various coating types are often misused or used synonymously, the
i , ]:•
term water-based, as discussed here, refers to any coating that uses water
primarily as the carrier and is meant to distinguish such coatings from
solvent-based coatings.
There are three types of water-based coating materials: latex or
emulsion coatings; partially solubilized dispersions; and water-soluble
coatings. Table 4-1 lists the significant characteristics of these three
water-based coatings. The indicated properties are not absolute, since
individual coatings vary.
The following sections describe the two methods of applying
water-based coatings used in automobile and light-duty truck surface
coating lines — electrodeposition and air spray.
4-2
-------
TABLE 4-1. WATER-BASED COATINGS
1
Properties
Resin particle
size
Molecular
weight
Viscosity
Viscosity
control
Solids at appli-
cation
Gloss
Chemical resis-
tance
Exterior dur-
bility
Impact resistance
Stain resistance
Color retention
on oven bake
Reducer
Washup
Latex or
mulsion coatings
0.1 micron
1 million
Low, not depen-
dent on molecu-
lar weight
Requires thick-
eners
High
Low
Excellent
Excellent
Excellent
Excellent
Excellent
Water
Difficult
Partially
solubilized
dispersions
<0.1 micron
50,000 - 200,000
Somewhat dependent
on molecular
weight
Thickened by addi-
tion of cosolvent
Intermediate
Low to medium-
high
Good to excellent
Excellent
Excellent
Good
Excellent to good
Water
Moderately
difficult
Water-soluble
coatings
—
20,000 - 50,000
Very dependent
on molecular
weight
Governed by mo-
lecular weight
and solvent per-
cent
Low
Low to highest
Fair to good
Very good
Good to excellent
Fair to good
Good to fair
Water or water/
solvent mix
Easy
4-3
-------
4.2.1.1 Electrodeposition
System Description
In electrodeposition (EDP) water-based dip systems, the vehicle to
be coated is immersed in a water-based coating, arid an electric potential
difference is induced between the vehicle and the coating bath. Current
flow through the bath causes the coating particles to be attracted to and
deposited on the metal surface. By correctly setting the electrical
potential and the time in the bath, the coating thickness can be controlled
O i I
within 5 x 10 millimeters (0.2 mil). Corrosion protection is excellent
because coverage is more complete than can be obtained by spray priming
alone. Figure 4-1 shows a typical EDP process with coating and water
2345
reuse. Such systems have been described in detail in the literature. ' ' '
The paint in the bath consists of 5 to 12 volume percent solids, 80 to
467
90 volume percent water, and about 5 volume percent organic cosolvent. ' '
Organic solvents used in water-based coatings are high molecular weight
i
. • • i
organic compounds; these compounds are added to help fuse the coating
particles into a continuous film. The coating solids displace solvent as
they are deposited, and the solvent is squeezed out. As the vehicle
component emerges from the bath, its coating is about 90 to 95 volume
percent solids, 5 to 9 volume percent water, and less than 1 volume
percent organic cosolvent. Excess coating is washed from the vehicle with
a spraywash. The solids are concentrated by ultrafiltration and returned
to the bath while the water is recycled to the spraywash.
Only water-based coatings can be applied by electrodeposition
(EDP). Currently, EDP (also called electrocoating) is used in more than
':, ' i
half of the existing assembly plants for applying automotive primers to
! I
bodies and parts. Traditionally, in applying EDP coatings the tank or
4-4
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4-5
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grids on the periphery are negatively charged while the part is
grounded.8 This is called anodic EDP.
i
Cathodic EDP, in which the part is negatively charged, is a new
technology which is expanding rapidly in the automotive industry.
Increased corrosion resistance and lower cure temperatures (generating
less odorous organic emissions) are two main reasons for this change from
,
anodic to cathodic systems. Cathodic systems are also capable of applying
better coverage on deep recesses of parts. Since cathodic EDP has these
advantages, and industry is presently converting to cathodic, it will be
used as the base EDP system in this document. '
In a typical EDP operation, bodies or parts are loaded on a
i • i
conveyor that first carries them through a pretreatment section for
cleaning. The treated and washed bodies or parts are automatically
lowered into the EDP tank containing the water-based coating. To avoid
marking the coating, direct current electrical power is not applied until
:i 1
the part is totally submerged. Current flow through the bath causes the
coating particles to be attracted to the metal surface, where they deposit
as a uniform film. The polymer film that builds up tends to insulate the
part and prevent further deposition. Dwell time in the tank is typically
1-1/2 to 2 minutes.4'6'9'10
The current is then shut off. The parts are raised out of the bath,
allowed to drain, rinsed to remove dragout, and then baked. Solids from the
dragout are collected in the rinse water and are usually returned to the EDP
11 12
tank. This recovery can result in coating savings of 17 to 30 percent. '
i
Excess water is removed from the coating bath using an ultrafilter.
After electrodeposition, the coatings are baked; the solvent and
water evaporate to leave a cured film that closely resembles a solvent-
4-6
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10
based finish. Some EDP coatings contain amines that are also
volatilized during curing. Since these amines can produce malodors or
visible emissions some oven exhaust gases are incinerated. Such emissions
and malodors are minimal for cathodic EDP, which uses a lower cure
temperature than anodic systems.
The solubilized resins used in automobile and light-duty truck
primers are generally based on malenized oils or malenized polyester.
These resins are combined with pigments, such as carbon black and iron
oxide, and are dissolved in a water-solvent mixture which contains about
5 percent organic cosolvent. The solvents used are typically higher
molecular weight organic compounds, such as ethylene glycol monobutyl
TM 8 '
ether (butyl cellosolve ).
Parts coated by EDP are normally baked from 15 to 30 minutes at
160° to 190°C (300° to 400°F), with the higher temperatures being
used for automobile and truck primers. ' ' ' '
The conveyors, pretreatment section, and bake oven used for EDP are
conventional items. The critical components of the EDP system include the
14 17
following: '
t Dip tank ~ The dip tank is a large rectangular container
generally with a capacity of 120,000 to 320,000 liters (32,000
18
to 85,000 gallons), depending on part size. Larger tanks
are used for priming bodies, while smaller units are used for
coating parts, such as fenders and hoods. The tanks are coated
internally with a dielectric material, such as epoxy, and are
4 9
electrically grounded for safety. ' Shielded anodes are
submerged and usually run along both sides of the tank
4-7
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t Power supply -- Direct current electrical power is supplied by
a rectifier which has a capacity of approximately 250 to
500 volts and 300 to 2500 amperes, depending on the number of
square feet per minute to be finished
j
• Heat exchangers — Coating drawn from the dip tank is passed
through a heat exchanger to dissipate heat that is developed
during the coating operation. The temperature is normally
maintained at 20° to 24°C ± 1°C (68° to 75°F ± 2°F).4'7'9
! '
a Filters — An in-line filter is also placed in the
recirculating system to remove dirt and polymer agglomerates
from the coating
• Pumps — Recirculating pumps are used to keep the coating
solution stirred
• Ultrafiltration unit — Excess water is removed from the
coating in this unit. The concentrate, with the coating, is
returned to the dip tank. The excess water, called permeate,
is used as rinse water.
• Coating mixing tank — Coating mixing tanks are used to premix
and store coating solids for adding to the dip tank as needed
• Control panel — The electrodeposition process is generally
controlled from a central control console. This panel contains
all start-stop switches plus instruments for monitoring
voltage, amperage, coating temperature,, and pH.
Factors Affecting Performance
Proper pretreatment can be critical to coating performance,
particularly if the substrate has grease or oil on the surface. Solvent-
based coatings will usually dislodge an occasional oil spot, but water-
4-8
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based will not. Cleaners developed for solvent-based coating systems
are generally adequate for EDP.
Similarly, for satisfactory appearance of the final finish, the
parts should be rinsed thoroughly after the EDP coating has been applied;
the final rinse should be deionized water.
Coating in the dip tank is affected by voltage, current density,
20
temperature, dwell time, pH, and solids content. For successful
operation of an EDP system, these parameters must be monitored on a
regular basis. By increasing the voltage or the temperature in the bath,
the film thickness can be slightly increased. However, excessively high
voltage will cause holes in the films because of gassing. Too high a
temperature is also undesirable; some coatings will flocculate at
temperatures approaching 90°C. Refrigeration of the bath is necessary
to maintain temperatures below this point. At high pH, a reduction in the
deposition occurs; if the pH drops below the isoelectric point (acidity
level where dispersing forces equals cohering forces), the total coating
in the bath can coagulate. If the solids content in the coating is too
high, the voltage pulls the solids strongly enough to press the moisture
from the deposited film; if the bath is too dilute, then the film will be
thin. Film buildup is usually about 0.018 millimeters (0.7 mil).
Solvent emissions are related to both coating composition and
production rate. The greater the quantity of solvent in the water-based
coating, the greater the air emissions. Production rate has an influence
on emissions: the higher the rate, the greater the emissions. This rate
depends on the area of the parts, their spacing on the conveyor, and the
conveyor speed.
4-9
-------
Normally, there are no solids transfer loss problems with
electrodeposition; nearly all the coating solids are transferred to the
part. Dripping can be associated with dragout, but; this material is
recovered in the rinse water and returned to the dip tank.
i
When an emission reduction is achieved by replacing solvent based
primer by a low solvent substitute, the percent reduction is related to
the emission level of the original solvent which depends on the percent
solvent in the coating and on the transfer efficiency. The reduction is
also related to the EDP system emissions which are equal to the organic
solvent added to the tank; normally just the organic solvent in the
1
coating applied, since solids transfer is 99+ percent complete.
Application
EDP is not used alone for most automobile and light-duty truck
primers. Most employ a primer surfacer, also called surfacer or
guidecoat, to build film thickness and permit sanding between the primer
and topcoat. These primer surfacers are applied by spraying and can be
either solvent or water-based. Because of the solvent content, they can
have a significant effect on the overall solvent emissions for primer
i
operations (see Chapter 6 — Emission Control Systems).
4.2.1.2 Water-Based Spray
Since applying water-based coating by EDP is limited to one-coat
priming, auto manufacturers have chosen spray coating for applying water-
based surfacers and topcoats.21'22'23 Such surfacer and topcoat systems
21 22
are used in production at three General Motors plants; * a similar,
23
but experimental, line in Canada is operated by the Ford Motor Company.
General Motors automobile plant recently started up in Oklahoma City uses
4-10
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gu1decoat and topcoat and a light-duty truck plant be1ng
for Shre.ap.rt. Louisiana may use water-based guidecoat and topcoat
The topcoat materials used are thermosettlng acrylics with 23 to
25 volume percent solids and water/so,vent ratios of 80/20 to 88/12 in the
liquid portion of the coating 21»22>23,24,25 _.
9* These coatings contain a
solvent to solids ratio in the range of 0.30 to 0.67 by vo,»e.
As with any coating airborne emissions, volatile organics from
..ater-based guidecoat and topcoat operations depend on the percent solids
-d solvent in the coating and the thickness of the coating that is
applied.
One critical factor in any spray operation is transfer efficiency
or that percentage of the coating app,ied that actually deposits on the
Part. This factor can have serious effects on sessions, cost, and
secondary pollutants.
By surveying the industry, an investigator found that spray
efficiencies^depended on the manner of coating application and charge on
the sol,ds. Transfer efficiencies of 30 to 60 were reported for
co«n air spray systems which averaged « percent for organic and water-
based coating. Continuous monitorins of the process line spray control
shou,d ensure transfer efficiencies „,„ ™ain Up to 40 percent even when
spraying thicker coats.
4'2-1'3 Po"l°ination of EDP and M^-Based TonMat
The advanced technology of utilizing water-based spray coating for
surfacing and topcoat finishes, subsequent to the electrodeposition
pnmer, has become operational for three automobile assembly plants
Although costs and energy requirements are higher, these systems have been
4-11
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successful in producing a satisfactory product that has less than a
27
quarter of the VOC emissions typical of solvent coatings.
The general finishing processes for the three General Motors plants
21 22
using water-based surfacer and topcoats are similar. ' The finishing
process at the General Motors South Gate, California plant has been
27
described as follows:
1. A conventional cleaning and phosphating with no dry-off
2. An electrodeposition primer application followed by baking
3. Applying sealers
4. Coating with an epoxy ester-based water-based spray primer
surfacer (guide-coat) using automatic and manual air spray
"5. Flash-off for 5 to 8 minutes in a 77°.to 93°C (170° to 200°F)
tunnel
6. A partial bake
7. Applying interior coating plus additional sealant. The coating
used here is a water-based acrylic enamel.
8. Final baking of the primer
, '
9. Wet-sanding and masking of the interior
10. Applying a water-based acrylic enamel topcoat in two separate
booths with a flash-off and set-up bake after each application
11. Coating the trunk with a water-based emulsion coating
12. Touch-up and accent color application in a third booth
t ,-[,„,. r' : : ; , i
13. A final bake at 163°C (325°F) for 30 minutes
In addition to automobile topcoats, water-based coatings are also
being used to finish components, such as wheels, and engines.
, n,, ' j»„ I, I • , ' '- "r ' . •
28,29,30
4-12
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4.2.2 Powder Coating
Powder coating, although considered here as a new coating method,
31
has been used since the 1950's. Fluidized-bed coating began in the
early 1950's, and electrostatic spray of powder was introduced in the
early 1960's. Powder coating involves applying 100 percent solid
materials in dry powder form; no solvents are used, although traces of
organics can be driven off from the resins during curing. Such a system
.emits small quantities of VOC; however, its use is limited to small
specific industry lines that can accept the lower flowout quality of
coating finish.
Powder coating materials are generally available as both
thermoplastic and thermosets, but the thermosets are the only materials
used to provide thins high-performance finishes as used for automobiles
and light-duty trucks. Powder coating is being used throughout the
industrial finishing industry for such diverse painting applications as
metal furniture, wire goods (baskets, racks, and shelves), piping, tubing,
32 33 34
fencing, posts, garden tractors, lawn equipment, and bicycles. ' '
In the U.S. automotive industry, powder coating has been used on
two pilot lines for applying topcoats and has also been applied to
under-the- hood parts, such as oil filters and air cleaners, as well as
35-41
bumpers, trailer hitches, and emergency brake cable guides.
In Japan, Honda is topcoating cars with powder at a continuous
production rate and Nissan Motor Company began applying powder topcoats to
42
trucks sometime during 1977. Nissan is constructing a new plant at
Kanda, North Kyushu, where powder topcoats will be applied to light-duty
trucks. Trucks will be finished in one of eight colors; all applied in a
43
single spray booth.
4-13
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The most significant use of powder for automobile finishing in the
U.S. is a pilot line being used for applying topcoats by the Ford Motor
Company at Metuchen, New Jersey. This line has been successfully
finishing Pintos in solid colors since 1973.36 Cars from this line can
i
be obtained in one of eight colors. The powder coating operation has been
placed adjacent to the main assembly line. Before powder finish, cars are
pretreated and primed in an identical manner to cars receiving conventional
finishes. Cars to be powder coated are moved from the main assembly line
and are painted by electrostatic spray in one of two booths. The bulk of
the coating is applied with automatic powder guns. Inaccessible areas are
oc
hand sprayed. Overspray is approximately 35 percent, most of which is
p
recovered. For good flowout, a 6.3 to 7.6 x 10" millimeters (2.5 to
3.0 mil) coating is applied, which equals approximately 2.9 kilograms (6.5
pounds) of topcoating per car.36 To fuse and cure the coating, the cars
are baked at 177°C (350°F) for 30 minutes. Following finishing and
baking, the cars are moved back into the main assembly line.
However, Ford has not successfully demonstrated applying powder
: j '
metallic coatings. In applying solvent-based coating, the viscosity is low
enough for the metallic flakes to turn and orient parallel to the surface
as the coating dries. With powder, the molten polymer is viscous; the
flake keeps a random orientation, making the appearance less aesthetically
pleasing. This is of great importance, since metallic coated vehicles
account for over 50 percent of sales. A demonstrated control option must
be applicable to a major segment of the industry. The unavailability of
, i ,-• j
metallic powders becomes a critical factor in using powders because
frequent color changes, including metallics, are required in normal
1 ' i
assembly operation.
4-14
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On a typical automobile or light-duty truck assembly line, the color
of the topcoat is determined by individual orders, which may come
completely at random. This requires a color change after each vehicle.
The time allowed for the change is dictated by the line speed, which
permits approximately 13 seconds between vehicles. Color changes require
removal of essentially all powder from the booth, lines, and guns as color
contamination will give the finished coat a salt-and-pepper look from
dissimilar color particles. Ford has been able to modify their
equipment to meet these requirements for one basic line.
Since metallic powder coatings are not currently available, powder
coatings are not considered a demonstrated control option for the purpose
of this study.
4.2.3 New Coating Development
New coatings containing higher solids fraction are attractive
because they can potentially be used to apply the same weight of paint
solids as typical coatings but have reduced volatile organic emissions.
These coatings are either categorized as radiation curable systems, higher
solids nonaqueous dispersion coatings, high-solids coatings, or powder
coatings. Powder coating, the most fully developed but use-limited system
has already been discussed (Section 4.2.2).
Radiation-Cured Coating
Radiation-cured coating involves photocuring mixtures of low
molecular weight polymers or oligomers dissolved in low molecular weight
acrylic monomers. These formulations contain no solvent carriers and can
45 46 47
be cured using either electron beam or ultra-violet light sources. ' '
Although attractive because of low VOC generation, these coatings have
gained little interest in the auto industry. Presumably, this lack of
4-15
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I
interest is because of the health hazard associated with spray application
of these relatively toxic monomer mixtures and the difficulties involved
in obtaining adequate cure of paint when it is applied to irregularly
shaped substrates.
Medium-solid Nonaqueous Dispersion
During the early 1970's, medium-solid nonaqueous dispersion (NAD)
coatings began to generate interest as spray topcoats for domestic and
foreign automobiles. As a result, several companies are now using NAD
coatings on automobile and truck assembly lines for applying both lacquer
48 49
and enamel topcoats. '
NAD enamels used in the industry have essentially the same solvent
I"
contents as their solution enamel counterparts. Although higher solids
contents are technically feasible, these have not been realized because of
application and appearance problems. Therefore, the present NAD enamels
are no less polluting than solution enamels.
Most of the impetus behind the switch to NAD coatings was because
dispersion coating builds sufficient film rapidly without the sagging and
solvent popping usually associated with solution enamels and lacquers.
Using NAD lacquer also allowed spray application at almost double the
usual solids for solution lacquers, thereby cutting the required number of
coats by 40 to 50 percent. These improved application performances made
it possible to shorten coating line time by 50 to 60 percent without
50
capital investment in equipment or facilities.
Presently in the industry, topcoats are being applied either from
nonaqueous dispersion and solution lacquers or from nonaqueous dispersion
enamels. A small percentage of automobiles are still being finished with
solution enamel paints.
4-16
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Most of the automobiles produced at General Motors are finished
with lacquers; these represent about half the domestic production. These
lacquers range from approximately 12 to 18 volume percent solids applied,
depending on whether the lacquer is a nonaqueous dispersion or a solution.
Most of the vehicles manufactured by Ford, Chrysler, and American
Motors are being topcoated with NAD enamels. General Motors uses these
coatings for their trucks. These enamels vary in their degree of
dispersion; in fact, some come very close to being solutions. Solid color
NAD enamels, which are relatively low in dispersion, are supplied at a
solids content generally in the range of 39 to 42 volume percent.
Metallic NAD enamels tend to be higher in dispersion than solid colors and
48 49
are normally supplied at 33 to 37 volume percent solids: . ' these
enamels are then diluted with solvent for application.
High-solids coatings
High-solids coatings are relatively new materials currently being
developed and investigated in the automotive, can, coil, and appliance
industries. The attraction of high-solids coatings (technically a medium
high solids content) seems to be their low solvent content, the promise of
application with conventional finishing equipment, and the promise of
energy savings through the use of more efficient application. Although
the traditional definition of high solids as specified in "Rule 66"
indicates no less than 80 volume percent solids, most people in
industry consider everything from 60 to 100 percent as high solids.
High-solids coatings will very likely not contain radically new resin
binders; most will be modifications of their low-solids counterparts.
These coatings can be categorized as either two-component/ambient-
curing or single-component/heat-converted materials. The coatings of the
4-17
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most immediate interest are the two-component/ambient-cured materials;
they offer a reduced solvent content and tremendous energy savings since
i
they require little, if any, baking.
Heat-converted, high-solids coatings, on the other hand, are baked
at temperatures similar to their low-solids counterparts — nominally
150° to 175°C (300° to 350°F). Resin systems being investigated
for two component materials include epoxy-amine, acrylic-urethane, and
urethane.*2'53'54'55
The most significant problem with high-solids coatings is the high
i ' i
working viscosity of the solution (due to solids at 60 to 80 volume
percent).54 The viscosity can be partially controlled by reducing the
molecular weight of the base polymer or by using reactive diluents, but
these techniques can result in a greatly altered product with inferior
properties. Heating the coating during the application is a more
effective means of reducing viscosity. Heated high solids can be
applied as airless, air, or electrostatically sprayed finishes from heated
equipment. They can also be roll coated.
i i i
In general, high-solids coatings hold a great deal of promise.
i • I
However, they are an emerging technology and are considered still in their
infancy.56 Of the approximately 1514 million liters (400 million gallons)
i
of industrial finishes consumed in 1975, less than 1 percent were high
solids.57 Most of these high solids coatings were used in coil and can
i
coating. None were used in the automotive industry. Recent developments on
i
50 to 60 percent solids coatings indicate that they are feasible for
automobile finishes and are expected to be widely used by 1982.
4-18
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4.2.4 Carbon Adsorption
System Description
The adsorption of VOC onto granular activated carbon column (ACC)
is effective for assembly plant contaminated airstreams. Economic
feasibility of such a system (a distinctly different consideration than
effectiveness) is directly dependent on the unit size and carbon life.
Unfortunately, the highly diluted VOC concentrations and large airstream
volumes found in auto and light-duty truck lines make widespread use of
ACC prohibitively expensive. Using this system for VOC control on small
emissions has been feasible in specific cases which have usually been
outside the automobile .and truck coating field.
Carbon adsorption as a technique for solvent recovery has been used
commercially for several decades. Applications include recovering solvent
from dry cleaning, metal decreasing, printing operations, and rayon
manufacture, as well as industrial finishing. ' ' ' Recovering
coating solvents from industrial finishing operations by adsorption has
some technical problems; however, the process is essentially no different
than any other being used for solvent recovery.
In the automobile and light-duty truck industry, the emissions of
greatest concern come from spray booths for each coating operation and
their respective bake ovens. Approximately 10 to 15 percent of the
CO
volatiles from solvent-based coatings are emitted in ovens. The
remaining 85 to 90 percent volatilizes in the spray booth and flash-off
area.
Applicability to Spray Booths
Applying carbon adsorption to spray booth emission control requires
unique design considerations because of the very high passthrough
4-19
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airflow. Flowrates as high as 94 to 188 cubic meters per second (200,000
I
to 400,000 cfm) are required for operator safety in manned booths and for
preventing cross contamination of adjacent car and light-duty truck bodies
from overspray.63'64 Using effective design loadings from one report,
three adsorbers 6.1 meters (20 feet) in diameter would be required to
C*3
handle air flows of this magnitude. While no such units are presently
used in the auto industry, systems of this size have been
constructed.65 Lacquer coating systems would require even larger units.
As a consequence of the high airflow, the solvent vapors are
diluted to a very low level, normally 50 to 200 ppm. The solvent
concentration corresponds to 2 percent or less of the lower explosive
i
limit (LEL). This low concentration lowers the adsorption capacity of the
carbon, thereby requiring a larger adsorber unit to remove the same
quantity of solvent as from a more concentrated air stream. However,
reducing air flow with increased vapor concentration is technically
i
feasible. For example, DuPont was able to demonstrate on one automobile
assembly line that substantial reductions could be achieved by maximizing
i ,
use of automatic painting, reducing booth length, avoiding longitudinal
mixing between manual and automatic painting zones, and staging of
solvent-laden air exhausted from manual zones through automatic zones.'
i
In addition, adsorption systems for spray booth emissions must be
designed to handle air with a high water vapor content. This high
.
humidity results from using water curtains on both sides of the spray
1 !
booths to capture overspray. Although carbon preferentially adsorbs
organics, water will compete for available sites on the carbon surface.
Generally, the relative humidity should be kept below 80 percent to
minimize this problem.
66
4-20
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The exhaust from the spray booths, particularly during periods of
(TO
cool ambient temperatures, can become saturated with moisture . One
solution to this problem would be to preheat the moisture-laden air to
lower the relative humidity below 80 percent; a 4° to 5°C (7 to' 9 F)
CO
temperature rise would be sufficient.
Before adsorption, particulates from oversprayed coating should be
removed from the air streams, since this material coats the carbon and
plugs the interstices between carbon particles. Such plugging reduces
adsorption efficiency and increases pressure drop through the bed. These
particulates can be removed by using either a fabric filter or the
combination of a centrifugal wet separator plus prefilter and bag
filter.66
Another variable that should be considered in designing an adsorber
for this application is the potential variability of the solvent systems
between different grades or types of coatings. Although all automotive
spray coatings contain the same families of solvents (i.e., glycol ethers,
esters, CR and Cq aliphatics), the various coatings used can differ
widely in specific compounds and relative proportions. Therefore, solvent
systems differ in their adsorptive characteristics and in their ability to
be removed by the adsorber. On lines where different coatings- are
periodically used, adsorbers will probably have to be overdesigned in
adsorptive capacity to be reliable.
Applicability to .Bake Ovens
Ovens are the second major source of solvent emissions. Adsorbers
for ovens will have to be designed to handle a different solvent mix than
is found in spray booths and flash-off areas. The solvent emitted in the
spray booth and flash-off area comprises a large percentage of low boiling
4-21
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point organic compounds, such as acetone, butanol, and toluene. Solvent
remaining in the film as it enters the oven contains the less-volatile
solvents. High-boiling point solvents may not consistently be completely
stripped during activated carbon regeneration; thus, more frequent
replacement of the carbon would be likely. Hot gas or superheated steam
regeneration would probably be required to improve their removal.
In the oven, high temperatures and flame contact can cause
polymerization of the volatiles into high molecular weight resinous
materials that can deposit on and foul the carbon bed. Various high
molecular weight volatiles in the coatings, such as oligomers, curing
agents, or plasticizers, can cause a similar problem. Filtration and/or
condensation of the oven exhaust air would be necessary before adsorption
to remove these materials. Further, to get satisfactory performance, the
oven exhaust would have to be cooled to no greater than 38 C. Without
i
cooling, many of the more volatile organics will not adsorb but will pass
through the adsorber. *
Carbon adsorption cannot be considered as a viable control option
at this time because this auxiliary equipment has not been demonstrated as
economically feasible.
4.2.5 Incineration
Incineration is the most universally applicable technique for
1 , l
reducing the emission of volatile organics from industrial processes.
While incineration of many industrial wastes may have adverse byproducts
of SO and NO emissions, these are not a concern for finishing coatings
which are principally hydrocarbons.
Industrial incinerators or afterburners are either noncatalytic
72
(commonly called thermal or direct fired) or catalytic. There are
i
4-22
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sufficient differences between these two control methods to warrant a
separate discussion for each.
4.2.5.1 Thermal Incinerators
System Description
Direct-fired units operate by heating the solvent-laden air to near
its combustion temperature and then bringing it in direct contact with a
flame. In general, a temperature of 760°C (1400°F) is sufficient for
nearly complete combustion. A typical unit is shown schematically in
Figure 4-2.
To prevent a fire hazard, industrial finishing ovens are seldom
operated with a concentration of solvent vapor in the.air greater than
.25 percent of the lower explosive limit (LEL), about 6000 ppm. Ovens in
the automobile and light-duty truck industry achieve concentrations of
only 5 to 10 percent LEL. These low concentrations are the result of the
high air flows that prevent oven gas escaping from oven openings and
high^-boiling point organics condensing on the inner surfaces of the
oven.
In spray booths, the concentrations are maintained at even lower
levals to protect the health and safety of the workers. Although most
spray booths currently operate at no more than 2 percent of LEL (see
Section 4*2.6), some plant innovations have helped maintain workers'
safety and also generated more concentrated air streams.
Because of the low VOC concentrations from current ovens and spray
booths, auxiliary heating is required to burn the vapors. Natural gas
combustion usually provides the energy for direct flame contacted, thermal
incinerators. Propane and fuel oil are also used. ' For most
solvents the fuel value is equivalent to 185630 joule per cubic meter
4-23
-------
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I 3
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-------
(0.5 Btu/scf), which translates into a temperature rise of approximately
15.3°C (27.5°F) for every percentage point of LEL that is
incinerated. For an air stream with a solvent content of 10 percent
of LEL, the contribution from the heat of combustion of the solvent would
be approximately 188,370 joule per cubic meter (5 Btu/scf); this
equals a temperature rise of 138°C (248°F) at 90 percent combustion
efficiency. For a spray booth exhaust at 2 percent LEL, the solvent would
contribute only 28°C (50°F) to the-temperature rise needed to bring
the gases up to the 816°C (1500°F) required for complete combustion.
To reduce fuel costs of thermal incineration, primary heat recovery
is often used to preheat the incoming process vapors as illustrated in
78
Figure 4-2. Recuperative or fixed surface heat exchangers, either
tube or plate type, are capable of recovering 50 to 70 percent of the heat
from the original fuel input. '
The regenerative heat exchanger, widely used in vapor incineration
equipment, contains either refractory or rotary tube or plate surfaces
that are capable of 75 to 90 percent heat recoveries.78'80'81'82 In
some cases, secondary recovery is also used to convert additional exhaust
78
heat into process steam or to warm makeup air for the plant.
Factors Affecting Performance
Temperature and residence time are the main operating parameters
that affect the emission reduction potential of thermal incinerators for
automobile and light-duty truck coating operations. For complete
combustion of the hydrocarbons in the air stream, sufficient temperature
and residence time must exist in the incinerator. Figure 4-3 shows the
combined effect of these two parameters on pollutant destruction. From
the table, it can be seen that for typical residence times of 0.3 to
4-25
-------
100
esidence
time, aecon
427
(800)
538
(1000)
649
(1200)
760
(1400)
871
(1600)
983 1094
(1800) (2000)
Temperature, °C (°F)
Figure 4-3. Coupled effects of temperature and time on rate of pollutant
oxidation.77
4-26
-------
1 second, and temperatures of 700°C (1290°F) are necessary for
complete combustion to occur. Solvent type also can influence incinerator
performance. While 677°C (1250°F) is adequate to combust most solvent
vapors, certain organics from coating solids require temperatures of
760° to 816°C (1400° to 1500°F) for nearly complete oxidation.72
In the automobile and light-duty truck industry, the emissions from
spray booths and baking ovens are the two areas of highest potential for
using incinerators. Their use on bake oven exhaust can be implemented
with minimal difficulty. Such add-on control devices are in place on
ovens in several assembly plants, particularly in California. Typical
CA QO OA
emission reduction with such units is over 90 percent. ' ' Since
the air exiting the ovens is generally at a temperature of 120 to
150°C (250° to 300°F), air preheating requirements are small.
As stated earlier, bake ovens contribute only about 10 percent of
the solvent emissions from coating operations and therefore applying
incinerators to bake ovens would control only a small fraction of the
total VOC emissions. The remaining 90 percent of the volatiles are
emitted in the spray booth. Although incinerating of the air from spray
booths is possible, there has been no application in the automobile and
light-duty truck industry. Because of the large air flow in the spray
booths (as much as 94 to 188 cubic meters per second or 200,000 to 400,000
cfm), the resulting low solvent content of the air (2 percent LEL or less)
and the low temperature of the exhaust gas, large quantities of natural
gas or equivalent fuel would be required to heat the vapor-laden air to
the 700° to 760°C (1300° to 1400°F) necessary to effect nearly
complete combustion.
4-27
-------
Attention has been given to a potential legal conflict with
incinerating spray booth exhaust air. NFPA No. 33-1973, Section 4.2,
(also OSHA regulation Part 1910.107 FR) specifically prohibits open flames
i ' • •
in any spraying area; Section 1.2 defines a spraying area as: "(b) The
interior of ducts exhausting from spray processes." However, Section
i •: • i
4.2.1 states: "Equipment to process air exhausted from spray operation
for removal of contaminants shall be approved by the authority having
jurisdiction." Section 4.2.1 would allow using incineration for spray
booth exhaust air so long as the local authority approved; thus the OSHA
regulation is not considered a limitation on this technology.
4.2.5.2 Catalytic Incineration
This add-on control method uses a metal catalyst to promote or
speed combustion of volatile organics. Oxidation takes place at the
catalyst surface to convert organics into carbon dioxide and water without
actually flaming, as it permits lower operating temperatures than needed
79
for direct-fired units.
A schematic of a typical catalytic afterburner is shown in Figure 4-4.
The catalysts, usually noble metals such as platinum and palladium, are
supported in the hot gas stream so that a large surface area is presented
to the waste organics. A variety of designs is available for the
catalyst, but most units use a noble metal electrodeposited on a larger
surface area support structure, such as ceramic rods or honeycombed
alumina pellets.72'85 Catalytic incinerators can potentially reduce
volatile organic emissions and are currently used for minor emissions in
the automotive industry.
As with thermal incinerators, the performance of the catalytic unit
depends on the temperature of the gas passing across the catalyst and on
4-28
-------
Clean hot gas
Catalyst
elements
Process
Z. vapors
^sPreheater
Figure 4-4.
Schematic diagram of catalytic afterburner using
torch-type preheat burner with flow of preheated
process vapors through a fan to promote mixing 7
V4
77
4-29
-------
the residence time. Temperatures are normally in the range of 260 to
315°C (500° to 600°F) for the incoming air stream and 400° to
'A'. • i
540°C.(750° to 1000°F) for the exhaust. The exit temperature from
the catalyst depends on the inlet temperature, the concentration of
organics, and the percent combustion.
Burning efficiency varies with the type of organic being oxidized
85
as well as the detention time and temperature. These effects of
temperature and organic type are shown in Figure 4-5. While high
temperatures are desirable for good emission reduction, temperatures in
excess of 593°C (1100°F) can cause serious erosion of the catalyst
-70 QC
through vaporization. '
. As with thermal incinerators, primary and secondary heat recovery
i ' I
can be used to minimize auxiliary heating requirements for the inlet air
stream and to reduce the overall energy needs for the plant (see
i'
Section 4.2.5.1).
Although catalysts are not consumed during chemical reaction, they
tend to deteriorate, causing a gradual loss of effectiveness in oxidizing
the organics. This deterioration is caused by: poisoning with chemicals,
such as phosphorous and arsenic, which react with the catalyst; by coating
the catalyst with particulates or condensates; and by high operating
temperatures,-which tend to vaporize the noble metal. In most cases,
87
catalysts are guaranteed for 1 year by the equipment supplier,
but with proper filtration cleaning and attention to operating temperatures
7? 87 88
the catalyst should have a useful life to 2 to 3 years. ' »
While catalytic incinerators can probably be adapted to baking
ovens with relatively little difficulty, using these add-ons for
4-30
-------
204
(400)
316
(600)
427
(800)
538
(1000)
649
(1200)
Temperature, °C (°F)
Figure 4-5.
Effect of temperature on oxidative
conversion of organic vapors in a
catalytic incinerator.77
4-31
-------
controlling spray booth and flash-off area emissions will require solving
j
the same design problems discussed for thermal incinerators.
4.3 EMISSION REDUCTION PERFORMANCE OF CONTROL TECHNIQUES
4.3.1 Method of Determining Emission Reduction
Emissions can be controlled either through substituting new
coatings for solvent-based coatings or add-on control devices. The
emission reduction attainable by add-on technology is related to the
ability of the technique to either capture or destroy the solvent
emissions. Measurement and quantification of this reduction is
straightforward and similar to the approach used for any end-of-line
control device.
However, the emission reduction potential for new coatings is not
as easily defined. Solvent emissions are related to the quantity of
volatile organic material in the coating before application and cure. The
potential reduction in emissions by coating substitution is determined by
the difference in the VOC content of the two coatings per unit of coating
solids deposited. Deposited solids are the same in both cases while
organic solvent and water are vaporized, thus the VOC emissions are
I
equivalent to the organic solvent content.
Emissions due to the use of a given coating can be expressed
quantitatively in terms of the amount of solvent or other volatile organic
compound emitted per unit of dry coating solids applied. This approach
relates emissions directly to each unit of coating material actually
applied to an automobile or truck independent of size of the vehicle,
production rate, or dilution air flowrate. Emissions due to a specific
coating can be derived from a chemical analysis of the paint and can be
expressed as the ratio of VOC (measured as carbon) per unit volume solids
4-32
-------
(see Appendix C). Alternatively, it can be derived from the total mass of
the organic solvent in the coating, again per unit solids content. This
measure would be expressed as kilograms VOC per liter solids. The two
derived values will not be the same but will differ by a factor of the
solvents' relative carbon content. Emissions of VOC reported in the
literature are based on solvent quantity. Appendix D discusses the
relative uncertainties of a standard based on this measure versus one
based on carbon content.
To determine the quantity of applied solids for the above emission
determination, it is necessary to consider the transfer efficiency of the
application system or the percentage of paint used that actually deposits
on the surface. For spray application, transfer efficiencies of 30 to 50
percent are normal when using air spray; electrostatic spray will improve
depositions to 60 to 90 percent (see Section 4.2.1.2).
Emission reduction potential discussed below for various coating
systems is given in terms of kilogram VOC/liter applied solids. The
following techniques are discussed: electrodeposition of water-based
coatings; water-based spray coating; powder coating; higher solids
coatings; carbon adsorption; and incineration. Powder coating and carbon
adsorption are included for information only since they are not considered
as currently viable control options (see Section 4.2).
4.3.2 Electrodeposition of Water-Based Coating
The electrodeposition process (EDP), as described in Section 4.2.1,
has four potential sources of solvent emissions: the newly coated object
as the coating is baked and evaporated, the surface of the coating in the
EDP tank, the cascading rinse water, and the ultrafilter permeate sent to
4-33
-------
the drain. An approximate distribution of emissions for various sources
i i
is presented here to complete the discussion.
Most EDP coatings are supplied with a solverit-to-solids ratio of
1 i I
0.06 to 0.12 by weight. The coatings on the substrates are about
95 percent solids when they emerge from the bath. The remaining 5 percent
is predominantly water, with only 3 to 5 percent of the volatile fraction
being solvent.89 Therefore, solvent emissions from this source are
relatively minor.
A more significant source of fugitive emissions is evaporation of
solvent from the rinse water. During operation, a portion of the coating
i i
from the EDP tank is pumped through an ultrafilter (Figure 4-1). The
! .
permeate or excess water is used for rinsing, while the coating
concentrate is returned to the EDP tank. Since ultrafiltration passes any
compound having a molecular weight less than 500, a significant portion of
1
water-miscible solvents, such as alcohols and glycol ethers, end up in
the permeate.89'90'91 These solvents then readily evaporate when the
permeate is used for spray rinsing. Depending on the water requirements
for the recycle system, some of the permeate may be wasted to the drain.
I
This affords the liquid a period of time with open surface for solvent
volatilization and subsequent discharge to the atmosphere.
Although emissions from the bath surface have not been quantified,
based on analysis of a coating used at General Motors, the amount of
organic solvent added to the bath will contribute 0.1 kg VOC/liter of
applied solids.
4.3,3 Hater-Based Spray
As described in Sections 4.2.1.2 and 4.2.1.3, water-based spray for
surfacer and topcoat operations is currently being used to minimize VOC
4-34
-------
emissions. Use of these sprays is generally one of the first options
considered to replace solvent-based sprays on the final coatings. In
determining emission reductions for water-based spray coatings, it is
necessary to consider the solvent content and solids content of the
coating. In addition, transfer efficiency must be considered for the
water-based coating and the solvent-based coating that it is replacing.
As a comparison, two water-based sprays of different water to
organic solvent ratio (82/18 and 88/12) are contrasted against
conventional enamel and lacquer (see Table 4-2). If a 25 volume percent
solids water-based coating with an 82/18 water/solvent ratio by volume
applied by air spray were used to replace a 28 volume percent solids
solvent-based enamel, also applied by air spray, emissions would be
reduced 79 percent. When compared to a 16 volume percent enamel, the
potential reduction increases to nearly 90 percent.
Either reduction calculation is developed by first computing the
ratio of solvent to solids content of each coating material and then
dividing by the transfer efficiency for each application method to
determine the total solvent per unit volume of coating applied. Percent
reduction is determined from the VOC for the solvent-based lacquer minus
the water-based coating divided by the VOC for the solvent-based lacquer.
As an illustration a vehicle coated with 28 percent solids topcoat
solvent-based enamel requires 3.41 liters of solids (see page 3-36) and
8.76 liters of solvent. At a typical solvent density of 0.839 kg/A, this
is equivalent to 2.16 kilogram VOC/liter solids sprayed. With a
40 percent transfer efficiency, the solids deposited would be 1.36 liters
(0.4 x 3.4l£). Assuming that the same amount of solids would be deposited
by a 25 percent solids water-based coating, its solvent content would be
4-35
-------
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calculated as follows. The volumetric solvent-to-solids ratio for a 82/18
water to organic coating would be 0.54 (0.18 x 0.75 v 0.25). When air
sprayed at 40 percent efficiency, the 3.41 liters of solids would be
carried in 1.84 liters of organic solvent (3.41 x 0.54) and is equivalent
to 0.453 kilograms VOC/liter solids applied (0.839 x 0.54). The emission
reduction would be 79 percent, based on two values for mass of VOC/liter
solids applied ((2.16 - 0.453) x 100 - 2.16).
The standards development has utilized this approach with specific
coating material composition to determine VOC (measured as carbon)
emissions. Emission limits were not determined from stack sampling but
from coating formulations and the assumption that all VOC in the coating
material is released to the atmosphere. Appendix C contains the equation
used to determine the mass of volatile carbon per unit of coating solids.
Data from a composite of 25 General Motors water-based topcoats yielded a
relative solvent content of 0.34 kilogram VOC (measured as carbon) per
liter solids in the coating material. This carbon/solids ratio must be
divided by the transfer efficiency (40 percent for air spray) to determine
the emissions per liter coating solids applied.
General Motors estimates that when using an acrylic lacquer
topcoat, its two plants at Van Nuys and South Gate emitted a total of 5.31
million kilograms (11.70 million pounds) of solvent per model year from
topcoat alone. When these plants converted to water-based topcoats, the
emissions from the topcoating operations were reduced to 1.30 million
27
kilograms (2.86 million pounds). This represents an emission
reduction of approximately 75 percent and agrees well with the theoretical
results presented in Table 4-2.
4-37
-------
One coating supplier estimated that an emission reduction in the
range of 72 to 84 percent will result from substituting water-based for
solvent-based enamels in spray applications. His estimates, which
were based on solvent-based coatings of 30 percent volume solids and
water-based coatings of 18 to 33 percent organic solvent, also agree with
the results above.
i
4.3.4 Powder Coating — Electrostatic Spray
Powder coatings are nearly 100 percent solids. Thus, with only a
small amount of volatile organic material, usually less than half of one
percent,92 powder coatings can be used to accomplish a large emission
reduction. Although powders contain little volatile material, 2 to
3 percent of the coating solids can be emitted during baking of the
I
polyvinyl chloride and epoxy coat. This material comes from the partial
evaporation of plasticizers and coreactants.93 Such values translate
into a VOC emission rate per unit of applied coating of 0.020 to
' I
0.031 kg/A (at an assumed 98 percent transfer efficiency).
i
When powder coatings are electrostatically sprayed, the powder that
j
does not deposit on the part is contained mostly in the spray booth. With
properly designed equipment, if the over-sprayed powder is recovered,
overall transfer efficiencies can be as great as 98 percent. This level
is difficult to reach for automobile or light-duty truck coatings because
of the many colors and the difficulty of segregating overspray from
different colors.
4.3.5 Higher Solids Coatings
To determine the emission reduction potential associated with
higher solids coatings, the VOC emission rate per unit of applied coating
was determined for various points with solids content in the range of 30
4-38
-------
to 80 volume percent. This emission rate was compared against those of
both lacquer and solution enamel topcoats. These data are presented for
two groups of substituted coatings in Figures 4-6 and 4-7. In preparing
these estimates, two different transfer efficiencies were considered.
Emissions from application by air spray (50 percent transfer efficiency)
and electrostatic spray (80 percent transfer efficiency) were each
compared with that from applying conventional solvent-based paints with
air spray. Transfer efficiencies selected are representative of typical
highly efficient systems.
As can be.seen in Figure 4-6, if a 16 volume percent solvent-based
lacquer were replaced by a 35 volume percent solids NAD or solution enamel
applied by electrostatic spray, potential emission reduction would be
nearly 80 percent.
At the present, most high-solids coatings are being developed to
achieve 70 percent solids or greater. If the above solvent-based lacquer
were replaced by only a 50 to 60 percent high-solids coating applied by
air spray, then a potential emission reduction of over 80 percent could be
realized. With the relatively high level of solvent dilution that would
be associated with a 50 to 60 volume percent high-solids coating, such
coatings could conceivably be sprayed without heated equipment and with
relatively little modification of existing equipment.
Figure 4-7 shows that if a 28 volume percent NAD coating was
replaced by a higher solids coating of 60 volume percent solids, then an
emission reduction of 74 or 84 percent would be possible, depending on the
method of application.
To show the benefit that could be obtained by developing this
technology further, an example of a very high-sol ids coating is
presented. If an 80 volume percent high-solids coating were used to
4-39
-------
-a =5 •
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100
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80% transfer e1
ficiency
50% tn
nsfer eff
ciency
30 40 50 60 70 80
Volume percent solids content of coatings
Figure 4-7. Emission reduction potential (percent) versus
content of higher solids coatings replacing a
28 volume percent enamel at 50 percent transfer
efficiency.
so 1 i ds
4-41
-------
replace a 16 volume percent solvent-based lacquer, then an emission
i
reduction as great as 95 percent would be possible.
4.3.6 Carbon Adsorption
Carbon adsorption is being used successfully in the paper and
fabric industry for controlling solvent emissions." » » » Although
pilot studies have been conducted, no full-scale carbon adsorption units
98
are in place on auto or light-duty truck coating lines. It is
generally acknowledged that an emission reduction of 85 percent is
possible for solvent vapor emissions from spray booths and ovens.
However, in the automotive industry, such a system is not off-the-shelf
technology and would be very costly and require considerable pilot work
prior to use.99'100'101
4.3.7 Incineration
Incineration is currently being used to control solvent emissions
in such finishing industries as paper, fabric, wire, can and coil coating,
as well as the automotive finishing industry. ' Field
i
investigations of incinerators in these industries have documented that
both thermal and catalytic incinerations are capable of eliminating 90
percent of the solvents from concentrated exhaust air
streams.*0'84'104'105'108-110
i
Conditions necessary for properly incinerating exhaust gases are
discussed in Sections 4.2.5.1 and 4.2.5.2. As a summary of emission
controls, state-of-the-art data from existing incinerators indicate that
organic compounds are oxidized from 91 to 100 percent for inlet
concentrations of 200 to 9000 ppm or 25 or more percent LEL. " The
" I
majority of these installations are on bake oven exhaust and receive
concentrated airstreams. One investigator reported typical concentrations
4-42
-------
of organic solvents in the range of 30 to 300 ppm by volume in air from
paint booths and 100 to 500 ppm by volume in air emitted from automobile
, .. .,. ... 100
assembly line baking ovens.
No catalytic incinerators are routinely used in the automotive
pc
industry at this time. Several bake ovens in Ford Motor Companyplants
QO QA 119
in California are equipped with thermal incinerators. ' ' Typical
units operating at 760° to 815°C (1400° to 1500°F) have operating
112
efficiencies of at least 90 percent.
Since existing systems are capable of oxidizing VOC above 90
percent, providing the temperature is adequate, the numerical emissions
control is selected as 90 percent removal of VOC in the incinerated air
stream of both bake oven and spray booth exhausts.
4-43
-------
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3. Bardin, P.C. Chevrolet Primes Truck Parts in Two 60,000-Gallon EDP
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I
9. Electrocoat System Speeds Truck and Tractor Seat Painting. Products
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i
15. Brewer, G. E. F. Electrocoat ~ Overview of the Past and State of the
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4-44
-------
17. Levinson, S.B. Electrocoat. Journal of Paint Technology. 44
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19. Brumbaugh, G. E. Preparation of Metal Surfaces for Water-Based
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24. Henning, C.C., and J.J. Krupp. Compelling Reasons for the Use of Water
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25. Jones, F.N. What Properties Can You Expect from Aqueous Solution
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Reduction. Industrial Finishing. 5Q(7):26. July 1974.
29. Electric Wheel Converts to Water-Based Alkyd Enamel. Industrial
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31. Pegg, F.E. Applying Plastic Coatings with the Fluidized Bed Process.
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33. Poll, G.H., Jr. High-Production Acrylic Powder Coating. Products
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4-45
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34. Iverson Powder Coats Bicycles in 20 Colors. Industrial Finishing.
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: i
35. Cole, E. N. Coatings and Automobile Industries Have Common Interest.
American Paint and Coatings Journal. 58(51):60. June 3, 1974.
36. Gabris, T. Trip Report — Ford Motor Company, Metuchen Plant. DeBell &
Richardson. Enfield, Connecticut. Trip Report 38. January 23, 1976.
37. Schrantz, J. Powder Coating Brings Advantages to Baldwin. Industrial
Finishing. 52(9):58-61. September 1976.
38. Automotive Powder Under the Hood. Products Finishing. 41.(2):56-57.
November 1976.
39. Cehanowicz, L. The Switch Is on for Powder Coating. Plastics
Engineering. 31(9):29. September 1975.
40. Robinson, G. T. Powder Coating Trailer Hitches. Products Finishing.
38(9):76. June 1974.
41. How Nylon Powder Coatings Help. Products Finishing. 38(7):81. April
1974.
42. Mazia, J. Technical Developments in 1976. Metal Finishing. .75_(2):75.
February 1977.
43. Powdered Automobile Paints Make a Strong.Inroad. Chemical Engineering.
83(14):33. July 5, 1976.
44. Miller, E.P. and D.D. Taft. Fundamentals of Powder Coating. Dearborn,
Society of Manufacturing Engineers. 1974. p. 125-129.
j .
45. Levinson, S.B. Radiate. Journal of Paint Technology. 44(571):32-36.
August 1972.
46. North, A.G. Progress in Radiation Cured Costings. Pigment and Resin
Technology. 3.(2):3-ll. February 1974.
I ' • !
47. Nickerson, R.S. The State of the Art in UV Coating. Industrial
Finishing. 50(2):10-14. February 1974.
48. Telecon. Mr. Noone, DuPont Company with Hoiley, W., DeBell and
Richardson. February 23, 1977.
49. Telecon. Little, A. Ditzler, PPG Industries, Inc., Detroit, Michigan
with T. Gabris, DeBell and Richardson. February 23, 1977.
50. Dowbenko, R. and D.P. Hart. Nonaqueous Dispersions as Vehicles for
Polymer Coatings. Industrial Engineering Chemistry Product Research and
Development. 12(1):14-28. 1973.
4-46
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51. Air Pollution Control District, County of Los Angeles. Rule 66, Organic
Solvents, as amended November 2, 1972 and August 31, 1974. Los Angeles,
California. July 28, 1966.
52. Young, R.G. and W.R. Howell. Epoxies Offer Fulfillment of High
Performance Needs. Modern Paint and Coatings. 65_(3):43-47. March 1975.
53. Lunde, D.I. Acrylic Resins Defy Conventional Relationships in New
Technology Coatings. Modern Paint and Coatings. 66(3):51-53.
March 1976.
54. Mercuric, A. and S.N. Lewis. High Solids Coatings for Low Emission
Industrial Finishing. Journal of Paint Technology. 47(607):37-44.
August 1975.
55. Baker, R.D. and J.J. Bracco. Two Component Urethanes: Higher Solids
Systems at Lower Cure Temperatures. Modern Paint and Coatings.
66(3):43-48. March 1976.
56. Larson, J.M. and D.E. Tweet. Alkyds and Polyesters Readied for Market
Entry. Modern Paint and Coatings. 65_(3): 31-34. March 1975.
57. Mazia, J. Technical Developments in 1976. Metal Finishing.
75(2):74-75. February 1977.
58. Mantel!, C.L. Adsorption. New York, McGraw-Hill. 1951. p. 237-248.
59. Kanter, C.B., et al. Control of Organic Emissions from Surface Coating
Operations. In: Proceedings of the 52nd APCA Annual Meeting. June
1959.
60. Elliott, J.H., N. Kayne, and M.F. Leduc. Experimental Program for the
Control of Organic Emissions from Protective Coating Operations. Report
No. 7. Los Angeles APCD. 1961.
61. Lund, H.F. Industrial Pollution Control Handbook. New York,
McGraw-Hill. 1971. p. 13-13, 19-10.
62. Letter from Sussman, Victor H., Ford Motor Company to Wetherold, R.G.,
Radian Corporation. March 15, 1976.
63.* Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold. Evaluation of a
Carbon Adsorption/Incineration Control System for Auto Assembly Plants.
Radian Corporation. EPA Contract 68-02-1319, Task 46. May 1976. p.
54-58.
64. Atherton, R.B. Trip Report — Automobile Manufacturers in Detroit,
Michigan; Dearborn and Wayne, Michigan. EPA. April 16, 1973.
65. Letter from Lee, D., Vic Manufacturing Company, to Wetherold, R.G.,
Radian Corporation. March 17, 1976.
4-47
-------
66. Roberts, R.E. and J.B. Roberts. An Engineering Approach to Emission
Reduction in Automotive Spray Painting. In: Proceedings of the 57th
APCA Meeting. 26(4). June 1974. p. 353.
67. Reference 63. p. 32.
68. Handbook of Chemistry and Physics. Weast, R,,C. (ed.) Cleveland, The
Chemical Rubber Company. 1964. p. E-26.
69. Reference 63. p. 27.
70. Grandjacques, B. Air Pollution Control and Energy Savings with Carbon
Adsorption Systems. Calgon Corporation. Report APC 12-A. July 19,
1975.
71. Lee, D.R. Activated Charcoal in Air Pollution Control. Heating, Piping
and Air Conditioning. April 1970. p. 76-79.
72. Reference 61. p. 5-27 to 5-32.
73. Conversation between Fred Porter, Ford Motor Company and EPA-CTO.
74. Gabris, T. Trip Report — Roll Coater, Inc., Kingsbury, Indiana.
DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report 76.
February 26, 1976.
75 Hydrocarbon Pollutant Systems Study. MSA Research Corporation. Evans
City, Pennsylvania. MSAR 72-233. October 20, 1972. p. VI-4.
76 Benforado, D.M. Air Pollution Control by Direct Flame Incineration in
The Paint Industry. Journal of Paint Technology. 39(508): 265. May
1967. :
77. Stern, A. C. Air Pollution. Vol. Ill, Sources of Air Pollution and
Their Control. New York, Academic Press. 1968.
78. Reference 61. p. 7-8 to 7-11.
79. Heat Recovery Combined with Oven Exhaust Incineration. Industrial
Finishing 52(6): 26-27.
80. Re-Therm Oxidation Equipment. Product Bulletin REE-1051-975-15M. Morris
Plains, New Jersey. Reeco Regenerative Environmental Equipment Company,
Inc.
81. Young, R.A. Heat Recovery: Pays for Air Incineration and Process
Drying. Pollution Engineering. 7.(9):60-6L, September 1975.
82. Can Ceramic Heat Wheels Do Industry a Turn?
August 1975. p. 42-43.
Process Engineering.
4-48
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83. Gabris, T. Trip Report — Ford Motor Company, Truck Plant, Milpitas,
California. DeBell & Richardson, Inc. Enfield, Connecticut. Trip
Report 120. April 8, 1976.
84. Gabris, T. Trip" Report -- Ford Motor Company, Auto Plant, Milpitas,
California. DeBell & Richardson, Inc. Enfield, Connecticut. Trip
Report 112. April 7, 1976.
85. Danielson, J.A, Air Pollution Engineering Manual. Cincinnati, Ohio.
Public Health Service Publication 999-AP-40. 1967. p. 178-184.
86. Bullett, Orville H. E.I. duPont de Nemours. In: Comments to National
Air Pollution Control Techniques Advisory Committee, September 27, 1977.
87. Kent, R.W. Thermal Versus Catalytic Incineration. Products Finishing.
40(2):83-85. November 1975.
88. Fuel Requirements, Capital Cost and Operating Expense for Catalytic and
Thermal Afterburners. Combustion Engineering. Wellsville, New York.
EPA Contract 68-02-1473, Task 13.
89. Koch, R.R. Electrocoating Materials Today and Tomorrow. SME Technical
Paper. FC75-563. 1975. p. 4.
90. Blatt, W.F. Hollow Fibers: A Transition Point in Membrane Technology.
American Laboratory. October 1972. p. 78.
91. Mahon, H.I. and B.J. Lipps. Hollow Fiber Membranes. In: Encyclopedia
of Polymer Science and Technology. New York, John Wiley and Sons.
1971. p. 269.
92. Automatic Powder Coating System Design. Technical Bulletin 2.
Stamford, Connecticut. Interrad Corporation.
93. Prane, J.W. Nonpolluting Coatings and Energy Conservation. ACS
Coatings and Plastics Preprints. 34(1):14. April 1974.
94. Oge, M.T. Trip Report -- Fasson Company, Painesville, Ohio. DeBell &
Richardson, Inc. Enfield, Connecticut. Trip Report 141. July 21, 1976.
95. Oge, M.T. Trip Report — Brown-Bridge Mills, Troy, Ohio. DeBell &
Richardson, Inc. Enfield, Connecticut. Trip Report 140. July 20, 1976.
96. Solvent Recovery Installations. Supplier Bulletin. Cincinnati, Ohio.
Vulcan-Cincinnati, Inc.
97. McCarthy, R.A. Trip Report ~ Raybestos-Manhattan, Incorporated,
Mannheim, Pennsylvania. DeBell & Richardson, Inc. Enfield,
Connecticut. Trip Report 77. February 26, 1976.
98. Letter from Reinke, J.M. Ford Motor Company to James McCarthy, EPA-CTO.
November 1, 1976.
4-49
-------
99. Letter from Sussman, Victor H., Ford Motor Company to James McCarthy,
EPA-CTO. August 6, 1976.
100. Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold. Evaluation of a
Carbon Adsorption/Incineration Control System for Auto Assembly Plants.
Radian Corporation. EPA Contract 68-02-1319, Task 46. May 1976.
101. Letter from Johnson, W.R., General Motors Corporation, to Radian
Corporation. March 12, 1976. Comments on Reference 63.
102 Oge, M.T. Trip Report -- Hazen Paper Company, Holyoke, Massachusetts.
DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report 134. May
19, 1976.
103. McCarthy, R.A. Trip Report — DuPont Corporation, Fabric and Finishes
Department, Fairfield, Connecticut. DeBell & Richardson, Inc. Enfield,
Connecticut. Trip Report 130. April 30, 1976.
104. Kloppenburg, W.B. Trip Report - Phelps Dodge Magnet Wire; Fort Wayne,
Indiana. DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report
113. April 7, 1976.
105. Kloppenburg, W.B. Trip Report -- General Electric Company; Schen'ectady
New York. DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report
106. April 6, 1976.
106. Gabris, T. Trip Report -- National Can Corporation. Danbury,
Connecticut. DeBell & Richardson, Inc. Enfield, Connecticut. Trip
Report 128. April 27, 1976.
107. Gabris, T. Trip Report - Continental Can Company, Inc.; Portage,
Indiana. DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report
80. March 3, 1976.
108 Fisher, J.R. Trip Report -- Supracote, Inc., Cucamonga, California.
DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report 31.
January 16, 1976.
109 Gabris, T. Trip Report -- American Can Company, Plant 025, Edison, New
Jersey! Deuell & Richardson, Inc. Enfield, Connecticut. Trip Report
6. December 29, 1975.
110. Kloppenburg, W.B. Trip Report - Chicago Magnet Wire, Elks Grove
Village, Illinois. DeBell & Richardson, Inc. Enfield, Connecticut.
Trip Report 124. April 9, 1976.
111. Gabris, T. Trip Report -- Litho-Strip Company, South Kilburn,
Illinois. DeBell & Richardson, Inc. Enfield, Connecticut. Trip Report
35. January 22, 1976. '.
112 Letter from Sussman, Victor H., Ford Motor Company, to James McCarthy,
EPA-CTO. March 16, 1976.
4-50
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5. MODIFICATIONS AND RECONSTRUCTIONS
5.1 BACKGROUND
This chapter identifies and discusses possible or typical changes to
automobile and light-duty truck surface coating operations which could be
termed modifications or reconstructions. Modified or reconstructed existing
facilities must comply with standards of performance for new sources. A
modification is defined as ". . . any physical change in, or change in the
method of, operation of an existing facility which increases the amount of
any air pollutant (to which a standard applies) emitted into the atmosphere
by that facility or which results in the emission of any air pollutant (to
which a standard applies) into the atmosphere not previously emitted." An
"existing facility" is defined as one which would be required to conform to
a standard of performance, if it were new, but which was, in fact, con-
structed or modified before the date of proposal of the standard of per-
formance.
The regulation on modifications requires the owner or operator of any
source—an automobile and light-duty truck surface coating operation in
this case—classified as an "existing facility" to notify EPA of changes
which could cause an increase in emissions of an air pollutant for which a
2
standard of performance applies. These changes are not "modifications"
(i.e., the existing facility would not have to meet the standards of perfor-
mance) if the owner or operator demonstrates that no increase in emissions
for which a regulation applied resulted from the alteration.
-------
The term "reconstruction" is defined as the ". . . replacement of a
substantial majority of the existing facility's components irrespective of
o
any change of emission rate." Reconstruction occurs when components of an
existing facility are replaced to such an extent that:
• The fixed capital cost of the new components exceeds 50 percent
of the fixed capital cost that would be required to construct a
comparable entirely new facility, and
• It is technologically and economically feasible to meet the appli-
cable standards.
The purpose of this provision is to discourage the perpetuation of a fa-
cility which, in the absence of a regulation, would normally have been
replaced.4 The owner or operator must notify EPA to provide information
• • ' 1 • : 5
concerning the construction or reconstruction of an existing facility.
.i •. , ' i , ' •
5.2 POTENTIAL MODIFICATIONS
The following potential modifications would apply to both passenger
car and light-duty truck body painting operations, since both operations
i
are similar. The only real difference is that automobile body lines generally
run faster than light-duty truck lines. This difference, however, does not
affect the types of changes that might be made to a coating line, the
reasons for the change, or the nature of its impact on emissions. Therefore,
for purposes of this chapter, the two operations can be considered similar.
Certain circumstances exist under which an increase in emissions does
not result in a modification. If a capital expenditure less than the most
i i i
recent annual asset guideline repair allowance published by the Internal
Revenue Service (Publication 534) is made to increase capacity at an exist-
i • „ ! ••
ing facility and also results in an increase in emissions of a regulated
5-2
-------
pollutant to the atmosphere, a modification is not considered to have
occurred.
The following changes in materials or formulations could increase
solvent emissions but would be considered as a change in raw material and,
therefore, not a modification. If associated capital expenditures exceed
the minimum for reconstructions, the facility could be considered to have
been reconstructed and thus subject to the proposed regulation.
• Lower Solids Coatings. If a change is made from a higher to a
lower solids coating (e.g., fronran enamel to a lacquer), more
material, and hence more solvent, will be used to maintain the
same dry coating thickness. While a change in the direction of
lower solids is unlikely, it could occur in any one plant as a
result of changing paint systems, colors, models, or use of
metallics. It is unlikely, however, that any major capital
expenditures to equipment would be required.
• Use of Higher Density Solvent. Regulations normally restrict the
number of pounds of solvent that can be emitted. An increase in
the density of the solvents used, even if the volumetric amounts
used were the same, would result in more mass of solvent being
emitted. Again, this could be construed as a raw material sub-
stitution and hence not a modification, as no major capital
expenditures would be involved. Such substitutions might come
about as a result of solvent shortages, attempts to cut paint
costs, or efforts to incorporate less photoreactive solvents.
• Increased Thinning of Coatings. A change to a higher viscosity
coating could result in an increased use of solvents for thinning
the coating to proper application consistency.
5-3
-------
An increase In working hours (i.e., from one- to two-shift operation
or from 8 hours to 10 hours per shift) does not increase solvent emissions
per hour and, hence, is not considered a modification.
Other possible changes that could result in increased solvent emissions
include:
, Change to Larger Parts. If body size were increased, more coating
materials could be used per vehicle, hence, emissions could
increase even if production rates were maintained constant.
While the overall trend is toward smaller sized automobiles, any
one facility could switch from a smaller sized automobile to a
larger model. It is felt, however, that such a change would not
qualify as a modification per se, since automobile or light-duty
truck assembly lines normally can accept more than one size of
vehicle.
• Increased Film Thickness. A change to a thicker coating, if
other factors remain constant, could result in increased solvent
emissions. An effort is under way in the automotive industry to
increase corrosion resistance, which could call for increased
coverage or thicker coatings in corrosion-prone areas. If these
changes are made only for the purpose of improved product relia-
bility, and no increases in production rate occurs, they will
will not be considered modifications.
» Reduced Deposition Efficiency, Increased overspray because of a
process modification, such as a switch from electrostatic spray
to conventional spray, would result in increased emissions. For
economic reasons, however, a switch in such a direction is un-
likely except possibly as a temporary measure.
5-4
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• Additional Coating Stations. If for any reason additional coat-
ing stations were added, emissions could increase. Such a change
would likely involve costly alterations or a new facility and, as
such, would be subject to regulation.
• Annual Model Changeovers. Model changes are normally handled
with existing equipment and do not require process changes.6
Slight increases in emissions could occur, however, due to a
change in configuration of the vehicle. For example, transfer
efficiencies are usually lower for coating small vehicles than
for larger ones. Therefore, a switch to production of smaller
vehicles could cause an increase in emissions. However, such
changes, made only for model changeovers and not intended to
increase production rate, will not be considered modifications.
• Changes in Coating Specifications. Changes in coating materials
to produce new colors or surfaces, increase corrosion resistance,
or otherwise improve the quality of the surface coating, could be
associated with an increase in solvent emissions.
Of the potential modifications listed above, only those involving
production increases which require excessive capital expenditures will
normally be considered as modifications. The installation of additional
coating stations is the only change listed which would usually subject the
source to regulation.
5.3 RECONSTRUCTIONS
Automotive spray booths and bake ovens usually last 20 to 25 years and
are normally not replaced before that time unless process changes require
their replacement. When spray booth and bake oven replacements are made,
5-5
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however, the capital expenditures involved are normally sufficient to be
considered reconstructions.
The trend toward electrodeposition (EDP) of water-based primer coatings
may have an impact on the issue of reconstruction,, Both Ford and General
Motors use this system quite extensively, and Chrysler is now considering
it.6 International Harvester uses the system for priming light-duty truck
bodies. Increased corrosion resistance is an advantage of the EDP coating
system and a principal reason for its use; considerably lower solvent
I
emissions (even with a guide coat) are an important secondary effect.
Hence, if a primer paint line were to be replaced, an EDP system would
likely be installed even without emission regulations. The fact that
50 percent of U.S. passenger car bodies are already prime-coated by this
method would support such a conclusion. Installation of an EDP system,
however, could be a potential reconstruction due to the costs involved in
adding the tank, bake oven, and auxiliary equipment. Since EDP of water-
i . ! :
based coatings achieves the lowest emissions of any control system identi-
fied in Chapter 4 for prime coat operations, any existing facility that
changes to an EDP system should automatically meet a standard of performance.
5-6
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2.
3.
4.
5.
6.
REFERENCES FOR CHAPTER 5
FEDERAL REGISTER, Volume 40, Number 242, "Standards of Performance for
New Stationary Sources: Modification, Notification, and Reconstruction,"
Subpart A, 40 CFR 60.14, Tuesday, December 16, 1975.
Ref. 1, Subpart A, 40 CFR 60.7.
Ref. 1, Subpart A, 40 CFR 60.15.
Ref. 1, Reconstruction.
Ref. 1, Subpart A, 40 CFR 60.7.
Telecon. Gabris, T. DeBell & Richardson, Inc. with Flaherty, R.
Chrysler Corporation. March 2, 1977.
Telecon. Gabris, T. DeBell & Richardson, Inc. with King, T.B., Inter-
national Harvester Corporation. March 2, 1977.
5-7
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6. EMISSION CONTROL SYSTEMS
6.1 GENERAL
Chapter 4 described and evaluated the performance of the individual
emission control technologies which can be used to reduce VOC emissions
from coating operations in the automotive industry. This chapter identi-
fies alternative emission control systems for typical automobile and light-
duty truck surface coating operations. A system can be either a coating
material and application technique, an add-on control device, or a combina-
tion of the two. The choice of the system depends on the particular coating
operation and the desired level of control.
This chapter presents a number of alternative emission control systems
to be used in analyzing the range of environmental (Chapter 7) and economic
(Chapter 8) impacts associated with various alternative regulatory options.
Primer, guide coat and topcoat operations are considered separate emission
sources. Although there are many alternatives for controlling or reducing
primer, guide coat, and topcoat emissions for both automobile and light-
duty truck surface coating operations, only those shown in Table 6-1 were
investigated. These were chosen because they are representative of the
options available.
The model plant for automobile bodies produces 55 bodies per hour,
3,840 hours per year (basis: 240 days at two 8-hour shifts). The model
plant for light-duty truck bodies operates at 38 bodies per hour, 3,840
hours per year. These model plants produce 211,200 automobiles or 145,920
light-duty trucks annually, and are typical of automotive assembly plants.
-------
6.2 BASE CASE
The application of a water-based primer by cathodic electrodeposition
(EDP) is currently in widespread use for the automobile and light-duty
truck surface coating operations, primarily because of the increased corro-
sion protection it affords. Thus, cathodic EDP is considered the base case
for the prime coat. At the present time, automobile and light-duty truck
surface coating lines usually spray an additional coat on the»vehicles
between the primer and the topcoat. This additional coat, the primer
surfacer, or guide coat, provides a smoother surface for the topcoat appli-
cation. Most plants currently use solvent-based guide coat and topcoat,
and, in the absence of air pollution regulations, new plants would likely
continue this practice. Therefore, the use of organic solvent-based coatings
is properly considered the base case for the guide coat and topcoat operations.
6.3 REGULATORY OPTIONS
There are three major sources of emissions from the coating of automobiles
and light-duty trucks:
• Primer
• Guide coat
. .-,?/ i
• Topcoat
For primer, EDP coating is the best control option and also the best
coating. Therefore, as explained in Section 6.2, this can be considered
the base case.
For guide coat and topcoat, two control methods are available:
• Use of water-based coatings
• Use of solvent-based coatings with incineration
6-2
-------
Incinerators have been used by some automobile and light-duty truck plants
for ovens, and, although not currently in use, incineration for spray
1-3
booths presents no technical problem.
The availability of these control methods leads to the three regula-
tory options described below:
• Regulatory Option I(A) involves EDP of water-based primer and the
air spraying of water-based topcoat. When water-based topcoats
are used, the surfacer used over the EDP primer is normally a
water-based coating and is so assumed in this option. This
option does not include any add-on controls.
• Regulatory Option I(B) adds incineration of the guide coat and
topcoat emissions from the bake ovens to the base case. The
incinerator achieves a 90 percent reduction in the VOC concentra-
tion of the stream passing through it.
• Regulatory Option II adds 90 percent effective incineration of
the emissions from both the spray booths and ovens on the guide
coat and topcoat operations to the base case.
Emissions from these options are summarized and compared to the base
case in Table 6-1. Regulatory Options I(A) and I(B) achieve between 75 and
80 percent reduction from the base case, while Regulatory Option II achieves
almost 90 percent reduction.
6-3
-------
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6-4
-------
REFERENCES FOR CHAPTER 6
1. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report 9.
December 30, 1975.
2. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report 13.
January 2, 1976.
3. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report 73.
February 24, 1976.
4. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report
102. April 5, 1976.
5. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report
110. April 6, 1976.
6. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report
112. April 7, 1976.
7. Bardin, P.C. Chevrolet Primes Truck Parts in Two 60,000-Gallon EDP
Tanks. Industrial Finishing. 49(2): p. 58-65.
8. Gabris, T. DeBell & Richardson, Enfield, Connecticut. Trip Report
120. April 8, 1976.
6-5
-------
-------
7. ENVIRONMENTAL IMPACT*
7.1 AIR POLLUTION IMPACT
7.1.1 General
Automobile and light-duty truck assembly lines are major point sources
of solvent emissions, most of which result from surface coating operations.
These coatings are normally based on organic solvent which is released upon
drying.
In 1973 (a very high production year), total U.S. consumption of
paints and coatings was about 1,900,000 tonnes or 4,180 million pounds and
consisted of the following solvent distribution:
Category
Oxygenated solvents
Aliphatic hydrocarbons
Aromatic hydrocarbons
Other
Total
Tonnes
(x 103)
801
680
400
17
1898
Percent
42
36
21
1
100
The incremental impacts discussed in this chapter were determined by
comparing the various regulatory options to a base case consisting of
a cathodic EDP system, a solvent-based guide coat, and a solvent-based
topcoat. This base case system was considered to be typical of systems
which industry might use in the absence of a new source performance
standard. Shortly before proposal of the standards, a new EDP coating
material was developed and placed in production use in at least two
assembly plants. The new coating material is much lower in solvent
content than the one used in this document for the regulatory options.
Since the proposed standards are based on the use of the new EDP coating
material, impacts of the proposed standards may vary slightly from those
presented in this document.
-------
In 1973, excluding maintenance coatings and exports, 1247 million
liters (330 million gallons) of industrial finishes were made and applied
on a variety of products.1 Of this 1247 million liters of coatings, approxi-
mately 245 million liters (65 million gallons) were used in the automotive
industry in the following distribution:
Automobiles
Light-Duty Trucks
Other Transportation
Total
Liters
(x 106)
170
40
35
245
Gallons
(x 106)
45
10.5
9.5
65.0
Percent
70
16
14
100
The solvent fraction included in the total 1247 million liters of
industrial product finishes is estimated at about 756 million liters
(200 million gallons) or 61 percent. The solvent fraction of coatings used
in the automotive industry varies from less than 2 percent to more than
90 percent depending on the type of coating used.
i
Solvent emissions from the automotive industry occur at the application
and cure steps of the coating operation. For example, a typical automobile
assembly line producing 211,200 vehicles per year (55 cars/hr, 16 hr/day,
240 days/year) creates uncontrolled volatile organic emissions from solvent-
based primer of approximately 1000 tonnes (2,200,000 pounds) per year.
Emissions from solvent-based topcoat operations of this line add about
1500 tonnes (3,300,000 pounds) per year. At this rate, slightly more than
7-2
-------
10.4 tonnes (23,000 pounds) of solvent emissions are generated each work
day from the total surface coating operation. Similarly, for a typical
light-duty truck surface coating operation, approximately 7.2 tonnes
(16,000 pounds) of solvent are emitted daily.
The objective of performance standards for new sources is to limit the
emission of pollutants by imposing standards that reflect the degree of
emission reduction achievable through the application of the best system(s)
of emission reduction, that is (are) determined by the Administrator to be
adequately demonstrated in achieving such reduction. Several alternative
solvent emission control systems (hereinafter referred to as regulatory
options) have been identified for automobile and light-duty truck surface
coating operations.
To assess the environmental impact and the degree of emission control
achieved by each alternative that could serve as the basis for standards,
the emissions for these alternatives are compared. Also, other facets of
environmental impact—such as potential water pollution and solid waste
generation—are assessed. Similarly, State regulations and controlled
emissions should be considered. These are discussed in the following
paragraphs.
7.1.2 State Regulations and Controlled Emissions
In August 1971, Los Angeles County, California, adopted Rule 66 which
controlled organic compound emissions. In 1976, Rule 66 was supplanted by
•*
South Coast Air Pollution Control District (SCAPCD)* Rule 442 with similar
provisions. Rule 442 states that emissions of photochemically reactive
* Replaced by the South Coast Air Quality Management District (SCAQMD) on
February 1, 1977.
7-3
-------
solvents** are not to exceed.18 kilograms (39.6 pounds) per day and
emissions of nonphotochemically reactive solvents are limited to
1350 kilograms (2970 pounds) per day. Emissions from organic materials
that come into contact with flame or are baked are limited to 6.5 kilograms
(14.3 pounds) per day. Emissions above these limits are subject to 85 percent
emission control. The regulation also provides exemptions for water-based
1' /i i
coatings where the volatile content consists of 80 percent water.
As of 1977, 13 States had statewide regulations dealing with hydrocarbon
emissions. Approximately half of these States' regulations were the same
as or similar to Rule 442 (Rule 66) of the SCAQMD. These regulations
carefully limited the amount of photochemically reactive solvent volatiles
that could be emitted within a given time period from coating applications,
baking ovens, and curing operations in an automotive plant.
**
Photochemically reactive solvent means any solvent with an aggregate
or more than 20 percent of its total volume composed of the chemical^
compounds classified below or which exceeds any of the following individual
percentage composition limitations, referred to the total volume of
solvent: •
a. A combination of hydrocarbons, alcohols, aldehydes, ethers,
esters, or ketones having an olefinic of cycloolefinic type of
unsaturation except perchloroethylene: 5 percent
b. A combination of aromatic compounds with eight or more carbon
atoms to the molecule excpet ethyl benzene, methylbenzoate, and
phenyl acetate: 8 percent
c. A combination of ethyl benzene, keto'nes having branched hydrocarbon
structures, trichloroethylene or toluene: 20 percent
Whenever any organic solvent or any constitutent of an organic
solvent may be classified from its chemical structure into more than one
of the above groups of organic compounds, it shall be considered as a
member of the most reactive chemical groups, that is, that group having
the least allowable percent of the total volume of solvents.
7-4
-------
There are many difficulties in understanding and interpreting
Rule 442-type regulations. Among those States having this type of regula-
tion, there are many variations and different interpretations of require-
ments. There has been considerable debate over what constitutes a
photochemically reactive solvent and a nonphotochemically reactive solvent
at both the State and Federal levels. The situation is further complicated
by the fact that the States are currently rewriting their regulations.
7.1.3 Comparative Emissions from Model Plants Employing Various Operating
Options
The various options that have been considered in this document and
discussed in Chapter 4 are summarized in Table 7-1. Comparative emissions
of model plants utilizing these options were determined for enamel coating
assembly lines.
7.1.3.1 Automobiles
A model assembly line representative of typical new lines in-industry
produces 55 automobiles per hour and operates two 8-hour shifts per day.
This line produces 880 autmobiles per day or 211,200 automobiles per year
(240 work days per year). Table 7-2 lists uncontrolled and controlled
emissions from this model assembly line. This model does not represent a
specific plant line nor is it intended to include all parameters of such
lines.
The solvent-based spray primer case described in Chapter 3 (Table 3-10),
based on typical coating application rates and solids content, results in
approximatley 1020 tonnes (2,244,000 pounds) of solvent emission per year.
The conveying organic solvent, 5.71 liters per vehicle (Table 3-13), was
assumed to completely discharge to the atmosphere. At 24 volume percent
7-5
-------
Table 7-1. OPERATING OPTIONS
Spray Technology Case* (No add-on controls)
j
Primer ~ solvent-based coatings applied by air spray
Topcoat — solvent-based coatings applied by air spray
Base Case
Primer ~ water-based coatings applied by EDP
Guide coat — solvent-based coatings applied by air spray
Topcoat — solvent-based coatings applied by air spray
Regulatory Option I(A)
Primer — water-based coatings applied by EDP
Guide coat — water-based coatings applied by air spray
Topcoat ~ water-based coatings applied by air spray
Regulatory Option I(B)
Primer ~ water-based coatings applied by EDP
Guide coat — solvent-based coatings applied by air spray
Topcoat ~ solvent-based coatings applied by air spray with incineration
of spray booth and oven exhaust
I
Regulatory Option II
Primer — water-based coatings applied by EDP
Guide coat — solvent-based coatings applied by air spray with
incineration of spray booth and oven exhaust
Topcoat — solvent-based coatings applied by air spray with incineration
of sp^ay booth and oven exhaust
*Spray transfer efficiency is assumed to be 43 percent in all options.
7-6
-------
Table 7-2. UNCONTROLLED AND CONTROLLED EMISSIONS FROM AUTOMOBILE
SURFACE COATING OPERATIONS
(tonnes/year)
Spray Technology Case (No add-on controls)
Primer —• solvent-based
Topcoat -- solvent-based
Total
1020
1489
2509
Base Case
Primer — EDP water-based coatings
Guide coat — solvent-based coatings
Topcoat -- solvent-based coatings
Total
37
249
1489
1775
Regulatory Option I(A)
Primer — EDP water-based coatings
Guide coat — water-based coatings
Topcoat — water-based coatings
Total
37
41
295
373
Regulatory Option I (B)
Primer -- EDP water-based coatings
Guide coat — solvent-based coatings
Topcoat — incinerated solvent-based coatings
Total
37
249
149
435
Regulatory Option II
Primer — water-based coatings
Guide coat — incinerated solvent-based coatings
Topcoat — incinerated solvent-based coatings
Total
37
26
149
212
7-7
-------
solids, 1.82 liters of solids are sprayed, 43 percent of which are applied
to the vehicle and the remainder are oversprayed. For the base case, a
prime coating was applied by EDP followed by an air-sprayed guide coat of
i
24 volume percent organic solvent. The EDP coating was assumed to contain
4 volume percent solvents, which at an average application rate of 5.30 liters
per vehicle (1.4 gal/ vehicle) results in 37 tonnes (81,400 pounds) of
solvent emissions per year for the EDP step.2 The solvent guide coat was
applied by air spray at an application rate of 1.4 liters/solvent emission
per vehicle, which results in an additional 249 tonnes (547,800 pounds) per
year solvent emissions:
I
1.4£/veh x 211,200 veh/yr x 0.839 kg/A x 10"3 tonnes/kg = 249 tonnes/yr
Regulatory Option I(B) employed incineration of bake oven and spray
booth exhaust for the topcoat, while the guide coat and topcoat would both
be organic solvent based. Incineration was assumed to provide 90 percent
removal of the VOC emitted. A similar percentage removal of the guide coat
VOC was assumed for Regulatory Option II.
7.1.3.2 Light-Duty Trucks
The model light-duty truck assembly line produces 145,920 bodies per
i
year (in 240 work days). As in the automobile base case, the model being
discussed here does not represent a specific line nor is it intended to
indicate that all light-duty truck surface coating operations have these
parameters. Table 7-3 shows uncontrolled and controlled emissions from
this model light-duty truck assembly line for the options listed in Table 7-1.
i i
Emission control for the light-duty truck industry segment was determined
by the same approach as for the automobile segment. Primers of 30 percent
1 !
solids by volume and 28 percent for topcoat were selected.
7-8
-------
Table 7-3. UNCONTROLLED AND CONTROLLED EMISSIONS FROM LIGHT-DUTY TRUCK
SURFACE COATING OPERATIONS
(tonnes/year)
Spray Technology Case (No add-on controls)
Primer ~ solvent-based
Topcoat -- solvent-based
Total
649
1080
1729
Base Case
Primer — EDP water-based coatings
Guide coat — solvent-based coatings
Topcoat — solvent-based coatings
Total
21
172
1080
1273
Regulatory Option I(A)
Primer ~ EDP water-based coatings
Guide coat — water-based coatings
Topcoat -- water-based coatings
Total
21
28
229
278
Regulatory Option I(B)
Primer ~ EDP water-based coatings
Guide coat — solvent-based coatings
Topcoat — incinerated solvent-based coatings
Total
21
172
108
301
Regulatory Option II
Primer — water-based coatings
Guide coat — incinerated solvent-based coatings
Topcoat -- incierated solvent-based coatings
Total
21
18
108
147
7-9
-------
7.1.4 Estimated VOC Emission Reduction in Future Years
7.1.4.1 General
". i
After a record production of 9.7 million automobiles in 1973, sales
declined in 1974 and 1975. In 1976, the auto industry staged a comeback
'* : i .. . i,
and production returned to over 8 million automobiles, with further gains
in 1977 to greater than 9 million. A recent study estimates U.S. production
3
will be approximately 11 million units in 1985.
As with the automobile industry, the truck industry was affected by
the recession. After the record production of 3,007,495 units in 1973,
production slackened in 1974 and 1975. However, truck production in 1976
increased 37 percent over 1975 production and exceseded the record high of
1973 by about 8000 units.4'5 Short-range (to 1983) expansion rates are
projected at approximately 4 percent per annum. Based on these growth
figures and the above estimate that light-duty truck production accounts
for 75 percent of total truck production, the manufacture of these vehicles
is expected to reach 2.54 million in 1979, 2.65 million in 1980, and
2.98 million in 1983.6
7.1.4.2 Automobiles
In 1979, approximately 9.6 million automobiles were manufactured in
the U.S. As stated in Chapter 4, it is expected that two new automobile
assembly lines will be added to meet the expected production rate of
10.87 million automobiles in 1983.
To determine the impact of VOC emission reduction by new standards of
I
performance, an industry-wide emission scenario was developed. For the
1 j
1979 base case, it was assumed that 40 percent of the lines use solvent-based
primer and 60 percent use water-based primer. All indications are that the
7-10
-------
automobile industry recognizing the technological merits of EDP of
water-based primer will tend to continue to use water-based primers in
increasing amounts. As this would occur even without air pollution control
regulations, the base case represents a continuation of state-of-the-art
technology. In Regulatory Option I(A), both new lines are assumed to be
water-based for guide coat and topcoat systems. In Regulatory Option 1(8),
the new lines would use incineration of the solvent-based topcoat emission.
For Regulatory Option II, these new lines are expected to have incineration
on both the guide coat and topcoat spray booth and oven exhausts. As shown
in Table 7-4, Regulatory Option I(A) would cause a decrease in emissions
amounting to approximately 2,804 tonnes (6,168,800 pounds) per year.
Emission values for this scenario were taken from Table 7-2.
7.1.4.3 Light-Duty Truck
As with automobiles, it is assumed that EDP of water-based primer will
be the preferred primer technology for new surface coating lines even if no
controls are used. The data presented in Table 7-3 are based on the assumption
that 145,920 trucks are manufactured per line per year. In 1979, 2.54
million light-duty trucks were manufactured. With the addition of two new
light-duty truck assembly lines by 1983, it is expected that manufacture of
these vehicles will increase to 2.98 million. Table 7-5 presents the
projected emission impacts for 1979 and 1983 produced by the various regulatory
options as discussed in Section 7.1.4.1. Regulatory Option I(A) would
cause a projected decrease of approximately 2000 tonnes (4,400,000 pounds)
per year in solvent emissions.
7-11
-------
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7-13
-------
The use of Regulatory Option I(A) for both automobile and light-duty
truck operations results in an overall reduction in solvent emissions
amounting to approximately 4800 tonnes (10,560,000 pounds) per year.
7.2 WATER POLLUTION IMPACTS |
j
As the industry has changed its surface coating operations to
minimize VOC emissions, increasing amounts of water have been used to
transfer the solids. Minor discharges of wastewater from EDP dripping,
spills during cleanup, and from spray booth removal of overspray are the
primary liquid wastes.
i < i
7.2.1 Ultrafiltration
!' i
Water-based EDP primers are prepared by neutralizing highly acidic
polymers with an alkali (e.g., amines) so that these polymers can be
dissolved or suspended in water. Small amounts of solvents are also added
to increase the dispersibility of polymers in water.
During EDP, the solids coat the automobile or light-duty truck body,
leaving alkali coalescing solvents behind in the dip tank. These solvents
must be removed. In modern installations, ultrafiltration is used to
'• - I
continuously remove water-solubles and chemical agents that are left behind
during the process (see details in Section 7.3). Any effluent originating
from a properly operated ultrafiltration unit can be adequately handled in
municipal or in-house sewage treatment facilities. Low molecular weight
compounds that pass through the ultrafiltration membrane do exert chemical
oxygen demand (COD) as discussed in Chapter 4.
7.2.2 Dripping, Spills, and Cleanup
Water pollution can also occur if the electrocoating system allows
rinse water or coating to drip or be spilled on the floor and the rinse
7-14
-------
and/or cleanup water is not automatically placed in a reservoir for
treatment.
7.2.3 Dragout
At the end of the electrocoating operation, the dipped body is covered
with an additional film of adhering paint called dragout. This film is
more porous than the electrodeposited coating; therefore, it is usually
rinsed off. Dragout also occurs as the body leaves the dip tank. Dragout
is returned to the dip tank or the ultrafiltration system.
7.2.4 Overspray Removal
As mentioned in Chapter 4, guide coats and topcoats are both applied
by spraying. Spraying operations are carried out in.spray booths for which
most automobile companies use waterwall washing to control overspray. In
the spray booth, a portion of the total coating is deposited on the surface
of the object being coated. The amount of coating not deposited on the
object is called overspray. In a typical waterwall spray booth, the paint
particles from overspray are collected by a curtain of water flowing down
the face of a sheet of steel located at the rear sides of the booth—the
so-called waterwalls. These waterwalls flow between 25 and 50 gallons per
mini'te per foot. Thus, a 20-foot section would have a waterflow of approxi-
mately 600 gallons per minute. In actual practice, this means that a
spray booth 180 feet long would need between 4500 and 9000 gallons of water
per minute. A typical surface coating operation with four spray booths
would need between 18,000 and 36,000 gallons of water per minute.8 The
used water is removed from the booth and transported to a sludge tank,
where the solids are removed, and the water is recirculated. Air spray
Q
transfer efficiency varies from 30 to 60 percent. This wide range results
7-15
-------
from the operation's efficiency being dependent on individual operators and
the type of spraying technique used.
Solvent-based topcoats are composed primarily of solvents, which
separate readily from water. Water-based topcoats, however, are made with
i
water-miscible solvents to assure good suspension of the resin binder in
the water phase of the coating. These various water-miscible solvents
(glycols, and certain esters and alcohols) in water-based coatings are
extremely miscible with water and actually act as coupling agents between
I
i
suspended particles and water.
Solvents remaining in discharged water exert a COD. Chemical oxygen
1 i •' ' I : I I ,. I .
demand presents a problem, if it is discharged into a stream in sufficient
concentration and quantity to diminish the oxygen in the stream, thereby,
affecting fish and other aquatic life. Almost all assembly plants discharge
spray booth effluent, following solids removal, to municipal sewers—some
i , j
of which have restrictions on COD. The effluent from two General Motors
i
plants using water-based topcoats is acceptable to sewer authorities. If
necessary, techniques can be used to lower the COD.
No water pollution impact is associated with the other emission control
i
systems considered as options.
7.3 SOLID WASTE DISPOSAL IMPACT
Water-based primer EDP operations can have impact on solid waste
disposal. In older installations the dragout and rinse were discarded,
resulting in a waste disposal problem. This practice also caused coating
I
i • i
loss. Improvements have been made, however, to reduce coating loss by
returning the coating to the dip tank.
7-16
-------
In modern operations, ultrafiltratfon continuously removes the amine(s),
solvents, and water-solubles, which are left behind during the electrocoating.
Consequently, it is possible to set up a nearly closed system with practically
no waste.
Once a year there is a regular cleaning of the ultrafiltration system.
Otherwise, cleaning is not needed except on such occasions as when a paper
cup or other foreign object is accidently dropped into the dip tank. Such
a minor cleaning job, however, does not involve dumping more than a few
gallons of paint.
There are no serious waste disposal problems associated with
electrocoating. Sludge may develop in the dip tank, leading to a minor
solid waste disposal problem; however, sludge is generally the result of
improperly controlled chemistry in the tank or poor housekeeping (such as
allowing parts to accumulate in the tank). In any case, the amount of such
solid waste is not excessive.
While water-based primers no longer present serious sludge and solid
waste disposal problems, water-based topcoats are prone to do so. Water-^
based, topcoats, because they are partial or full suspension systems similar
to dispersion and/or emulsions, display considerably less storage stability
than do solvent-based topcoats, which are often actually true solutions.
In a dispersion, fine particles (of the binder) are suspended in a continuous
liquid phase such as water.
The stability of these suspension (also referred to as colloidal)
systems is very dependent on the water-to-sol vent ratio. This is especially
true when the water-to-sol vent ratio of a water-based topcoat is disturbed,
as it is when the overspray or the water-based topcoat hits the spray booth
7-17
-------
12
I ! • I
waterwall. In the waterwall, a major portion of the water-based topcoat
overspray is thrown out of suspension, forming lumps consisting of agglo-
i i
derated solids with locked-in water. This significantly increases the
8 10
amount of sludge formed in an automotive plant. '
Sludge formed during a conventional solvent-based topcoat operation--
as for example a combined light-duty truck/automobile production of 50
r . . . i i i
units per hour each, working with two shifts—results in a daily amount of
i
15,000 to 20,000 pounds.11 As an average, approximately four times more
sludge is formed during water-based topcoat operations than is formed
I
during solvent-based topcoat operations. For example, one of the automo-
tive plants reported that its sludge tank had to be cleaned only once a
year when using solvent-based topcoats, and when the plant switched to
water-based topcoats, the sludge tank had to be cleaned every three months.
Estimates of the exact amounts and compositions of the sludge by various
automotive industry spokesmen vary over a wide spectrum.
There are some basic differences between the treatment of sludge from
solvent-based coatings and that of water-based topcoats. Sludge from
" I ! 'I
water-based topcoats, in order to break the suspension system and to remove
i
the particles, is treated with slightly acidic compounds like calcium
acetate at a pH of 3 to 4.13 Ultrafiltration could be used to remove
colloidal particles, but this method is an expensive solution to the problem.
i : : i
The heavy metals in pigments of some topcoating solids may require special
disposal due to the potentially harmful nature of these materials.
However, the solid waste problem associated with the use of the
water-based coatings is minor when compared with the solid waste
considerations of the total automotive plant. Typical values for
13
7-18
-------
operations are given in Chapter 3, Table 3-14. There is little solid waste
impact associated with alternatives other than water-based coatings.
7.4 ENERGY IMPACT
Automobile and light-duty truck surface coating operations consume
significant amounts of energy. With the exception of catalytic incinerators—
with primary and secondary heat exchangers used on the curing oven—all the
regulatory options presented in this report require additional energy.
The energy impacts associated with each regulatory option are summarized
in Tables 7-6 through 7-13. These tables are a compact representation and
summary of energy balances prepared for the purpose of comparing the primary
energy required for a base case finishing model to the primary energy
required when pollution reduction coatings and/or add-on emission controls
are used.
Standards based on Regulatory Option I(A) would increase the energy
consumption of a typical new automobile and light-duty truck assembly plant
by the equivalent of about 18,000 barrels of fuel oil per year—this amounts
to an increase of approximately 25 percent. About one-third of this increase
in energy consumption is due to the use of air conditioning, which is
necessary with the use of water-based coatings, and the remaining two-thirds
are due to the increased fuel required in the bake ovens for curing water-based
coatings. Standards based on Regulatory Option I(B) would cause an increase
of about 150 to 425 percent in energy consumption; this amounts to an
increase of about 100,000 to 300,000 barrels of fuel oil per year. Standards
based on Regulatory Option II would result in an increase of 300 to 700 percent;
this is equivalent to about 200,000 to 500,000 barrels of fuel oil per
year, depending upon whether catalytic or thermal incineration were used.
7-19
-------
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TABLE 7-11. ENERGY BALANCE ~ ADD-ON EMISSION CONTROL SYSTEM
Light-Duty Truck Body Primer Application
Model Description
Incinerator on oven only,
10 X LEL
Thermal — primary heat
exchanger
Thermal — primary and
secondary heat
exchanger
Catalytic — primary heat
exchanger
Catalytic — primary and
secondary heat
exchanger
Incinerator on spray booths
onlyd
Thermal — primary heat
recovery
Catalytic — primary heat
recovery
Energy Requirements/145,920 Trucks3
Primer Application
»
Electricity
kW/hr
—
—
—
—
1,739,904
1,825,152
Fuel
106 Btu
..
—
._
~
748,800
278,784
Primer Cure Oven
Electricity
kW/hr
46,080
53,760
53,760
61,440
«...
—
Fuel
106 Btu
6,720
2,120°
1,152
(960)C
.,_
—
Total Energy
Requirements
106 Btu
7,181
2,658
1,690
(346)
766,199
299,035
*145,920 trucks — the yearly output of a model surface coating operation
"Energy credit from secondary heat recovery is included.
cjhe parentheses indicate that the shown amount of energy is a credit.
QDoes not include energy for comfort heating of spray booth air
7-25
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7-26
-------
TABLE 7-13. ENERGY BALANCE — ADD-ON EMISSION CONTROL SYSTEM
Light-Duty Truck Body Topcoat Application
Model Description
Incinerator on oven only,
10 X La
Thermal — primary heat
exchanger
Thermal — primary and
secondary heat
exchanger
Catalytic — primary heat
exchanger
Catalytic — primary and
secondary heat
exchanger
Incinerator on spray booths
only**
Thermal — primary heat
recovery
Catalytic — primary heat
recovery
Energy Requirements/145,320 Trucks*
Primer Application
Electricity
kW/hr
—
—
—
—
2,977,920
3,134,208
Fuel
1Q6 Btu
—
~
—
—
1,267,200
464,640
Primer Cure Oven
Electricity
kW/hr
69,120
80,640
72,960
84,480
—
—
Fuel
106 Btu
9,600
3,070°
1,536
(2,304)C
—
—
Total Energy
Requirements
10« Btu
10,291
3,876
2,266
(1,459)
1,296,979
495,982
*145,920 trucks ~ the yearly output of a model surface coating operation
"Energy credit from secondary heat recovery is included.
5/The parentheses indicate that the shown amount of energy is a credit.
aQoes not include energy for comfort heating of spray booth air
7-27
-------
The relatively high impact of standards based on Regulatory Option I(B) and
Regulatory Option II is due to large amounts of incineration fuel needed.
As previously stated, growth projections indicate that four new assembly
lines (two automobile and two light-duty truck lines) will be built by
1983. Based on these projections, standards based on Regulatory Option I(A)
would increase national energy consumption in 1983 by the equivalent of
about 72,000 barrels of fuel oil. Standards based on Regulatory Option I(B)
would increase national energy consumption in 1983 by the equivalent of
400,000 to 1,200,000 barrels of fuel oil, depending upon whether catalytic
or thermal incineration were used. Standards based on Regulatory Option II
would increase national energy consumption in 1983 by the equivalent of
800,000 to 2,000,000 barrels of fuel oil, again depending upon whether
catalytic or thermal incineration were used.
Table 7-14 presents a summary of the primary energy requirements of
each option and the incremental increase for each option.
7.5 OTHER ENVIRONMENTAL IMPACTS
No other environmental impacts are likely to arise from standards of
" ' ' . ,'',', , „ i ,
: i * ' •' I" '''" '
performance for automobile or light-duty truck surface coating operations,
i *
regardless of which alternative emission control system is selected as the
i
basis for standards.
7.6 OTHER ENVIRONMENTAL CONCERNS
i
7.6.1 Irreversible and Irretrievable Commitment of Resources
The alternative control systems will require the installation of
additional equipment, regardless of which alternative emission control
i
system is selected. This will require the additional use of steel and
other resources. This commitment of resources will be small compared to
7-28
-------
TABtE 7-14. SUMMARY OF ENERGY REQUIREMENTS FROM REGULATORY OPTIONS
Automobile Line
Option I(A)
Primer ~ EDP Water-based
Guide Coat -- EOF Water-based
Topcoat -- EDP Water-based
Energy
Requirements
106 Btu
253,101
319,825
Incremented
Increase Base
106 Btu 106 Btu
29,801 223,300
84,862 234,963
Option I(B)
Primer — EDP Water-based
Guide Coat -- Solvent-based
Topcoat — Solvent-based with incineration
Thermal
Catalytic
223,300
2,008,563
909,151
0 223,300
1,773,600 . 234,963
674,188 234,963
Option II
Primer — EDP Water-based
Guide Coat ~ Solvent-based with incineration
Thermal
Catalytic
Topcoat — Solvent-based with incineration
Thermal
Catalytic
223,300
1,300,855
494,650
2,008,563
909,151
1,795,505 223,300
1,300,855 0
494,650 0
1,773,600 234,963
674,188 234,963
7-29
-------
the national usage of each resource. A good quantity of these resources
will ultimately be salvaged and recycled. There are expected to be no
significant amounts of space (or land) required for the installation of
control equipment and/or new coating technology, because all control systems
can be located within little additional space. Therefore, the commitment
of land on which to locate additional control devices and/or application
equipment is expected to be minor.
As has been noted, the use of primary and secondary heat recovery
would enhance the value of incineration. Without heat recovery, significant
energy would be lost.
7.6.2 Environmental Impact of Delayed Standards
Delay of standards proposal for the automobile or light-duty truck
industry will have negative environmental effects by increasing VOC emis-
sions to the atmosphere and minor, or no, positive impacts on water and
solid waste. Furthermore, there does not appear to be any emerging emis-
sion control technology on the horizon that could achieve greater emission
reductions or result in lower costs than that represented by the emission
1 i 'I
control alternatives under consideration here. Consequently, delaying
standards to allow further technical developments appears to present no
trade-off of higher solvent emissions in the near future for lower
emissions in the distant future.
7.6.3 Environmental Impact of No Standards
Growth projections have been presented in earlier sections. It is
obvious that the increased production of automobiles and light-duty trucks
will add to national solvent emissions.
7-30
-------
There are essentially no adverse water and solid waste disposal impacts
associated with the alternative emission control systems proposed in this
section. Therefore, as in the case of delayed standards, there is no
trade-off of potentially adverse impacts in these areas against the negative
result on air quality which would be inherent with not setting standards.
7-31
-------
REFERENCES
j
i
1. less, Roy W. Chemistry and Technology of Solvents. Applied Polymer
Science. Chapter 44. American Chemical Society, Organic Coatings and
Plastics Division. 1975.
2. Baum, B., et al. Second Interim Report on Air Pollution Control
Engineering and Cost Study of the Transportation Surface Coating
Industry, DeBell and Richardson, Inc. Enfield,Connecticut.
EPA contract no. 68-02-2062. May 1977. p. B-36.
j
3. DeBell and Richardson. Plastics in the Automotive Industry.
Enfield, Connecticut. 1975-1985.
4. DeBell and Richardson Trip Report 13. ;
i
5. Automotive News, Yearbook Issue, 1978.
6. Auto News. 1975 Almanac Issue. April 23, 1975. p. 55.
7. Telecon. Gabris, T. with George Koch Sons, Inc., Evansville, Indiana.
October 29, 1976.
8. DeBell and Richardson Trip Report 110.
9. DeBell and Richardson Trip Report 56.
, , i
10. DeBell and Richardson Trip Report 102.
i
3,1. DeBell and Richardson Trip Report 120.
12. Telecon. Gabris, T. with one of the California General Motors plants.
October 29, 1976.
13. Gervert, Phil. General Motors Water Pollution Section. November 2, 1976.
7-32
-------
8. ECONOMIC IMPACT
Chapter 8 contains four sections covering the economic impact of
the proposed VOC control. In Section 8.1, the structure of the motor
vehicle industry and its role in the U.S. economy are described. Two
major segments of the motor vehicle industry, passenger cars and light-
duty trucks, are identified and characterized. This industry description
includes geographic distribution, concentration and integration, import/
export considerations, demand determinants, price determination, price
leadership, price uniformity, nonprice considerations, price-cost
relationships, projected demand, determination of existing capacity, and
of projected capacity needs.
In Section 8.2, control costs and cost effectiveness for
alternative VOC control systems are developed. Costs for controls of
three variations of line speed for cars as well as for light-duty trucks
are included.
Section 8.3 identifies other cost considerations and rates their
potential impact on the economic analysis of emission control systems.
In Section 8.4, the economic impacts of alternative emission
control systems are analyzed. Included is an assessment of the magnitude
of cost of relative degrees of control and their impact on prices in the
industry.
-------
The major conclusion of Chapter 8 is that the economic impact of
\
each considered alternative control system is moderately small and that
the cost of NSPS should not preclude construction of new grass roots
j
assembly lines.
8.1 INDUSTRY ECONOMIC PROFILE
I
j :
8.1.1 Role of Motor Vehicle Industry in the U.S. Economy
i
The motor vehicle industry* occupies a key pivotal position in the
U.S. economy. As a substantial consumer of steel, rubber, iron, aluminum,
copper, zinc, lead, and glass, it determines to a certain extent the
economic viability of these major U.S. manufacturing industries. In
i ' I
addition, the marketing and servicing of motor vehicles has created an
infra-structure equally essential to other segments of the domestic
economy, such as the petroleum industry.
About 2 percent of the gross national product and about 14 percent
1
of the national income from durable goods are generated by the motor
vehicle industry.1 According to a recent report by a Federal task
force, the industry provides direct employment for 955,000 members of the
U.S. labor force. The magnitude of indirect employment is even more
substantial; an additional 3.4 million Americans owe their livelihood, at
2
least in part, to the existence of the motor vehicle.
As a result of increased governmental requirements regarding
. i . i
environmental, safety, and fuel economy standards, the motor vehicle
*The term "motor vehicle industry" is used in this section to denote
machine tool, parts and components, and assembly segments of the
industry, regardless of vehicle type; in the following sections of this
chapter the vehicle types considered are only passenger cars and light
trucks, and the industry segments are broadened to include marketing and
servicing.
8-2
-------
industry has entered a period of unprecedented technological change.
Concommitantly, strong competition is present from the import sector of
the market. The ability of the industry to cope with these and other
exogenous constraints, such as changes in consumer taste, will determine
whether the present role of the motor vehicle industry remains the same or
is altered.
8.1.2 Structure of the Industry
8.1.2.1 Concentration
The production of automobiles and light-duty trucks in the United
States represents one of the nations's most concentrated industries. Three
companies, General Motors, Ford Motor Company, and Chrysler Corporation,
have accounted for most of the industry's production almost since its
inception. The merger of two independents in 1954 resulted in the
formation of American Motors Company, which subsequently became the
fourth-ranking firm in the industry. Whether measured by capitalization,
sales, profits, breadth of product line, or number of distribution
outlets, General Motors is the dominant firm in the industry, followed by
Ford, Chrysler, and American Motors, in that order.
Historically, many other firms have attempted to enter the market
but U.S. based companies have not been successful in the long run.
Checker Motors, International Harvester, and Volkswagen currently
participate in the industry, but only on the periphery.
The automobile and light-duty truck industry is of such magnitude
that it could conceivably accommodate a number of competitive firms in its
structure. The fact that four firms have consistently comprised almost
the entire industry suggests that they have acquired resources that have
not only permitted them to survive, but have also forestalled the
8-3
-------
successful entry of other firms into the industry. However, a Canadian
task force reviewing the North American automotive industry reached the
.
conclusion that there is no evidence that there has been any attempt to
. . . i.
limit competition despite the fact that it is virtually impossible for a
new company to enter the motor vehicle market because of very high
development and start-up costs.3 The degree of vertical and horizontal
integration present within the industry reflects the influence of these
!
resources. '
8.1.2.2 Integration
ill! 'I
|
Vertical integration within the industry is obvious and well
defined. Reproduction integration for some of the firms extends as far
i
as captive iron and steel foundries, which provide the raw materials for
component parts. Integration at the production level is largely achieved
, , j
through captive establishments that supply many of the engines,
transmission, fabricated parts, and other major components required for
body and final assembly. Postproduct integration extends to franchised
dealers who distribute the product and to subsidiary companies that
finance consumer purchases. Postmarket integration exists in the form of
i
franchised repair and supply facilities.
i . i j
Horizontal integration is reflected in the firms' interests in the
j
manufacture of nonautomptive products such as boats and farm equipment.
International Harvester is the only significant company in light-duty
truck manufacture that has a significant revenue from farm equipment.
8.1.2.3 The United States-Canada Automotive Agreement
The working relationship between the United States and Canada,
, , . . i
beginning with implementation of the United States-Canada Automotive
Products Agreement in 1965, established, in essence,"a free trade zone
8-4 ' ^ ' ' "!
-------
between the two countries. It allowed the then-established U.S.
automotive firms freedom of access to Canadian labor and consumer markets,
and, through restrictive clauses in the Agreement, ensured the perpetuation
of the Canadian automotive industry.* In effect, only General Motors, Ford,
Chrysler, and American Motors are participants in the Agreement; Canada holds
the right to impose tariffs on any other firms seeking to establish trade in
the Canadian sector. To the extent that Canada chooses to exercise that
right, Volkswagen's entry into the Canadian sector of the industry is
constrained. The Agreement has no time limit, but either government may
terminate it on 12 months notice. The net effect of the Agreement has been
to provide an integrated North American motor vehicle industry and market.
Consideration of the U.S. domestic motor vehicle industry in this study takes
into account available Canadian resources and the reciprocal drain on U.S.
production by Canadian demand.
8.1.2.4 Geographic Distribution
At the beginning of 1978, passenger cars and light-duty trucks**
were being assembled at 51 and 31 locations, respectively, in the United
States and Canada. Total reported outputs from these plants in 1977 were
10,095, 364 passenger cars and 3,455,504*** light-duty trucks.4 A
listing of North American passenger car assembly locations, by firm, is
shown in Table 8-1 and light-duty truck locations, by firm, in Table 8-2.
*The term "automotive industry" as used here includes both automobile and
truck production.
**The term "light-duty truck" is defined in Chapter 3 of this report as
"all vehicles with ratings of 8,500 pounds or less GVW." Included in
this classification are pickup trucks, vans, panel trucks, station
wagons built on pickup truck chassis, multistop trucks, and off-road
vehicles.
***Lack of specificity in Canadian data required estimation of light-duty
truck production. This figure assumes light-duty truck production to
be 90 percent of total truck production.
8-5
-------
TABLE 8-1. NORTH AMERICAN AUTOMOBILE ASSEMBLY LOCATIONS^
1977
Manufacturer
Plant Location
General Motors Corporation
Ford Motor Company
Arlington, Texas
Baltimore, Maryland
Detroit, Michigan
Doraville, Georgia
Fairfax, Kansas
Flint, Michigan(2)
Framingham, Massachusetts
Fremont, California
Janesville, Wisconsin
Lakewood, Georgia
Lansing, Michigan
Leeds, Missouri
Linden, Mew Jersey
Lordstown, Ohio
Norwood, Ohio
Pontiac, Michigan
South Gate, California
St. Louis, Missouri
N. Tarrytown, New York
Van Nuys» California
Willow Run, Michigan
Wilmington, Delaware
Oshawa, Ontario
St. Therese, Quebec
Atlanta, Georgia
Chicago, Illinois
Dearborn, Michigan
Kansas City, Missouri
Lorain, Ohio
Los Angeles, California
Louisville, Kentucky
Mehwah, INew Jersey
Metuchen, New Jersey
San Jose, California
St. Louis, Missouri
Twin Cities, Minnesota
Wayne, Michigan
Wix&n, Michigan
Oakville, Ontario
St. Thomas, Ontario
8-6
-------
TABLE 8-1. Concluded
Manufacturer
Plant Location
Chrysler Corporation
American Motors Company
Checker Motors Company
Belvedere, Illinois
Hamtramck, Michigan
Detroit, Michigan (2)
Newark, Delaware
St. Louis, Missouri
Windsor, Ontario
Kenosha, Wisconsin
Brampton, Ontario
Kalamazoo, Michigan
8-7
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TABLE 8-2. NORTH AMERICAN LIGHT-DUTY TRUCK
ASSEMBLY LOCATIONS5
1977
General Motors
Arlington, Texas
Baltimore, Maryland
Doraville, Georgia
Fremont, California
Janesville, Wisconsin
Lakewood, Georgia
Leeds, Missouri
Lordstown, Ohio
St. Louis, Missouri
Flint, Michigan
Oshawa, Ontario
Scarborough, Ontario
Ford
Atlanta, Georgia
Avon Lake, Ohio
Kansas City, Missouri
Lorain, Ohio
Louisville, Kentucky
Mahwah, New Jersey
Wayne, Michigan
San Jose, California
Norfolk, Virginia
Ontario Truck, Ontario
Oakville, Ontario
Chrysler
Warren, Michigan
Fenton, Michigan
Pilette Road, Ontario
Tecumseh Road, Ontario
American Motors
Toledo, Ohio
South Bend, Indiana*
International Harvester
Fort Wayne, Indiana
*This plant, operated by A.M. General Corp,, a
subsidiary of American Motors, is used for
military and postal vehicle production.
8-8
-------
Traditionally, production facilities have been centered in the
Great Lakes region because of the availability of transportation for
component parts to production facilities and for finished products from
production facilities. However, differentials in labor costs and overhead
have resulted in more recently built plants being located in nontraditional
areas such as the southwestern part of the United States.
Recent industry growth continues to follow this pattern. Volkswagen,
a newcomer to the domestic passenger car industry, began operations in New
Stanton, Pennsylvania in March 1978. In Oklahoma, General Motors has begun
construction of its first new car assembly plant in 14 years. This plant is
scheduled to become operational for model-year 1980. Another plant being
constructed by General Motors in Shrevesport, Louisiana, is expected to be
producing light-duty trucks by 1981.
Extensive retooling of existing plants by several of the firms in the
industry is planned in response to the need for compliance with energy,
safety, and environmental standards set by the government.
8.1.2.5 Import/Export Considerations
8.1.2.5.1 Imports
Import penetration of the United States new car market began in
earnest with the introduction of the Volkswagen Beetle in the late 1950's.
By 1958 the economic climate resulting from the 1957 to 1958 recession, and
a lack of small car production on the part of the domestic manufacturers,
combined to make possible the capture of over 10 percent of the market by
foreign imports.* This initial success was almost immediately offset,
*For purposes of this study, the term "foreign imports" is used to denote
vehicles manufactured outside of North America.
8-9
-------
however, by a series of events that, for a time at least, returned the
competitive edge to domestic manufacturers. One of these events was the
introduction of competitively designed small cars into the domestic
automobile lines. Another event was the recovery of the U.S. economy from
the 1957 to 1958 recession, which brought with it an increased demand for
larger, more expensive cars. The third event was the entry into the U.S.
market of imports that proved unsatisfactory for American driving habits,
!
and for American standards of maintenance and service. This resulted in a
i
severe setback in the American public's confidence in, and acceptance of,
foreign cars in general.
Throughout the 1960's the trend in consumer purchases was toward
large cars. Domestic manufacturers virtually abandoned the small-car
concept. As a result, the share of the market for imports increased
steadily. Japan's successful entry into the market in 1965 was a major
milestone in import growth. Volkswagen sales had peaked by 1970, but
Japanese imports continued to grow. Despite Detroit's attempt to fight
back by introducing subcompacts such as the Pinto and Vega in 1971, and
despite the devaluation of the dollar relative to Japanese and German
i
currency after 1971, the trend in favor of imports continued. Market
share for imports peaked at 18.2 percent in 1975, declined to 14.8 percent
in 1976, and rose to 18.5 percent in 1977.
Imports have had a lesser impact on the light-duty truck market
than on the new car market. In 5 of the last 8 years, the import share of
the light-duty truck market has hovered between 8 percent and 9 percent,
and it has not risen above 11.2 percent.4'5 The inability of foreign
i
manufacturers to penetrate the domestic market more extensively may be
8-10
-------
explained to some degree by restrictive tariffs that have been imposed on
the importation of fully assembled light-duty trucks. ,
The degree of import penetration in the light-duty truck market
becomes even less pronounced when the behavior of captive (foreign
manufacture under domestic manufacturer contract) imports is considered.
These have been commanding a larger share of the import market for several
years. However, there is some doubt as to whether this trend will
continue as the upcoming fuel economy standards for light-duty trucks
raises the question of whether the required method of computing corporate
mileage will include or exclude captive imports.
Recently, importers who have done well with light-duty trucks have
begun exploring the possibility of making new breakthroughs in the heavy-
duty truck market, based on an anticipated changeover from gas to diesel
power. This poses a new threat to Ford and International Harvester, who
are currently the leaders in heavy-duty truck production, and might well
lead to their more aggressive participation in the light-duty truck
market.
The future of the import influence on the domestic market has two
perspectives. Some analysts predict that the import share of the market
will continue to rise because foreign manufacturers, reassured by
continued positive sales performance, may consider establishing
manufacturing operations in the U.S. This prediction would appear to be
supported by the fact that in September 1977, Honda Motor Company of Japan
revealed plans for the construction of a motorcycle plant in the United
States, with car assembly the obvious next step. The manufacturers of
Toyota and Datsun, two leading Japanese imports, are also studying the
possibility of establishing U.S. assembly facilities.
8-11
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! .li1* ' Illf! illli!,'1
I
Critics of this viewpoint believe that the establishment of new
facilities in the U.S. by foreign manufacturers need not imply further
erosion of domestic market shares. They contend that the market share
attributable to the new facility may come from the present share held by
the same manufacturer. Some critics go even further and argue that import
j
penetration is transient. The influence of government regulations
regarding emission control, passenger safety, and fuel economy, and the
narrowing of price competition between imports and domestic cars are seen
as factors that will return a portion of the import market share to
existing domestic manufacturers. In support of this contention, a review
of the North American auto industry undertaken by the Canadian government
in 1977 came to the conclusion that the tide of imports in the North
American market "has peaked and the global industry has reached equilibrium."
8.1.2.5.2 Exports
United States exports of finished cars to any country other than
Canada are practically negligible. Not only have most other countries
erected and maintained formidable trade barriers in this regard, but there
is also little evidence that, even without these barriers, there would be
any significant market there for United States cars. Therefore, U.S. car
manufacturers have so far elected to put little emphasis on exports, per
se, preferring instead to invest directly in car production plants,
located within the countries themselves, for the production of European-
type cars.7 Exports are only a minor portion of U.S. truck sales, never
. , 8
having exceeded 100,000 units in any single year.
8.1.2.6 Demand Determinants
Demand for new cars and light-duty trucks is a fluctuating
. . . , . ,, j
phenomenon that reflects the influence of several classical determinants
8-12 !
-------
of demand. Consumer personal disposable income, consumer expectations,
price, the availability of substitute goods, and consumer taste may all
influence demand.
Income
The conclusion of most researchers has been that personal disposal
Q
income is the most important demand determinant. When consumers are
prosperous, car and light-duty truck sales tend to increase. When
recession, inflation, high unemployment, and general economic uncertainty
have been present, consumers have hesitated to purchase vehicles. A rise
in car ownership by household tends to accompany a rise in real income.
At high income levels, a saturation in the demand for additional
automobiles is evident, with further income increases producing very
little change in auto ownership.
Expectations
Closely related to income is the consumer's expectations regarding
the behavior of prices in relation to his anticipated income. Reflected
in the increasing volume of car and light-duty truck sales is the
expectation that prices will escalate more rapidly than personal income.
To the extent that this is so, consumers tend to replace vehicles before
anticipated price increases.
Price
Price also influences consumer demand for new vehicles. If price
is increased, the quantity of cars or trucks demanded in the short run
will fall as consumers postpone their purchase or turn to a substitute
good.
11
It should be noted that the demand for high-priced cars is less
responsive to increased prices than is the demand for lower-priced cars
8-13
12
-------
The consumer of the high-priced car will, as a general rule, postpone his
purchase, but will not turn to a substitute good. However, consumers of
lower-priced cars may downgrade their purchase13 or may substitute a
used car or a lower-priced import. Therefore, price differentials are
i
extremely important in this area of the new car market. Price
differentials are also extremely important in the light-duty truck market,
since consumers can substitute either used or imported vehicles.
Substitute Goods
Viable substitutes for passenger cars and light-duty trucks include
imported vehicles, used vehicles, and substitutions within and among model
classes. Within certain settings, the accessibility of public
i
transportation is also a factor. Imports and substitutions within and
i
among model classes provide perfect substitutes for new vehicles. Used
cars provide the consumer with a wide range of close substitutes. Public
transit systems, taxicabs, rental vehicles, and commercial delivery
services substitute only in metropolitan settings.
Taste
As a determinant of demand, consumer taste is most fickle,
subjective, and nonquantifiable. Taste is comprised, among other things,
of design, styling, size, brand loyalty, self-image, and status. Its
influence is demonstrated by the recent trend away from the purchase of
family cars and toward the purchase of vans and other light trucks for
recreational use and leisure activities. It has been estimated that
approximately 500,000 light-duty truck sales represent substitution sales
for passenger cars in this past model year
14
8-14
-------
8.1.2.7 Pricing Procedures
8.1.2.7.1 Price Determination
Pricing practices in the industry appear to substantiate the post-
Keynesian economic theory that "the pricing behavior of oligopolistic
firms in the manufacturing sector of industrialized capitalist economies
can be explained by the demand for funds from internal sources for
15
purposes of investment expenditures. In .theory, current actual costs
are not used in pricing, and no attempt is made to maximize the rate of
return in any single year. Demand is a factor in production rather than
pricing, in that the imnediate response to either increased or decreased
demand is accelerated or decelerated production rather than higher or
lower price. Thus, pricing to achieve a target rate of return is
concerned with funding requirements for planned investment expenditures
rather than current cost or demand conditions.
Over the years, General Motors has had the discretionary power to
establish prices for its products that have generated sufficient cash flow
to finance internally much of the investment expenditures it has
undertaken. The pricing method used by General Motors is to project unit
costs (direct labor and materials, plus unit overhead) on the basis of a
"standard" volume (about 80 percent of capacity) and then add on a profit
margin designed to yield a target rate of return sufficient to support
long-range capacity and expansion objectives.
Ford, Chrysler, and American Motors consider cost plus a reasonable
profit as their base selling price. Ceiling prices have been set by
pricing as close to the competition as possible.
8-15
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8.1.2.7.2 Price Leadership
i
The dominance of General Motors in the industry is evident in the
40 percent to 50 percent share of the domestic market it has held since
1931. This strong market share provides a basis for price leaderhip in
the industry. While the role of first announcing price appears to be
in" : j
about equally divided between General Motors, Ford, and Chrysler, it is
apparent that Ford and Chrysler frequently attempt to anticipate and
follow the pricing actions of General Motors, and, when necessary, to
i ' I '" :
back ad just.
,
A clear example of the latter type of movement occurred in .
September, 1956 when Ford announced a suggested price list for 1957 models
I
that entailed an average 2.9 percent increase over 1956 models, ranging
' i
from $1 to $104 per model. Two weeks later, General Motors announced an
average 6.1 percent increase over 1956 prices for its Chevrolet models,
with price increases ranging from $50 to $166 per model, within the week,
! i
Ford had revised its prices upward so that on ten models the price :
differential with Chevrolet was only $1 to $2. A week later, Chrysler
i
announced the price of Plymouths at approximately $20 higher than
Chevrolet, consistent with Chrysler's traditional pricing pattern.
More recently, in response to the government's voluntary price
deceleration program, General Motors announced that it would move away
from the industry's usual practice of raising car prices once a year, >nd
19
would, instead, raise prices whenever it was deemed appropriate. In
setting this new pricing trend, General Motors suggested that it would be
able to keep price rises over the 1978 model year at about 5 to
5.5 percent compared with the 6 percent average boosts of the past
2 years. While neither Chrysler nor Ford has made any such commitment, a
I'
8-16
18
-------
spokesman for Chrysler stated that "any pricing action in the future would
continue to depend on the competitive situation and other factors."
8.1.2.7.3 Price Uniformity
Historically, list price differentials among different
manufacturers' models in the same model class have tended to be small.
Similarly, price differentials in the cost of accessories, options, and
the hundreds of possible combinations of models/accessories are slight.
The uniformity in pricing in these areas reflects the fact that General
Motors has nearly half of the total market and twice the share of its
nearest competitor, thereby effectively inundating price competition
within the industry.
8.1.2.8 Nonprice Competition
In the North American automobile and light-duty truck market, much
of the demand for vehicles is replacement demand. Because the purchase of
a new vehicle is a deferrable item, and because perfect and close
substitutes are available, manufacturers have had to develop strategies
that ensure the constant stimulation of replacement sales. With the
virtual disappearance of price differentials as a factor of competition,
these strategies take the form of nonprice competition such as frequent
design and styling changes, aggressive and imaginative marketing
techniques, and dealer-buyer incentive programs.
Major design and styling changes are introduced by manufacturers
every few years, with more modest changes in trim and styling occurring in
the intervening years. To the extent that consumers see their vehicles as
symbols of affluence, as a means of acquiring distinction, or as an
expression of personality, these changes move them toward vehicle
replacement.
8-17
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Aggressive marketing techniques are evident in the public image
each firm has established. Over the years, General Motors has maintained
the strategy of advertising a "car for every price and purpose," and with
i
its breadth of product line and range of options and accessories, it has
managed to capture approximately 60 percent of the full-sized and
intermediate-size car markets and to capture about 30 percent of the
compact and subcompact market.
Ford's marketing strategy has been built on the concept of "basic
transportation." Although Ford produces competitive models in all model
classes, its greatest successes have been realized in the small car
market. However, in recent years, Ford has elected to maintain a line of
full-size and luxury cars as competitive alternatives to General Motor's
downsizing of all its models. Ford's marketing strategy is apparently
aimed at capturing that portion of the consumer market that elects to ,
remain with a full-size car or that refuses to pay a full-size price for
an intermediate-size car. Recently, Ford's share of the full-size market
has ranged between 25 percent and 30 percent.
]
Chrysler's traditional marketing stance has been to build its image
on superior engineering. While its products cover all model classes, ,
Chrysler's historical appeal has been to the luxury and full-size car!
market. It has consistently priced its vehicles higher than those of! its
competitors, maintaining that they "are worth more, perform better, and
have better engineering." In recent years, Chrysler's share of the full-
size market has declined from 15 percent to about 10 percent, and last
year, for the first time, Chrysler has moved into the domestic production
of subcompacts with the introduction of the Omni and Horizon models. ;
8-18
-------
American Motors historical strategy has been to produce less
expensive economical, small cars. In the years in which the firm has
departed from this strategy, sales have declined radically. Currently,
American Motors has begun to concentrate its efforts in the compact and
subcompact areas and to increase advertising of its Jeep products, which
have consistently been successful.
Dealer-incentive programs include special sales campaigns that
provide cash bonuses to dealers who exceed their sales quotas, special
product promotions in which optional equipment is sold at reduced prices,
and merchandise or trip prizes to outstanding salesmen or sales managers.
Buyer-incentive programs include cash rebates on new vehicle purchases,
special pricing on optional equipment, expansion of warranty items, and
extensions of warranty periods.
8.1.2.9 Price-Cost Relationships
The price-cost margin, or profitability of sales, depends upon
factors such as vehicle mix and the ability of the firm to recover cost
increases. Because the industry is capital-intensive, fixed costs are
high. Therefore, even a small change in unit volume will cause revenues
to vary. As sales decline, the profit margin becomes narrower.
Characteristically, the industry does not respond with a decrease in price
in order to stimulate sales. To the extent that prices are held constant,
increases or decreases in quantity of the product demanded will widen or
narrow the profit margin.
In the 1972 to 1973 model year, sales in the industry peaked, and
the profit position of the industry was maximized as the difference
between costs and revenues widened. The subsequent decline in the market
in response to the energy crisis produced by the Arab oil embargo did not
8-19
-------
result in a price decrease to induce greater sales volume. The industry
practice of costing on a constant input basis, coupled with volume
production, causes the implementation of price changes to take as long as
2 years. Therefore, the sales decline in 1974 to 1975 did not occasion a
cutback, and the industry waited for the market to recover. As a result,
that year was characterized by a substantial narrowing of the profit
margin and reduced profitability.
It becomes apparent that the wider the profit margin of a
manufacturer, the more flexibility he has in dealing with fluctuations in
demand, changes in the costs of inputs, and in establishing prices.
Conversely, smaller profit margins provide the manufacturers with less
flexibility in these areas. Hence, profit margins become critical for
companies that hold smaller shares of the market, such as American Motors
i
and Chrysler Corporation. To the extent that prices must remain
competitive, and because of the cost-revenue relationship, profitability
for these companies becomes a matter of achieving a delicate balance. At
the point where costs and revenues converge, or when costs exceed
revenues, the long-run financial position of both companies will need to
be such that long-run target profits can be met or external funds can 'be
I
generated to finance capital expenditure demands of the company.
j
8.1.3 Projected Demand
Using current market shares and number of U.S. new car and light-
duty truck registrations as the basis, United States demand for new cars
and light-duty trucks was projected through 1983 for each individual firm.
For passenger cars, an annual industry growth of 3 percent was
accepted as the "most likely" value from a range of estimated rates !
encountered in the course of research for this project. The upper limits
8-20
-------
of the range were 3.5 percent to 4 percent and the lower limits were
oil
1.8 percent to 2 percent. * For trucks, an annual growth rate of
4 percent was accepted as the "most likely" value in a range of values
from 3 percent to 6 percent suggested by authorities from both the public
arid private sectors of the economy.
Historical demand in Canada for new cars and for new light-duty
trucks was examined in relation to historical demand in the United States.
On the basis of the observed relationship, Canadian demand through 1983 was
projected for the same time period as 10 percent of the United States
demand for new cars, and 11 percent of United States demand for light-duty
p
trucks. Existing shares of the Canadian market were assumed to remain
constant over the next 5 years for both cars and light-duty trucks.
United States demand and Canadian demand were combined to obtain
total North American projected demand for new passenger cars (see
Table 8-3) and for light-duty trucks (see Table 8-4).
8.1.4 Determination of Existing Capacity
In order to rationally determine the required new assembly lines
needed for this industry, the existing capacity as well as future vehicle
demand, was determined.
Estimates of existing production capacity for cars and for
light-duty trucks were derived for each of the firms in the industry and
are shown in Tables 8-5 and 8-6. For both cars and trucks, the basic
formula used to measure production capacity for each firm was: (optimal
line speed x number of final assembly lines) x (number of shifts x number
of working days per year).
Optimal line speed is considered to be the optimal rate at which an
automobile or truck assembly line can produce vehicles when the production
8-21
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TABLE 8-3 U.S. AND CANADIAN PROJECTED DEMAND FOR NORTH-AMERICAN-MADE
PASSENGER CARS3, 1979 to 1983
i j
(Thousands of Units) i
Manufacturer*3
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
American Motors
Totals
1979
5417
2653
1387
206
9663
1980
5580
2733
1428
212
9953
1981
5747
2815
1471
218
10251
1982
5919
2899
1515
225
10558
1983
6097
2986
1560
232
10875
aExports by U.S. manufacturers have not been included.
^Checker Motors, which produces for a specialized market, has a
projected demand of 5576 units in 1983. Volkswagen's new car assembly plant
in New Stanton, Pennsylvania, became operative in March 1978; sufficient sales
data to project demand for 1983 are not yet available.
8-22
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TABLE 8-4. PROJECTED U.S. AND CANADIAN DEMAND FOR NORTH-AMERICAN-MADE
LIGHT-DUTY TRUCKS, 1979 to 1983
(Thousands of Units)
Manufacturer
General Motors Corp.
Ford Motor Company
Chrysler Corporation
American Motors
Internat'l Harvester
Company9
Totals
1979
1378
1100
490
116
31
3115
1980
1422
1144
510
121
32
3240
1981
1491
1190
530
126
33
3370
1982
1550
1238
551
131
35
3505
1983
1612
1288
573
136
36
3645
Estimates are for U.S. demand only.
8-23
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TABLE 8-5. ESTIMATED PASSENGER CAR PRODUCTION CAPACITY
IN NORTH AMERICA, 1978
Manufacturer
No. of Final
Assembly Lines
in U.S. and Canada
Estimated Capacity
(Thousands of Units)
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
American Motors Co.
Checker Motors Corp.
Volkswagen of America, Inc.
29 a
16
2b
1
1
6,124
3,379
1,478
422
211
211
aA new passenger car assembly plant in Oklahoma, presently under
construction, is planned for 1980. Total capacity is estimated
to increase by 211,200 units, bringing the total to 6,336,000 units.
bAllowance has been made in this table for the 1978 conversion to
light-duty truck assembly of one line each for Chrysler and ,
American Motors, and capacity estimates have been reduced accordingly.
8-24
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TABLE 8-6. ESTIMATED LIGHT-DUTY TRUCK PRODUCTION CAPACITY
IN NORTH AMERICA, 1978
Manufacturer
No. of Final Assembly
Lines in U.S. and Canada
Estimated Capacity
(Thousands of
Units)
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
American Motors Co.
Internat'l Harverster Co.
11 a
9
1,605
1,313
729
437
145
aA new General Motors plant in Shrevesport, Louisiana has been planned
for 1981. Estimated capacity should increased by 145,000 units, bringing
the total to 1,750,000 units.
bChrysler will cease light-duty truck production in its Tecumseh Road
plant in 1979; this plant will be used for subassembly operations. The
Jefferson Avenue plant converted in 1978 to light-duty truck production.
It is assumed one change will offset the other.
cAmerican Motors will retool its Brampton, Ontario plant in 1978 for
light-duty truck production. The estimate presented here reflects this
change.
8-25
-------
rates of components and subassemblies are adjusted to be totally
compatible. In accordance with the findings described in earlier chapters of
this study, constant line speeds of 55 cars per hour and 38 trucks per Jiour
were entered into the capacity formula. It is recognized that not every line
in every company will operate at the accepted line speed; some will operate at
1
a higher rate and others at a lower rate. Endogenous constraints such as the
1
age of plants and equipment and the type and complexity of vehicle mix on a
line are present. Also present are exogenous constraints such as the seasonal
|
and cyclical nature of consumer demand. The accepted values represent best
estimates of average car and truck optimal line speeds for the industry.
Number of lines per company is proprietary information. Data used for
i
this component of the formula were estimated from public sources such as
i
Ward's Automotive Yearbook and Automotive News, and the results were compared
with other studies reporting similar information. Estimated number of;lines
per company reflects line usage for both automobile and light-duty truck
production. ':
Number of shifts was established as a constant value of 2. It is
understood that number of shifts may vary in response to consumer demand.
This value was entered into the formula as representative of the industry.
Number of "/orking days per year was established as a constant value of
240. This number is consistent with findings in earlier chapters of this
study and reflects downtime required for maintenance, inventory, retooling for
model changeover, vacation, and variations in labor skill.
I
8.1.5 Determination of New Sources
i
A company-by-company determination of new source requirements was
made. Using the projected demand for 1979 and 1983, and considering factors
as each company's market share, age and capacity of plants and publicized
8-26
-------
company plant changes or expansion, the following company line additions
were concluded. General Motors will require an additional passenger car
line by 1983 and one additional light-duty truck line by 1982; Ford will
need one additional light-duty truck line by 1980; and Chrysler will need
one additional passenger car line by 1980.
As demand at each firm exceeds present capacity, the firm may elect
to build a new line. Alternatively, a firm may increase capacity by
modifying or reconstructing an existing line. For example, Chrysler may
choose to continue its announced program of gutting and refitting existing
plants in order to increase production capacity to meet projected
20
demand. A second alternative for each firm would be to construct the
new line in Canada, where environmental standards are currently somewhat
less stringent.
The economic analysis in this study assumes that four new lines
will be built, that they will be built in the United States and will be
impacted by New Source Performance Standards.
8.2 COST ANALYSIS
8.2.1 Introduction
To determine the costs of controlling emissions of volatile organic
compounds (VOC) associated with the painting of automobiles and light-duty
trucks, alternative control systems were applied to selected typical plant
sizes. Estimated costs were then plotted on graphs to represent the control
option costs for varying plant capacities. The costs of the control options
represent those additional expenditures over the base case, in which
electrodeposition (EDP) is used for the prime coat, solvent-based coatings
are used in the guide-coat and topcoat operations, and VOC emissions are not
controlled. Figure 8-1 shows the available control options. The cost
8-27
-------
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estimates developed herein are study estimates with an expected range of
+30 percent. They are limited to new coating facilities and are keyed to
fourth quarter 1977 costs.
To represent the varying capacities of the assembly plants, three
line speeds were selected from a range of actual industry production rates
for automobiles and another three for light-duty trucks. For a given line
speed, no cost distinction is made between automobiles and light-duty
trucks. Any differences that may exist are too small to consider in a
study estimate.
Vehicle Type
Automobile
Light-duty truck
Line Speed, Vehicles/h
40
55
85
30
38
48
It is assumed that vehicle manufacturers using solvent-based
lacquers require three topcoat lines, those using solvent-based enamels
require two topcoat lines, and those using water-based paints require two
topcoat lines. For a given plant it is also assumed that all the topcoat
lines are identical in length.
Realizing vehicle size directly affects potential VOC emissions,
emission calculations are based on an average body size and paint
8-29
-------
thickness. Table 8-7 presents average solvent-borne paint usage for
surface (guide) and topcoats.
Uncontrolled VOC emissions during guidecoat and topcoat application
range from approximately 1.26 gigagrams/yr (1400 tons/yr) at an automobile
i
assembly plant using enamel coatings and producing 40 vehicles/h to more
i
than 6.35 gigagrams/yr (7000 tons/yr) at a plant using lacquer coatings
and producing 85 vehicles/h. Using values from Table 8-7, an example of
the enamel solvent calculations is as follows:
vehicles hours shift liters guide solvent + liters topcoat SQlvent content qm solvent ^ ^_
hour shift "day vehicle* content vehicle liter, year
40
(8)
(2.0
(0.69)
11.2
(0.75))
839.
(240)
= 1.26 x 10 qm/year
8.2.2 Capital Cost of Control Options
The five control options incorporate two basic technologies: a.
change in coating material (from solvent-based to water-based paint) and
incineration of the exhaust gases (by thermal or catalytic incineration).
!
8.2.2.1 Change to Waterborne Paint
Control option IA involves the use of water-based coatings. These
i
j
coatings generally require longer spray booths, flash tunnels, and ovens
than do solvent-based enamels, hence increased capital costs. The
. :. " ' i
Incremental increase of capital costs are less when water-based systems
are compared with solvent-based lacquers, because a third (shroud) coat of
i
lacquer is required for solvent spray systems. Table 8-8 lists the
i
coating equipment requirements for the various types of coatings in a
plant producing 55 vehicles/h.
The turnkey costs of booths, tunnels, and ovens are shown in
Table 8-9. Costs include such items as air hardling and conditioning,
lighting, sprinklers, spray equipment, conveyors, and water-treatment
8-30
-------
TABLE 8-7. AVERAGE SOLVENT-BASED PAINT USAGE FOR AUTOMOBILE
AND LIGHT-DUTY TRUCK BODIES
Vehicle
Automobile
Light-duty truck
Coating
Enamel guide-coat
Enamel topcoat
Lacquer guide-coat
Lacquer topcoat
Enamel guide- coat
Enamel topcoat
Lacquer guide- coat
Lacquer topcoat
Solvent Content,
Percent by
Vo 1 ume
69
75
69
87
69
72
69
87
Paint Usage per Vehicle
Paint Usage per Vehicle,
Liters Gallons
2.0 0.54
11.2 2.95
2.0 0.54
25.3 6.67
2.0 0.54
12.2 3.23
2.0 0.54
31.1 8.22
EE-250
8-31
-------
TABLE 8-8. COATING EQUIPMENT REQUIREMENTS IN A PLANT PRODUCING
55 VEHICLES/HOUR21
Coating and
Number of Lines
Equipment
Length Per
Line, m (ft)
Water-based guide
coat (1 line)
Solvent-based guide
coat (lacquer and enamel)
(1 line)
Water-based
topcoat (2 lines)
Solvent-based
enamel topcoat (2 lines)
Solvent-based
lacquer topcoat (3 lines)
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
85 (280)
85 (280)
315 (1036)
67 (220)
51 (168)
315 (1036)
94 (308)
85 (280)
128 (420)
30 (100)
9 (30)
76 (250)
68 (224)
51 (168)
128 (420)
8-32
-------
TABLE 8-9. TURNKEY COSTS OF AUTOMOBILE AND LIGHT-DUTY TRUCK
COATING EQUIPMENT LINES
(4th quarter 1977 dollars)
Equipment
Estimated Cost
Cost Used in
This Study
Water-based paint
spray booth
Solvent-based paint
spray booth
Flash-off tunnels
Ovens
36,000 - 39,000/m
(11,000 - 12,000/ft)*
39,000/m
(12,000/ft)b
32,800/m
(10,000/ft)a,b
32,800/m
(10,000/ft)a
6,600 - 7,800/m
(2,000 - 3,000/ft)b
1,200 - I,400/m3
(35 - 40/ft3)a
6,600 - 9,800/m
(2,000 - 3,000/ft)b
39,000/m
(12,000/ft)
32,800/m
(10,000/ft)
6,600/m
(2,000/ft)
9,800/m
(3,000/ft)
Reference 23
Reference 24
8-33
-------
equipment. In addition to the equipment costs, the land and building
costs must be considered. Each unit is 6.1 m (20 ft) wide, and for
purposes of estimating building costs, it is assumed that a 1.5 m (5 ft)
aisle is required on each side of the booths, tunnels, and ovens.
Ten percent was added for space between coating lines. A building cost of
OQ
$291.10/m2 ($26.20/ft ) was used to calculate costs. The real
estate is assumed to cost $24.80/m2 ($100,000/ac).
Table 8-10 presents the incremental capital costs of a water-based
system versus conventional solvent-based systems for application of
guide-coat and topcoat at plants of various line speeds. Calculation of
these capital costs increments was accomplished by determining the
additional line needed for water-based systems over solvent-based (unit
line cost — Table 8-9 -- x length — Table 8-10 — for water-based minus
/I I
that for solvent-based) plus the additional land and building costs
(additional line length needed times width (10.01 m) times land and
building unit costs (291.10 + 24.80) $/m2). These costs are comparable
?7 '
to values presented in the literature/7 The capital costs of similar
systems are assumed to be directly proportional to line speed because the
lengths of the spray booths, flash-off tunnels, and ovens are a function
of line speed. A line speed that produces 70 vehicles per hour travels
twice as fast as one which produces only 35 vehicles per hour. Thus, |the
ovens, for example, must be twice as long at the facility producing 70
vehicles per hour to achieve the same retention time.
8.2.2.2 Incineration
i
Control options IB and II require the use of thermal and catalytic
incinerators. Capital costs were determined for incineration options based
on a set of assumed operating parameters. These parameters include the
8-34
-------
TABLE 8-10. INCREMENTAL CAPITAL COST INCREASES OF WATER-BASED GUIDE COAT
AND TOPCOAT SYSTEM VERSUS CONVENTIONAL SOLVENT-BASED SYSTEMS
Type of Coating Solvent-Based Enamel Solvent-Based Lacquer
Vehicles per hour
Capital Cost, $106
30
5.65
38
7.15
40
7.53
48
9.05
55
10.2
85
16.0
30
0.39
38
0.50
40
0.52
48
0.63
55
0.72
85
1.11
EE-252
EXAMPLE CALCULATION FOR ADDED CAPITAL COSTS FOR 55 VEHICLES/HOUR
ENAMEL COATING LINE.
L(M)Ca ($/M)
67 (32,800)
51 (6,600)
116 (9,800)
434 +
L(M)Ca
2(30)
2(9)
Guide-Coat
s.b.
f.o.
ov.
Topcoat
s.b.
f.o.
ov.
L(M)Ca
85
85
316
.486
L(M)Ca
2(94)
2(85)
2(128)
614
($/M)
(39,000)
(6,600)
(9,800)
+
($/M)
39,000
6,600
9,800
2(76)
230
($/M)
32,800
6,600
9,800
8.8 x 106 $
Building/land 486 - 434 + 614 - 230
(6.1 + 3.0) 1.1 = 10.01 m width A
(291.1 + 24.8) 4362
aL(M)C is length of line in meters times
the number of coats (1 or 2).
= 436 m length
= 4362 n)2
1.4 x 106 $
10.2 x 10° $
8-35
-------
TABLE 8-11. TECHNICAL PARAMETERS USED IN DEVELOPING COSTS OF
INCINERATORS FOR CONTROL SYSTEM25
Parameter
Value*
1. Temperature, °C (°F)
Ovens and flash tunnels
Spray booths
2. Volumetric flowrate,
NitP/s (scfm) per vehicle/h
Guide coat spray booth
Guide coat ovens and flash tunnels
Topcoat ovens and flash tunnels, enamel
Topcoat ovens and flash tunnels,
enamel
Topcoat spray booth, lacquer
Topcoat ovens and flash tunnels,
lacquer
3. Hydrocarbon concentration, % LELa
Spray booths
Ovens and flash tunnels
4. Control efficiency, %
149
21
(300)
(70)
0.
0.
3.
0.
10.
0.
1,
10,
645 (1,370)
087 (184)
82 (8,100)
105 (222)
0 (21,200)
273 (580)
90.0
aLEL = lower explosive limit
following conditions and the values listed on Table 8-11. All exhaust
gases are incinerated at 430°C (800°F) in the catalytic incinerators
and 760°C (1400°F) in the thermal incinerators. Incinerators for oven
and flash tunnel exhausts are designed for 35 percent primary and
55 percent secondary heat recovery. Only 35 percent primary heat recovery
is considered for the spray booth exhausts.
The reactor units are shop-assembled packages complete with
i ' ;• ; j ' i !
burners, fan, controls, heat exchanger, and stack. Maximum unit size
23.5 Nm3/s (50,000 scfm). If exhaust volumes exceed this rate, multiple
8-36
is
-------
units are used. Utility requirements are assumed to consist of electrical
power to drive the fans and No. 2 fuel oil for the incinerator. Although
natural gas would be used for catalytic incinerators, capital costs are
uniformly developed for the more costly fuel of storage. Tanks with
capacity for a 15-day fuel supply and ancillary facilities, such as dikes
for above ground tanks, are included in the costs.
Direct capital cost items included in incinerator installation are
foundations, rigging, structural steel, ductwork, dampers, electrical
work, piping, temperature monitoring equipment, and painting. Indirect
costs of system startup, performance testing, engineering, and the
constructor's overhead and profit are also included. No allowance is made
for stack monitors. However, since VOC emissions are a function of the
temperature in the firing chamber, the cost of temperature monitoring
equipment is included.
Because costs are estimated on a turnkey basis, cost of
construction money is not specifically considered. Company philosophy and
accounting methods have an impact on this. For purposes of this study, it
is assumed that the cost of construction money is accounted for in the
25 percent allotted for the constructor's overhead and profit. The
parameters used in developing the costs for incineration systems are shown
in Table 8-11.
Table 8-12 presents delivered cost of incinerators from various
exhaust flowrates. To determine installed costs, accessory equipment and
installation charges were added to the delivered incinerator costs.
Installation costs of the incinerators were estimated. Installed costs
were then compared with the incinerator purchase prices. The ratio of
estimated installed cost to purchase price ranged from 2.1 to 2.8. This
8-37
-------
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CM
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£
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Incinerated Air 1
Type of Incinerator
.
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CM If)
CM CO
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IO f*.
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CM (•»
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compared favorably with previously reported ratios, which ranged from 1.2
28
to 3.7. The estimated costs of dampers, oil storage, electric
service, rigging, structural steel, foundations, ductwork, piping,
painting, startup, and testing are based on engineering judgment.
Installed costs include allowance of 25 percent for the constructor's
overhead and profit and 12 percent for engineering. Tables 8-13 through
8-20 show the capital cost of each of the control options that incorporate
exhaust gas incineration.
8.2.3 Annualized Cost of Control Options
The total annualized cost is divided into three categories: direct
operating cost, capital cost, capital charges, and (when applicable)
credit for heat recovery. Operating and maintenance costs fall into the
first category and include the following:
• Utilities (including electric power, fuel, and process water)
9 Operating labor
a Maintenance and supplies
• Solid waste disposal
Capital charges include depreciation, interest, administrative
overhead, property taxes, and insurance. Depreciation and interest are
computed by use of a capital recovery factor (CRF), the value of which
depends on the operating life of the building or equipment and the
interest rate. Table 8-21 lists the cost factors used in computing the
annualized costs.
8.2.3.1 Water-based Paints
Water-based coating systems reportedly require more operating and
27
maintenance labor than solvent-based coating systems. Estimates of
8-39
-------
TABLE 8-13. CAPITAL COSTS OF.CONTROL OPTION IB-T FOR SURFACE COATING
OF AUTOMOBILES (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
40
Unc. a
Unc.
3,220
320
3,540
55
Unc.
Unc.
4,280
350
4,630
85
Unc.
Unc.
6,610
395
7,000
Solvent-Based Lacquer
40
Unc.
Unc.
8,080
425
8,500
55
Unc.
Unc.
11,300
475
11,800
85
Unc.
Unc.
17,340
585
17,900
aUnc. — Uncontrolled
8-40
-------
TABLE 8-14. CAPITAL COSTS OF CONTROL OPTION IB-C FOR SURFACE COATING
OF AUTOMOBILES (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
40
Unc.a
Unc.
4,080
276
4,350
55
Unc.
Unc.
5,530
320
5,850
85
Unc.
Unc.
8,550
385
8,940
Solvent-Based Lacquer
40
Unc.
Unc.
10,400
440
10,800
55
Unc.
Unc.
14,500
529
15,000
85
Unc.
Unc.
22,300
724
23,000
aUnc. — Uncontrolled
8-41
-------
TABLE 8-15. CAPITAL COSTS OF CONTROL OPTION II-T FOR SURFACE COATING
OF AUTOMOBILES (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
40
745
170
3,220
320
4,460
55
835
180
4,280
350
5,640
85
1,260
190
6,610
395
8,460
Solvent-Based Lacquer
40
745
170
8,080
425
9,420
55
835
180
11,300
475
12,800
85
1,260
190
17,300
585
19,300
8-42
-------
TABLE 8-16. CAPITAL COSTS OF CONTROL OPTION II-C FOR SURFACE COATING
OF AUTOMOBILES (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
40
817
142
4,080
276
5,320
55
997
150
5,530
320
7,000
85
1,520
162
8,550
385
10,620
Solvent-Based Lacquer
40
817
142
10,400
440
11,800
55
997
150
14,500
529
16,200
85
1,520
162
22,300
724
24,700
8-43
-------
TABLE 8-17. CAPITAL COSTS OF CONTROL OPTION IB-T FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel Solvent-Based Lacquer
30
Unc.a
Unc.
2,620
292
2,910
38
Unc.
Unc.
3,610
320
3,930
48
Unc.
Unc.
4,080
345
4,420
30
Unc.
Unc.
7,420
413
7,830
38
Unc.
Unc.
8,740
485
9,220
48
Unc.
Unc.
12,100
562
12,700
aUnc. ~ Uncontrolled
8-44
-------
TABLE 8-18. CAPITAL COSTS OF CONTROL OPTION IB-C FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
30
Unc.a
Unc.
3,260
254
3,510
38
Unc.
Unc.
4,060
278
4,340
48
Unc.
Unc.
5,140
310
5,450
Solvent-Based Lacquer
30
Unc.
Unc.
9,680
420
10,100
38
Unc.
Unc.
12,200
485
12,700
48
Unc.
Unc.
15,500
628
16,100
aUnc. ~ Uncontrolled
8-45
-------
:!'•» 'ili'l" , lllli!!!i fill "•
TABLE 8-19. CAPITAL COSTS OF CONTROL OPTION II-T FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
30
437
172
2,620
292
3,520
38
730
172
3,610
320
4,830
48
786
172
4,080
345
5,380
Solvent-Based Lacquer
30
437
172
7,420
413
8,440
38
730
172
8,740
485
10,100
48
786
172
12,100
562
13,600
8-46
-------
TABLE 8-20. CAPITAL COSTS OF CONTROL OPTION II-C FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS (1000 DOLLARS)
Type of Coating
Vehicles Per Hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels
and ovens
Topcoat spray booths
Topcoat flash tunnels
and ovens
Total capital costs
(rounded)
Solvent-Based Enamel
30
537
145
3,260
254
4,200
38
790
145
4,060
278
5,270
48
907
145
5,140
310
6,500
Solvent-Based Lacquer
30
537
145
9,680
420
10,800
38
790
145
12,200
485
13,600
48
907
145
15,500
620
17,200
8-47
-------
TABLE 8-21. COST FACTORS USED IN COMPUTING ANNUALIZED COSTS FOR
CONTROL OPTIONS (1977 VALUES)
Operating factor
Maintenance labor rate
Operating labor rate
Supervisory labor rate
Utilities
Electric power
Fuel oil
Capital recovery factora
Air pollution control equipment
(10 year life)
Production equipment
(15 year life)
Buildings
(20 year life)
Taxes and insurance
Administrative overhead
Catalyst allowance
16 h/day
240 days/yr or
3840 h/yr
$12.07/h
$10.97/h
$12.07/h
$0.0242/kWh
$0.107/liter ($0.396/gal
16.28% of capital cost
control equipment
13.14% of capital cost
production equipment
11.02% of capital cost
buildings
2% of capital cost
2% of capital cost
$2120/yr per Nm3/s
($1.00/yr per scfm)
a!0 percent interest
8-48
-------
additional labor needed for water-based guide and topcoats (in manhours
per hour of line operation) are as follows:
Lacquer
Enamel
Operating labor
Maintenance labor
Supervision
10
7
1
20
7
2
The cost of maintenance materials and supplies is assumed to be equal to
the cost of maintenance labor.
Water-based painting facilities require considerably more energy
than solvent-based coating facilities (see Table 7-9). Most of this
additional energy is used to evaporate the water and condition the
incoming air to the spray booths.
The cost of controlling water pollution associated with water-based
coating facilities is estimated to be only slightly more than solvent-
based coating facilities. Both systems use water cleanup for overspray.
Water-based paints are believed to cost more than conventional coatings,
but they also have a higher solids content. Although a comparison of
paint prices was not available from the paint manufacturers or the
automobile industry, the above would seem to indicate that the net applied
paint cost is comparable for enamel and lacquer coatings and water-based
coatings. General Motors uses water-based paint at two of its three
California plants. Their response to an inquiry by the California Air
Resources Board did not mention any net cost difference between water-
27
based and solvent-based coatings.
Figures 8-2 and 8-3 show annualized cost differentials between
water-based coating operations and solvent-based operations at various
8-49
-------
8
a
— 3
t
•8 2
JL
JL
JL
JL
JL
30 40 50 60 70
Line speed, vehicles/h
80
90
Figure 8-2.
Cost differential -- control option IA for guide-coat and
topcoat, water-based enamel vs. solvent-based enamel.
5
10 ^
o-
j=
£ 3
I 2
c
o
s 1
J=
Capital charges
30 40 50 60 70
Line speed, vehicles/h
80
90
Fiqure 8-3. Cost differential - control option IA for guide-coat and
topcoat, water-based enamel vs. solvent-based lacquer.
8-50
-------
line speeds.- These annualized cost differentials were calculated as
follows:
1. Additional production equipment costs were calculated (unit
line cost — Table 8-9 — times length — Table 8-10 ~ for
water-based minus solvent-based coating equipment)
2. Additional building costs were calculated (additional line
length needed times width (10.01 m) times building unit costs
(291.10 $/m2)
3. Both additional production equipment costs and additional
building costs were'then multiplied by their respective capital
recovery factor, taxes, insurance, and administrative overhead
factors (Table 8-21)
4. Additional labor costs were calculated (additional labor —
page 8-49 -- times labor rates — Table 8-21). Additional
maintenance material costs were assumed to be equivalent to the
additional labor costs (page 8-49).
5. Additional utility costs were calculated (utility rates --
Table 8-21 -- times additional demand — Table 7-9)
All of the above values were summed, yielding the total annualized cost
differential as shown in Figures 8-2 and 8-3.
Tables 8-22 and 8-23 present annualized costs and cost-
effectiveness of this control option for automobiles and light-duty
trucks. Control efficiency percentages were determined from solvent
emissions measured from water-based and organic solvent-based systems
using a typical coating with air spray transfer efficiencies of 40 percent;
application rates are given in Table 8-7. The computation of annualized costs
is similar to that described above for Figures 8-2 and 8-3.
8-51
-------
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The two differences are: (1) cost differentials are replaced by control
option costs, and (2) capitol costs now involve air pollution control
equipment — not production equipment and building costs.
8.2.3.2 Incineration
Cost factors used to compute the annualized costs of controlling
VOC emissions from the guide-coat and topcoat operations are shown in
Table 8-21. Operating labor for each incinerator, regardless of size,
includes 1.0 manhour for each startup and shutdown and 0.25 manhour per
shift for monitoring. Each incineration unit must be tuned up and the
heat exchangers must be cleaned twice yearly, as regular maintenance which
• "i • • i , r
together with miscellaneous maintenance, requires an estimated 64 manhours
per year per incinerator. Operating and maintenance labor is calculated
as being independent of incinerator size.
It is estimated that the catalyst in catalytic incinerators must'be
~ • '
replaced yearly at a cost of $2120/Nnrr per second ($1.00/scfm).
Because total exhaust rates differ between solvent-based lacquer
i
and solvent-based enamel operations, the annualized costs also vary;
control of emissions from solvent-based lacquer is more costly. ;
Heat recovered by the primary heat recovery systems with the
incinerators on sp^ay booths is used to preheat the spray booth exhausts.
The resultant saving is not considered a credit from a cost standpoint;
rather it is accounted for in the decreased fuel rate. On the other hand,
I
the heat obtained from secondary heat recovery can be considered credit
because it is used for production facilities, mainly oven heating. All
the incinerators used on oven exhausts have primary and secondary heat
recovery. The heat recovered in the secondary heat exchanger is credited
at the rate of $2.68 gigajoules ($2.83/106 Btu).
8-54 ;
-------
Tables 8-24 through 8-31 present the annualized costs of the four
incinerator control options for automobiles and light-duty trucks. Annual
costs are determined for control option IB and II using the factors in
Tables 8-13 through 8-21. Calculations are the same as for option IA
except air pollution control equipment is the additional capital expense
rather than production lines.
8.2.4 Cost-Effectiveness of the Control Options
In this section a comparison of the annualized costs of the various
alternative control options to the quantities of VOC removed by them, or a
cost-effectiveness analysis, is made on each of the control options and
each of the model coating facilities.
The purpose of this comparison is to determine (1) which is the
most practical control option, (2) whether the options differ in
cost-effectiveness, and (3) whether the expenditure of additional monies can
be justified by the amount of pollutant controlled.
Tables 8-22 and 8-23 list these cost-effectiveness quotients for
control option IA. It is clear from these tables that the quotients are
virtually identical for automobiles and light-duty trucks when compared
with the base case of solvent-based enamels, but there is a spread of
approximately 20 percent between the two when compared with the base case
of solvent-based lacquers. This spread results from the higher lacquer
requirements for truck bodies; when lacquer is used, a light-duty truck
requires about 23 percent more topcoating than an automobile, but when
enamel is used, the difference is only about 5 percent.
There is a large difference in the cost-effectiveness of water-
based coatings compared with enamels and water-based coatings compared
with lacquers because water-based coatings need less spray booth, flash-
8-55
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8-62
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8-63
-------
off tunnel, and oven facilities than do solvent-based lacquer coatings,
whereas they need more of these facilities than do solvent-based enamels.
The VOC emitted by coating operations using solvent-based lacquers
are more than twice those emitted by operations using solvent-based
enamels. This results partly from the higher solvent content of lacquers
and partly from the additional paint required for each vehicle. On the
other hand, lacquers require greater volumes of dilution air. Although
emissions generated from lacquers cost more to control than those from
enamels, more VOC is removed and the cost-effectiveness remains about 'the
same for a given control option using incinerators.
1 ,
Figures 8-4 and 8-5 compare the cost-effectiveness of each of the
control options. Control option IA, the use of water-based paint, is the
most cost-effective option in all cases.
As the cost-effectiveness lines indicate, no economy-of-scale
occurs 1n controlling the larger facilities because these facilities
require proportionately higher exhaust gas rates and the maximum-sized
incinerator is 23.5 Nm3/s (50,000 scfm), thus necessitating more
incinerators. Thus, gas incineration costs are proportional to plant
capacity. Neither does control option IA (a switch to water-based paint)
exhibit an economy-of-scale for basically the same reason; more pieces of
the same size equipment are required in larger facilities. Finally, for
all control options, the operating costs are larger than the capital
charges. The nature of these costs is such that they are directly ;
proportional to production rate, which also militates against economics-
of-scale. " •'•- r ;
S-.64
-------
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10,000
5000
4000
3000
2000
1000
500
400
300
200
100
1
l
i
30 40 50 60 70 80
Line speed, vehicles/h
90
Control option IA -
Control option IA -
Control option IA -
- automobiles and trucks (enamel)
- automobiles (lacquer)
- trucks (lacquer)
Figure 8-4. Cost-effectiveness of water-based control options.
8-65
-------
•'•'I ' , ''HI • ' ' ,,'11'i!:11!1:1'1 Ir I
t/1 (/)
c $2
o
-------
The cost-effectiveness of each of the control options may be
summarized as follows:
Option Cost-Effectiveness, $/Mg.VOC controlled
IA 330-410 (lacquer-base case)
2500-3300 (enamel-base case)
'--• IB-T 4200
IB-C 3100
II-T 4200
II-C 3100
8.2.5 Control Cost Comparison
It is difficult to compare the estimated cost of water-based
coating operations with costs reported at actual installations. For
example, cost data presented to the California Air Resources Board by two
27
of the major automobile manufacturers cannot be compared directly with
the estimated costs of water-based operations presented in this report
because the figures are aggregated, they include many items not included
in control option IA, and they are based on a "tear-out/redo" premise.
After their detailed review, the values were considered to be on the high
side by the staff of the Air Resources Board. The turnkey costs of spray
booths, flash-off tunnels, and ovens for water-based paint were provided
by vendors, however, and the quoted prices are substantially lower than
the industry retrofit estimate given to the California Air Resources
Board. Because no direct cost data for new line installations could be
extracted from the California report or from other industry sources, the
vendor's turnkey prices were used.
Much of the increase in annualized coating costs is due to
increased energy consumption when using water-based paints. In this case
some comparison can be made with the data that GM supplied to the
California Air Resources Board. The actual recorded incremental increase
8-67
-------
at the Van Nuys plant (which has a production rate of 60 vehicles/h) was
89.4 TJ/yr (84.8 x 109 Btu/yr). The study estimate for control option
IA at a plant producing 55 vehicles/h includes an incremental increase of
76.5 TJ/yr (72.4 x 109 Btu/yr) for additional fuel oil and 44.6 TJ/yr
(42.3 x 109 Btu/yr) for additional electricity.
Incinerator costs used in this study are based on a 1976 report .
and updated to fourth quarter 1977 prices.. These prices compare
reasonably well with older installations as reported in a 1972
report.28 The prices shown in the 1972 report were also updated to
fourth quarter 1977. Figures 8-6, 8-7 and 8-8 compare costs used in this
study with costs in other studies. '
8.2.6 Base Cost of the Facility
For purposes of comparison, a base cost of solvent-based painting
facilities has been developed under this study. This base cost includes
the complete cost of an electrodeposition (EDP) prime coating facility, a
guide-coat facility, a topcoat facility, and touch-up facilities. The
cost of related support facilities such as employee parking, material
storage, and a cafeteria is also included.
Because this is a study estimate, costs are not detailed. It is
assumed that the costs of painting facilities for automobiles and
light-duty trucks are basically the same for both. For study purposes, it
is assumed that base costs are proportional to line speed. The base cost
of a paint shop that uses lacquer is higher than the cost of one that uses
enamel. Total costs were estimated for a facility that handles 55
vehicles per hour.
Building space was estimated at 17,500 m2 (188,000 ft2) for
lacquer facilities and 11,800 m2 (127,000 ft2) for enamel facilities.
8-68
-------
400
CO
o
X
CO
CO
o
T3
cn
s-
O)
(O
300
200
O Costs used in this study
£> Costs from Reference 8
Costs from Reference 9
10 15
Capacity, Nm3/s
20
10
20 30
Capacity, 1000 scfm
40
50
Figure 8-6.
Comparison of purchase price values: catalytic
incinerators with primary heat recovery.
8-69
-------
400
o
X
CO
O
•o
300
1 «—r~
O Costs used in this study
A Costs from Reference 8
T
3
200
ro
=1
cr
10
Capacity, Nm /s
L—
20 30
Capacity, 1000 scfm
40
50
Figure 8-7.
Comparison of purchase price values: thermal
incinerators with primary heat recovery.
8-70
-------
400
ro
o
300
I/)
to
cr>
s-
01
cr
O Costs used in this study
A Costs from Reference 8
D Costs from Reference 9
10
10 ,15
.Capacity, NnrVs
J 1
20 30
Capacity, 1000 scfm
*
1
.*
0
20
40
50
Figure 8-8.
Comparison of purchase price values: thermal
incinerators with primary and secondary heat
recovery.
8-71
-------
These figures include 3250 m2 (35,000 ft2) for EDP in both
'
instances. In addition, 835 m2 (9,000 ft2) of building space for
I
employee services (e.g., cafeteria and dispensary) and employee parking
facilities for 300 vehicles is included in the base cost estimate. This
figure is based on 500 employees working two shifts. The following unit
costs were used for real estate:
Buildings -- $29l.lO/m2 ($26.20/ft2)
Land — $24.80/m2 ($100,000/acre)
. i : j • . , ,.
Unit costs used for the spray booths, flash-off tunnels, and ovens are
shown in Table 8-9 and the aggregate line lengths are shown in Table 8-32.
Electrodeposition facilities include rinse tunnels, an oven, and an
EDP tank with ancillary equipment such as conveyors, electrical equipment,
ventilation, and hooding. An industry representative reported that recent
costs of retrofitted EDP facilities ranged from $11.4 to $14.8 million,
and an average facility cost $12.6 million. One vendor's turnkey
estimate for a facility handling 55 vehicles per hour ranged from $6.5 to
$9.5 million. The following is a breakdown of this estimate:
EDP tank $2.0 to $3.5 million
Rinse tunnels $1.5 to $2.0 million
Oven
"ft
$3.0 to $4.0 million-
r
The high side of this range ($9.5 million) cpmp.am'with the retrofitted
average of $12.6 million and was used in preparing this estimate.
Tables 8-33 and 8-34 present total base cost for various line speeds.
8-72
-------
TABLE 8-32.
AGGREGATE LENGTHS OF SPRAY BOOTHS, FLASH-OFF TUNNELS, AND
OVENS FOR PAINT SHOPS HANDLING 55 VEHICLES PER HOUR3
(m (ft))
Facility
Spray booths
Flash-off tunnels
Ovens
Type of Solvent-Based Paints
Lacquer
292 (956)
235 (772)b
735 (2408)
Enamel
147 (484)
100 (238)b
502 (1648)
aBased on three topcoat lines for lacquer coatings
and two topcoat lines for enamel coatings.
"Includes 7.3 m (24 ft) of cooling area.
8-73
-------
TABLE 8-33. BASE COST OF AN AUTOMOBILE AND LIGHT-DUTY TRUCK PAINT
SHOP THAT USES SOLVENT-BASED ENAMEL
Line Speed, Vehicles/h
Guide, top, and touch-
up coating faci1itiesa
EDP facility3
Ancillary facilities3
Totals
Installed Costs, $10^
30
7.2
5.7
0.3
13.2
38
9.1
7.3
0.4
15.8
40
9.6
7.6
0.4
17.6
48
11.5
9.2
0.5
21.2
55
13.2
10.5
0.6
24.3
85
20.4
16.2
0.9
37.5
3Includes cost of land and building
TABLE 8-34. BASE COST OF AN AUTOMOBILE AND LIGHT-DUTY TRUCK PAINT
SHOP THAT USES SOLVENT-BASED LACQUER
Line Speed, Vehicles/h
Guide, top, and touch-
up coating facilities3
EDP facility3
Ancillary facilities3
Totals
Installed Costs, $10^
30
12.5
5.7
0.3
18.5
38
15.8
7.3
0.4
23.5
40
16.6
7.6
0.4
24.6
48
19.9
9.2
0.5
30.6
55
22.8
10.5
0.6
33.9
85
35.1
16.2
0.9
52.2
3Includes cost of land and building
8-74
-------
8.3 OTHER COST CONSIDERATIONS
In addition to NSPS, the automotive industry will be impacted by
r
other mobile source emission control, safety, fuel economy, and noise-
control regulations. However, the imposition of these other regulations
probably will not affect the results of the analysis contained in
Section 8.4 since they will impact vehicle unit size and construction
rather than numbers.
A comprehensive study to evaluate the combined economic impact of
all government regulations on the automotive industry is presently being
conducted by A. T. Kearney, Inc. Results are not available at this time.
8.4 POTENTIAL ECONOMIC IMPACT
The impact of the standards of performance based on all options
proposed are computed in this section as the annualized cost per unit of
production for each company effected. The projected economic impact of
each considered alternative control option on the required grass roots new
lines is small, and the cost of compliance with Standards of Performance
for New Source should not, by itself, preclude the construction of any of
these lines.
8.4.1 Grass Roots New Lines
As determined in Section 4.1.5 projected new source requirements
are to include: one car and one truck line for General Motors, one truck
line for Ford, one car line for Chrysler, and no new lines for American
Motors, Checker, and International Harvester.
8.4.2 Control Costs
The absolute and relative magnitude of the estimated alternative
control costs for grass roots new lines, by firm, are shown in Tables 8-35
through 8-38. In all cases, the estimated incremental control costs are
8-75
-------
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8-79
-------
less that a quarter of one percent of the list price for each
manufacturer's lowest-priced automobile or light-duty truck. The capital
investment costs of the alternative control options are also exceedingly
|
small in relation to the planned annual capital expenditures of each firm.
For the incremental cost calculations, annualized costs for each
company's line were spread over the year's production volume. This was
I
judged consistent with the industry's pricing policy. The April 1978
published list price, as reported in Automotive News, was deemed
acceptable as a base price for comparison purposes. It was assumed that
the additional price of optional equipment would offset any price discount
by the dealer.
For General Motors, the annualized costs of a new line are, at
most, $3.70 "per passenger car and $9.02 per light-duty truck.* These
annualized costs are, respectively, 0.1 percent of General Motors
suggested list price for its lowest-priced passenger car and 0.2 percent
i
of the suggested list price for its lowest-priced, light-duty truck. The
capital investment required for controlling both lines, assuming that the
highest annualized cost option was adopted by General Motors, is slightly
i
less than 1 percent of the firm's planned annual capital expenditures for
1982. I
- <
For Ford, the annualized cost per truck is $4.55 at most. This is
0.1 percent of the suggested list price for Ford's lowest-priced, ligHt-
duty truck. The corresponding capital investment requirement, if Ford
*The methodology used to derive each manufacturer's annualized costs on a
per unit basis! in keeping with traditional industry pricing pract1Ces,
assumes that the incremental costs attributable to the New Source
Performance Standard will be distributed by the manufacturer over all
units sold rather than over the production volume of the new line.
8-80
-------
selected this control option and line speed, is less than 0.3 percent of
Ford's planned annual capital expenditures for 1980.
For Chrysler, annualized costs per passenger car would be, at most,
$6.67, which amounts to 0.2 percent of Chrylser's suggested list price for
its lowest-priced car. Should Chrysler choose this option, 1.1 percent of
its planned capital expenditures for 1980 would be needed for this purpose.
If cost figures were distributed only for the vehicles coated on
the new lines, annualized costs per vehicle would increase from a least
cost base of $0.18/car to $7.43/car for General Motors auto line to a
highest cost base of $9.02/truck to $89.06/truck for their light-duty
truck line.
As is evident in Tables 8-35 through 8-38, control costs for each
manufacturer tend to become higher as line speeds increase. This is due
to the increased number of vehicles that are affected and are, therefore,
a greater percent of the manufacturer's output.
8.4.3 Potential Price Effect
«*
Several factors must be considered in analyzing potential price
increases attributable to Performance Standards for New Source. For one
thing, not every manufacturer will incur NSPS-related cost increases in
the same year by reason of new assembly line construction. Both Chrysler
and Ford will probably incur such costs earlier than General Motors. On
the other hand, all firms in the industry, including those not impacted by
1983, will eventually effect NSPS-related cost increases.
Another point to be considered is that it will probably not be
possible to determine which portion of the firm's price increase in any
given year is reflecting NSPS-related costs since, as a rule, current
prices to not reflect current cost in the automotive industry.
8-81
-------
Annual price increases for new cars have averaged approximately
!
5 percent over the past 5 years and 4.38 percent over the past 10 years.
The magnitude of volatile organic compound emission control cost increases,
is, at most, a 0.1 percent per car and 0.2 percent per light-duty truck for
General Motors. For Ford, the cost increase is 0.1 percent per light-duty
truck and for Chrysler, 0.2 percent per car. Since these price changes are
based on the lowest-priced vehicle for each manufacturer, the percentage,
change should become almost infinitesimal when compared with the range of
vehicle prices for each manufacturer. It is apparent that the relative
magnitude of these projected NSPS-related cost increases to historical
average price increases is small. Independently, they should not cause
significant cost-price increases for cars or light-duty trucks through 1983.
The ability of Ford and Chrysler to adjust their revenue functions
so as to effect an NSPS-related price change will depend upon the pricing
behavior of General Motors, the industry price leader. Ford and Chrysler
can adjust their revenue functions only within the constraints imposed by
the degree, timing and nature of price changes announced by General Motors.
1" • i
A consideration of Ford's desired price increase relative to that of
General Motors suggests that there should be no adverse effects on Ford's
profitability function regardless of ths size, timing, or nature of
the change. The effect of Chrysler's revenue function is less predictable.
Critical to Chrysler's ability to adjust its revenue function is the nature
and magnitude of General Motors desired price change. If future price
changes by General Motors are not of the nature and magnitude to allow
Chrysler to pass along the entire NSPS increase, then Chrysler's
profitability function will probably by somewhat adversely affected.
8-82
-------
Recently, General Motors announced a new price increase strategy
that would permit small price increases to take place over a model year,
as frequently as the firm deems necessary. By eliminating the traditional
annual increase in favor of the new system, manufacturers would appear to
be recovering cost increases more quickly. While General Motors pricing
strategy imposes constraints on the ability of other members of the
industry to recover costs, the new pricing strategy may provide some
relief in cost recovery. It is also possible that the system will
"flatten out" a, degree of the cyclical nature of sales. In effect,
consumer purchasing patterns may become more consistent throughout the
year and less negatively influenced by one large annual increase. To the
extent that sales volume increases consistently over the year, cost
recovery may take place rapidly enough to permit lower total annual
increases while maintaining target rates of return.
8.4.4 Sensitivity Analysis
The economic impact that has been projected in this chapter assumes
that market shares of each company will remain constant through 1983. To
give recognition to the possibility that these shares could shift, a
sensitivity analysis, based on the assumption that each company had
regained the highest market share it had held in the past 5 years, was
conducted. This scenario calculation indicated that, were these market
shares possible: General Motors would need one truck line; Ford would
need one car line and one additional truck line; Chrysler would need two
additional car lines and a truck line; and American Motors would need a
car line.
It should be noted in this context that it is obviously impossible
for all companies to achieve their top market shares simultaneously. In
8-83
-------
any case, the annualized costs involved would still be minimal with
0.7 percent increase for cars and 0.2 percent increase for trucks being
the largest single unit price increase.
The sensitivity test did not indicate any restructuring of relative
positions within the industry. There were indications, however, that if
market shares for Chrysler and/or American Motors increased appreciably in
the passenger car market, there could be a resultant adverse effect on
their profit margins, since these firms would be producing more units with
associated NSPS cost increases and would still be in the position of being
constrained in passing along those costs by whatever pricing action was
being taken by General Motors. However, the probability .that either firm
will be able to'recapture a substantially higher market share is remote.
8.5 POTENTIAL SOCIOECONOMIC AND INFLATIONARY IMPACTS 'j
Since the major potential impact of these regulations, that of
, „ ,,,,:,':,,"'• I-
preventing plant expansion of .new coating lines, is not considered
probable, the impact will be determined by company response to reduced
production margins. Output and employment effects should be minimal.
Secondary response of added demand on energy prices will be upward but of
an insignificant amount.
As a longer term inflationary seed, the maximum cost increase due
to these regulations should be less than 1 percent of the anticipated unit
price. This determination was developed by computing the total investment
costs to achieve compliance by 1983. Table 8-39 shows the projected
amount of fifth year annualized costs including depreciation and
interest. The estimated $57 mi Hi on'dollars is less than $4.90 per
vehicle industry wide or $79 per new line vehicle. Increased costs of
this magnitude are not considered as a significant inflationary force.
8-84
-------
TABLE 8-39. INFLATIONARY IMPACT ASSESSMENT 1983a
(4th Quarter 1977 $)
Manufacturer
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
Total
No. of
Lines
2
1
1
4
Fifth-Year
Annual i zed Costs
(1000's)
$40,300
$ 6,070
$10,100
$56,470
Investment
Costs
(1000's)
$32,900
$ 5,380
$ 8,460
$46,740
No. of Vehicles
Impacted
(1000's)
8,366
1,521
1,657
11,544
aBased on Regulatory Option II (thermal)
8-85
-------
REFERENCES
1. Impact of Environmental, Energy, and Safety Regulations and of
Emerging Market Factors Upon the United States Sector of the North
American Automotive Industry. Office of Business Research and
Analysis, Bureau of Domestic Commerce, Domestic and International
Business Administration, U.S. Department of Commerce. Washington,
D.C. August 1977. p. 3-1.
2 Review of the North American Automotive Industry. Automotive Task
Force, Department of Industry, Trade and Commerce. Ottawa, Canada.
April 1977. p. 72.
1 i
3 Review of the,North American Automotive Industry. Automotive Task
' Force, Department of Industry, Trade and Commence. Ottawa, Canada.
April 1977. p. 26.
4. Automotive News: 1978 Market Data Book Issue, pp. 37, 42-43.
5. Ward's Automotive Yearbook. 1978. p. 16.
6 Review of the North American Automotive Industry. Automotive Task
* Force, Department of Industry, Trade and Commerce. Ottawa, Canada.
April 1977. p. 199.
7. Impact of Trade Policies on the U.S. Automobile Market. Charles
River Associates. October 1976. pp. 33-34.
1 : • i
8. U.S. Industrial Outlook 1978. Department of Commerce, p. 159
i
9 Lanzillotti, R. F. The Automobile Industry. The Structure of .
American Industry, 4th Edition. Walter Adams (ed.). New York, The
Macmillan Company. 1971. pp. 276-277.
10. Impact of Environmental, Energy, and Safety Regulations and of.
Emerging Market Factors Upon the United States Sector of the North
American Automotive Industry. Office of Business Research and
Analysis, Bureau of Domestic Commerce, Domestic and International
Business Administration, U.S. Department of Commerce. Washington,
D.C. August 1977. p. 8-3.
11. Data and Analysis for 1981-1984 Passenger Automobile Fuel Economy
Standards: Document 1 Automobile Demand and Marketing. Office of
Automotive Fuel Economy, U.S. Department of Transportation. February
28, 1977. p. A-l.
12 Marketing and Mobility: Report of a Panel of the Interagency Task
ForcfoS Motor Vehicle Goals Beyond 1980. The Panel on Marketing and
Mobility, Office of the Secretary of Transportation. Washington,
D.C. March 1976. p. 2-196.
8-86
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13. Marketing and Mobility: Report of a Panel of the Interagency Task
Force on Motor Vehicle Goals Beyond 1980. The Panel on Marketing and
Mobility, Office of the Secretary of Transportation. Washington,
D.C. March 1976. p. 2-196.
14. U.S. Industrial Outlook 1978. Department of Commerce, p. 157.
15. Kenyon, P. Pricing in Post-Keynesian Economics. Challenge.
July-August 1978. p. 45.
16. Data and Analysis for 1981-1984 Passenger Automobile Fuel Economy
Standards: Document 1 Automobile Demand and Marketing. Office of
Automotive Fuel Economy, U.S. Department of Transportation, p. 3-71
to 3-75.
17. Data and Analysis for 1981-1984 Passenger Automobile Fuel Economy
Standards: Document 1 Automobile Demand and Marketing. Office of
Automotive Fuel Economy, U.S. Department of Transportation, p. 3-75
to 2-79.
18. Lanzilloti, R. F. The Automobile Industry. The Structure of
American Industry, 4th Edition. Walter Adams (ed.). New York, The
Macmillan Company. 1971. p. 282. .
19. The Wall Street Journal. June 27, 1977. p. 1.
20. Chrysler's Downhill Plunge in Market Shares. Fortune.
June 19, 1978. p. 58.
21. Memorandum from W. Johnson of U.S. EPA, Chemical Application Section,
to W. Vatavuk of U.S. EPA Economic Analysis Branch. April 12, 1978.
22. Building Construction Cost Data, 1978. Robert Snow Means Company,
Inc. Duxbury, Massachusetts, p. 267.
23. Personal communication between A. Knox of PEDCo Environmental, Inc.,
and F. Steinhable of Binks Manufacturing Company. June 21, 1978.
24. Personal communication between D. Henz of PEDCo Environmental, Inc.,
and J. Dwyer of George Kock and Sons. May 25, 1978.
25. Second1 Interim Report on Air Pollution Control Engineering and Cost
Study of the Transportation Surface Coating Industry. Enfield,
Connecticut. Springborn Laboratories, Inc. EPA Contract
No. 68-02-2062. May 6, 1977.
26. Report of Fuel Requirements, Capital Cost and Operating Expense for
Catalytic and Thermal Afterburners. Combustion Engineering Air
Preheater, Industrial Gas Cleaning Institute. Stamford,
Connecticut. EPA-450/3-76-031. September 1976.
8-87
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27. Proposed Model Rule for the Control of Volatile Organic Compounds
from Automobile Assembly-line Coating Operations. Presented to the
California Air Resources Board on January 26, 1978, as Agenda
Item 78-2-2.
I
28. Rolke, R.W., et al. Afterburner Systems Study. Emeryville,
California. Shell Development Company. NTIS Publication
No. PB-212-560. August 1972. !
29. Capital and Operating Costs of Selected Air Pollution Control
Systems. Niles, Illinois. SARD, Inc. EPA Publication
No. EPA-450/3-76-014. p. 4-18 to 4-19. September 1976.
8-88
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9. RATIONALE
9.1 SELECTION OF SOURCE AND POLLUTANTS
Volatile organic compounds (VOC) are organic compounds which participate
in atmospheric photochemical reactions or are measured by Reference Methods 24
(Candidate 1 or Candidate 2) and 25. There has been some confusion in the
past with the use of the term "hydrocarbons." In addition to being used in
the most literal sense, the term "hydrocarbons" has been used to refer col-
lectively to all organic chemicals. Some organics which are photochemical
oxidant precursors are not hydrocarbons (in the strictest definition) and
are not always used as solvents. For purposes of this discussion, organic
compounds include all compounds of carbon except carbonates, metallic car-
bides, carbon monoxide, carbon dioxide and carbonic acid.
Ozone and other photochemical oxidants result in a variety of adverse
impacts on health and welfare, including impaired respiratory function, eye
irritation, deterioration of materials such as rubber, and necrosis of plant
tissue. Further information on these effects can be found in the April 1978
EPA document "Air Quality Criteria for Ozone and Other Photochemical Oxidants,"
EPA-600/8-78-004. This document can be obtained from the EPA library (see
ADDRESSES Section).
Industrial coating operations are a major source of air pollution
emissions of VOC. Most coatings contain organic solvents which evaporate
upon drying of the coating, resulting in the emission of VOC. Among the
largest individual operations producing VOC emissions in the industrial
coating category are automobile and light-duty truck surface coating opera-
tions. Since the surface coating operations for automobiles and light-duty
-------
trucks are very similar in nature, with line speed being the primary
: : •[
difference, they are being considered together in this study. Automobile
and light-duty truck manufacturers employ a variety of surface coatings,
most often enamels and lacquers, to produce the protective and decorative
finishes of their product. These coatings normally use an organic solvent
base, which is released upon drying.
The "Priority List for New Source Performance Standards under the1Clean
Air Act Amendments of 1977," which was promulgated in 40 CFR 60.16, 44 FR 49222,
dated August 21, 1979, ranked sources according to the impact that standards
promulgated in 1980 would have on emissions in 1990. Automobile and light-duty
truck surface coating operations rank 27 out of 59 on this list of sources
i
to be controlled.
The surface coating operation is an integral part of an automobile or
light-duty truck assembly plant, accounting for about one-quarter to one-third
i
of the total space occupied by a typical assembly plant. Surface coatings
are applied in two main steps, prime coat and topcoat. Prime coats may be
!
water-based or organic solvent-based. Water-based coatings use water as
the main carrier for the coating solids, although these coatings normally
, -i ' • > • ' ' • . _ ;,
contain a small amount of organic solvent. Solvent-based coatings use organic
solvents as the coating solid carrier. Currently about half of the domestic
• : .. j :„•• '• :
automobile and light-duty truck assembly plants use water-based prime coats.
Where water-based prime coating is used, it is usually applied by EDP.
The EDP coat is normally followed by a "guide coat," which provides a suitable
surface for application of the topcoat. The guide coat may be water-based
or solvent-based.
Automobile and light-duty truck topcoats presently being used are
i
almost entirely solvent-based. One or more applications of topcoats are
9-2
I: ,::„
-------
applied to ensure sufficient coating thickness. An oven bake may follow
each topcoat application, or the coating may be applied wet on wet.
In 1976, nationwide emissions of VOC from automobile and light-duty
truck surface coating operations totaled about 135,000 metric tons. Prime
and guide coat operations accounted for about 50,000 metric tons with the
remaining 85,000 metric tons being emitted from topcoat operations. This
represents almost 15 percent of the volatile organic emissions from all
industrial coating operations.
VOC comprise the major air pollutant emitted by automobile and light-duty
truck assembly plants. Technology is available to reduce VOC emissions and
thereby reduce the formation of ozone and other photochemical oxidants.
Consequently, automobile and light-duty truck surface coating operations
have been selected for the development of standards of performance.
9.2 SELECTION OF AFFECTED FACILITIES
The prime coat, guide coat, and topcoat operations usually account for
more than 80 percent of the VOC emissions from automobile and light-duty
truck assembly plants. The remaining VOC emissions result from final top-
coat repair, cleanup, and coating of various small component parts. These
VOC emission sources are much more difficult to control than the main surface
coating line for several reasons. First, water-based coatings cannot be
used for final topcoat repair, since the high temperatures required to cure
water-based coatings may damage heat sensitive components which have been
attached to the vehicle by this stage of production. Second, the use of
solvents is required for equipment cleanup procedures. Third, add-on con-
trols, such as incineration, cannot be used effectively on these cleanup
operations because they are composed of numerous small operations located
9-3
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throughout the plant. Since prime coat, guide coat, and topcoat operations
account for the bulk of VOC emissions from automobile and light-duty truck
'",[..: '• ' i ' , ">' f
assembly plants, and control techniques for reducing VOC emissions from
these operations are demonstrated, they have been selected for control by
• , , , , | „ ,
standards of performance.
The "affected facility" to which the proposed! standards would apply
i
could be designated as the entire surface coating line or each individual
surface coating operation. A major consideration in selecting the affected
facility was the potential effect that the modification and reconstruction
provisions under 40 CFR 60.14 and 60.15, which apply to all standards of
performance, could have on existing assembly plants. A modification is any
physical or operational change in an existing facility which increases air
pollution from that facility. A reconstruction Is any replacement of com-
ponents of an existing facility which is so extensive that the capital cost
of the new components exceeds 50 percent of the capital cost of a new facility.
!
For the standard of performance to apply, EPA must conclude that it is
j
technically and economically feasible for the reconstructed facility to
meet the standards.
Many automobile and light-duty truck assembly plants that have a spray
prime coat system will be switching to EDP prime coat systems in the future
to reduce VOC emissions to comply with revised SIP's. The capital cost of
this change could be greater than 50 percent of the capital cost of a new
surface coating line. If the surface coating line were chosen as the affected
facility, and if this switch to an EDP prime coat system were considered a
reconstruction of the surface coating line, all surface coating operations
on the line would be required to comply with the proposed standards. Most
9-4
-------
plants would be reluctant to install an EDP prime coat system to reduce VOC
emissions if, by doing so, the entire surface coating line might then be
required to comply with standards of performance. By designating the prime
coat, guide coat, and topcoat operations as separate affected facilities,
this potential problem is avoided. Thus, each surface coating operation
(i.e., prime coat, guide coat, and topcoat) has been selected as an affected
facility in the proposed standards.
9.3 SELECTION OF BEST SYSTEM OF EMISSION REDUCTION
VOC emissions from automobile and light-duty truck surface coating
operations can be controlled by the use of coatings having a low organic
solvent content, add-on emission control devices, or a combination of the
two. Low organic solvent coatings consist of water-based enamels, high
solids enamels, and powder coatings. Add-on emission control devices
consist of such techniques as incineration and carbon adsorption.
9.3.1 Control Technologies
Water-based coating materials are applied either by conventional
spraying or by EDP. Application of coatings by EDP involves dipping the
automobile or truck to be coated into a bath containing a dilute water solu-
tion of the coating material. When charges of opposite polarity are applied
to the dip tank and vehicle, the coating material deposits on the vehicle.
Most EDP systems presently in use are anodic systems in which the vehicle
is given a positive charge. Cathodic EDP, in which the vehicle is negatively
charged, is a new technology which is expanding rapidly in the automobile
industry. Cathodic EDP provides better corrosion resistance and requires
lower cure temperatures than anodic systems. Cathodic EDP systems are also
capable of applying better coverage on deep recesses of parts.
9-5
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The prime coat is usually followed by a spray application of an inter-
I
mediate coat, or guide coat, before topcoat application. The guide coat
provides the added film thickness necessary for sanding and a suitable sur-
face for topcoat application. EDP can only be used if the total film thick-
ness on the metal surface does not exceed a limiting value. Since this
limiting thickness is about the same as the thickness of the prime coat,
spraying has to be used for guide and topcoat application of water-based
coatings.
I
Currently, nearly half of domestic automobile and light-duty truck
i
assembly plants use EDP for prime coat application, but only two domestic
plants use water-based coatings for guide andtopcoat applications.
Coatings whose solids content is about 45 to 60 percent are being
developed by a number of companies. When these coatings are applied at
high transfer efficiency rates, VOC emissions are significantly less than
emissions from existing solvent-based systems. While these high solids
coatings could be used in the automotive industry,, certain problems must be
overcome. The high working viscosity of these coatings makes them unsuit-
able for use in many existing application devices,, In addition, this high
viscosity can produce an "orange peel," or uneven, surface. It also makes
these coatings unsuitable for use with metallic finishes. Metallic finishes,
which account for about 50 percent of domestic demand, are produced by adding
small metal flakes to the paint. As the paint dries, these flakes become
•: ,"",", ' !
oriented parallel to the surface. With high solids coatings, the viscosity
of the paint prevents movement of the flakes, andthey remain randomly oriented,
producing a rough surface. However, techniques such as heated application
are being investigated to reduce these problems, and it is expected that
9-6
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within a few years high solids coatings will be technically demonstrated
for use in the automotive industry.
Powder coatings are a special class of high solids coatings that consist
of solids only. They are applied by electrostatic spray and are being used
on a limited basis for topcoating automobiles, both foreign and domestic.
The use of powder coatings is severely limited, however, because metallic
finishes cannot be applied using powder. As with other high solids coatings,
research is continuing in the use of powder coatings for the automotive
industry.
Thermal incineration has been used to control VOC emissions from bake
ovens in automobile and light-duty truck surface coating operations because
of the fairly low volume and high VOC concentration in the exhaust stream.
Incineration normally achieves a VOC emission reduction of over 90 percent.
Thermal incinerators have not, however, been used for control of spray booth
VOC emissions. Typically, the spray booth exhaust stream is a high volume
stream (95,000 to 200,000 liters per second) which is very low in concentra-
tion of VOC (about 50 ppm). Thermal incineration of this exhaust stream
would require a large amount of supplemental fuel, which is its main drawback
for control of spray booth VOC emissions. There are no technical problems
with the use of thermal incineration.
Catalytic incineration permits lower incinerator operating tempera-
tures and, therefore, requires about 50 percent less energy than thermal
incineration. Nevertheless, the energy consumption would still be high if
used to control VOC emissions from a spray booth. In addition, catalytic
incineration allows the owner or operator less choice in selecting a fuel;
it requires the use of natural gas to preheat the exhaust gases, since oil
9-7
-------
firing tends to foul the catalyst. While catalytic incineration is not
currently being employed in automobile and light-duty truck surface coating
operations for control of VOC emissions, there are no technical problems
which would preclude its use on either bake oven or spray booth exhaust
gases. The primary limiting factor is the high energy consumption, of natural
i
gas, if used to control emissions from spray booths.
Carbon adsorption has been used successfully to control VOC emissions
|
in a number of industrial applications. The ability of carbon adsorption
to control VOC emissions from spray booths and bake ovens in automobile and
light-duty truck surface coating operations, however, is uncertain. The
presence of a high volume, low VOC exhaust stream from spray booths would
require carbon adsorption units much larger than any that have ever been
built. For bake ovens in automobile and light-duty truck surface coating
operations, a major impediment to the use of carbon adsorption is heat.
The high temperature of the bake oven exhaust stream would require the use
of refrigeration to cool the gas stream before it passes through the carbon
bed. Carbon adsorption, therefore, is not considered a demonstrated tech-
nology at this time for controlling VOC emissions from automobile and
light-duty truck surface coating operations. Work is continuing within the
automotive industry on efforts to apply carbon adsorption to the control of
VOC emissions, however, and it may become a demonstrated technology in the
near future. ,
- - i
9.3.2 Regulatory Options
Water-based coatings and incineration are two well-demonstrated and
feasible techniques for controlling emissions of VOC from automobile and
light-duty truck surface coating operations. Based upon the use of these
9-8
-------
two VOC emission control techniques, the following two regulatory options
were evaluated.
Regulatory Option I includes two alternatives which achieve essentially
equivalent control of VOC emissions. Alternative A is based on the use of
water-based prime coats, guide coats, and topcoats. The prime coat would
be applied by EDP. Since the guide coat is essentially a topcoat material,
guide coat emission levels as low as those achieved by water-based topcoats
should be possible through a transfer of technology from topcoat operations
to guide coat operations. Alternative B is based on the use of a water-based
prime coat applied by EDP and solvent-based guide coats and topcoats. Incinera-
tion of the exhaust gas stream from the topcoat spray booth and bake oven
would be used to control VOC emissions under this alternative.
Regulatory Option II is based on the use of a water-based prime coat
applied by EDP and solvent-based guide coats and topcoats. In this option,
the exhaust gas streams from both the guide coat and topcoat spray booths
and bake ovens would be incinerated to control VOC emissions.
These two regulatory options are summarized in Table 9-1 and are compared
against a base case consisting of water-based prime coat (EDP) and solvent-
based guide coat and topcoat. This base case is representative of VOC emis-
sions from new automobile and light-duty truck surface coating operations
capable of meeting existing State Implementation Plan (SIP) emission limits.
9.3.3 Environmental, Energy, and Economic Impacts
Standards based on Regulatory Option I would lead to a reduction in
VOC emissions of about 80 percent, and standards based on Regulatory Option II
would lead to a reduction in emissions of about 90 percent, compared to VOC
emissions from automobile and light-duty truck surface coating operations
9-9
-------
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controlled to meet current SIP requirements. Growth projections indicate
there will be four new automobile and light-duty truck assembly lines con-
structed by 1983. Very few, if any, modifications or reconstructions are
expected during this period. Based on these projections, national VOC emis-
sions in 1983 would be reduced by about 4,800 metric tons with standards
based on Regulatory Option I, and about 5,400 metric tons with standards
based on Regulatory Option II. Thus, both regulatory options would result
in a significant reduction in VOC emissions from automobile and light-duty
truck surface coating operations.
With regard to water pollution, standards based on Regulatory Option II
would have essentially no impact. Similarly, standards based on Regulatory
Option I(B) would have no water pollution impact. Standards based on Regula-
tory Option I(A), however, would result in a slight increase in the chemical
oxygen demand (COD) of the wastewater discharged from automobile and light-
duty truck surface coating operations within assembly plants. This increase
is due to water-miscible solvents in the water-based guide coats and topcoats
which become dissolved in the wastewater. The increase in COD of the waste-
water, however, would be small relative to current COD levels at plants
using solvent-based surface coatings and meeting existing SIPs. In addition,
this increase would not require the installation of a larger wastewater
treatment facility than would be built for an assembly plant which used
solvent-based surface coatings.
The solid waste impact of the proposed standards would be negligible.
The volume of sludge generated from water-based surface coating operations
is approximately the same as that generated from solvent-based surface coating
operations. The solid waste generated by water-based coatings, however, is
9-11
-------
very sticky, and equipment cleanup is more time consuming than for solvent-
based coatings. Sludge from either type of system can be disposed of by
i
conventional landfill procedures without leachate problems.
With regard to energy impact, standards based on Regulatory Option I(A)
would increase the energy consumption of surface coating operations at a
new automobile or light-duty truck assembly plant by about 25 percent.
Regulatory Option I(B) would cause an increase of about 150 to 425 percent
in energy consumption. Standards based on Regulatory Option II would result
in an increase of 300 to 700 percent in the energy consumption of surface
coating operations at a new automobile or light-duty truck assembly plant.
The range in energy consumption for those options which are based on use of
incineration reflects the difference between catalytic and thermal inciner-
ation. !
The relatively high energy impact of standards based on Regulatory
Option I(B) and Regulatory Option II is due to the large amount of incineration
fuel needed. Standards based on Regulatory Option II would increase energy
consumption at a new automobile and light-duty truck assembly plant by the
equivalent of about 200,000 to 500,000 barrels of fuel oil per year, depending
upon whether catalytic or thermal incineration was used. Standards based
on Regulatory Option I(B) would increase energy consumption by the equivalent
of about 100,000 to 300,000 barrels of fuel oil per year.
Standards based on Regulatory Option I(A) would increase the energy
consumption of a typical new automobile and light-duty truck assembly'plant
by the equivalent of about 18,000 barrels of fuel oil per year. Approximately
one-third of this increase in energy consumption is due to the use of air
, „ , , ,„•- ; i
conditioning, which is necessary with the use of water-based coatings, and
9-12
-------
the remaining two-thirds are due to the increased fuel required in the bake
ovens for curing water-based coatings.
Growth projections indicate that four new automobile and light-duty
truck assembly lines (two automobile and two truck lines) will be built by
1983. Based on these projections, standards based on Regulatory Option I(A)
would increase national energy consumption in 1983 by the equivalent of
about 72,000 barrels of fuel oil. Standards based on Regulatory Option I(B)
would increase national energy consumption in 1983 by the equivalent of
400,000 to 1,200,000 barrels of fuel oil, depending on whether catalytic or
thermal incineration were used. Standards based on Regulatory Option II
would increase national energy consumption in 1983 by the equivalent of
800,000 to 2,000,000 barrels of fuel oil, again depending on whether cata-
lytic or thermal incineration were used.
The economic impacts of standards based on each regulatory option were
estimated using the above mentioned growth projection of four new assembly
lines by 1983. Incremental control costs were determined by calculating
the difference between the capital and annualized costs of new assembly
plants controlled to meet Regulatory Options I(A), I(B), and II, respec-
tively, with the corresponding costs for new plants designed to comply with
existing SIPs. Of the four assembly plants projected by 1983, two were
assumed to be lacquer lines and the other two enamel lines. There are basic
design differences between these two types of surface coatings which have a
substantial impact on the magnitude of the costs estimated to comply with
standards of performance. Lacquer surface coating operations, for example,
require much larger spray booths and bake ovens than enamel surface coating
operations. Water-based systems also require large spray booths and bake
9-13
-------
ovens; thus, the incremental capital cost of installing a water-based system
in a plant which would otherwise have used a lacquer system, is relatively
low. The incremental capital costs differential, however, would be much
larger if the plant had been designed for an enamel system.
Tables 9-2 and 9-3 summarize the economic impacts of the proposed
standards on typical size plants. Table 9-2 presents the incremental costs
of the various control options for a plant which would have used solvent-
based lacquers. Table 9-3 presents similar costs for plants which would
have been designed to use solvent-based enamels. While these tables present
incremental costs for passenger car plants, light-duty truck plants would
have similar cost differentials. In all cases, it is assumed the plants
would install a water-based EDP prime system in the absence of standards of
performance. Therefore, no incremental costs associated with EDP prime
coat operations are included in the costs presented in Tables 9-2 and 9-3.
A nominal production rate of 55 passenger cars per hour was assumed for
both plants. Tables 9-2 and 9-3 show incremental capitalized and annualized
costs per vehicle produced at each new facility. The manufacturers would
probably distribute these incremental costs over their entire annual produc-
tion to arrive at purchase prices for the automobiles and light-duty trucks.
Incremental capital costs for using incineration to reduce VOC emis-
sions from solvent-based lacquer plants to levels comparable to water-based
plants are much larger than they are for using incineration on a solvent-based
enamel plant. This large difference in costs occurs because lacquer plants
have larger spray booth and bake oven areas than enamel plants and, therefore,
a larger volume of exhaust gases. Since larger incineration units are required,
the incremental capital costs of using incineration to control VOC emissions
9-14
-------
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from a solvent-based lacquer plant are about 15 to 25 times greater than
they are for using water-based coatings. Similarly, energy consumption is
much greater; hence, the annualized costs of using incineration are about
ten times greater than they are for using water-based coatings.
On the other hand, the incremental capital costs of controlling VOC
emissions from new solvent-based enamel plants by the use of incineration
are only about one-half the incremental capital costs between a new solvent-
based enamel plant and a new water-based plant. Due to the energy consump-
tion associated with incinerators, however, the incremental annualized costs
of using incineration with solvent-based enamel coatings .could vary from as
little as 15 percent more to as much as 90 percent more than the annualized
costs of using water-based coatings.
While the incremental capital costs of building a plant to use water-based
coatings can be larger or smaller than the costs of using incineration,
depending upon whether a solvent-based lacquer plant or a solvent-based
enamel plant is used as the starting point, the annualized costs of using
water-based coatings are always less than they are for using incineration.
This is due to the large energy consumption of incineration units compared
to the energy consumption of water-based coatings.
Since the incremental annualized costs are less with Regulatory
Option I(A) than with Regulatory Option I(B), it is assumed in this analy-
sis that Regulatory Option I(A) would be incorporated at any new, modified,
or reconstructed facility to comply with standards based on Regulatory
Option I. As noted, four new assembly plants are expected to be built by
1983. The incremental capital cost to the industry for these plants to
comply with standards based on Regulatory Option I would be approximately
9-17
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I
$19 million. The corresponding incremental annualized costs would be about
$9 million in 1983. If standards are based on Regulatory Option II, it is
expected that industry would choose catalytic incineration because its
annualized costs are lower than thermal incineration. Based on this assump-
tion, the incremental capital costs for the industry under Regulatory Option II
would be approximately $42 million, and the incremental annualized costs by
1983 would be about $30 million. For standards based on either Regulatory
Option I or Regulatory Option II, the increase in the price of an automo-
bile or light-duty truck that is manufactured at one of the new plants would
be less than 1 percent of the base price of the vehicle.
9.3.4 Best System of Emission Reduction
Both Regulatory Options I and II achieve a significant reduction in
VOC emissions compared to automobile and light-duty truck assembly plants
controlled to comply with existing SIPs, and neither option creates a signi-
ficant adverse impact on other environmental media. In terms of energy
consumption, standards based on Regulatory Option II would have as much as
10 to 25 times the adverse impact on energy consumption as standards based
on Regulatory Option I, while only achieving 10 to 15 percent more reductions
in VOC emissions. The costs of standards based on Regulatory Option II
range from two to three times the costs of standards based on Regulatory
Option I. Thus, Regulatory Option I(A), water-based coatings, was selected
as the best system of continuous emission reduction, considering costs and
nonair quality health, environmental, and energy impacts.
Although water-based coatings are considered to be the best system of
emission reduction at the present time, it is very likely that plants built
in the future will use other systems to control VOC emissions, such as high
9-18
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solids coatings and powder coatings. High solids coatings are expected to
be available by 1982 and will probably be used by most new sources to comply
with the VOC emission limitations. Powder coatings are also expected to be
available in the future but are not demonstrated at this time.
9.4 SELECTION OF FORMAT FOR THE PROPOSED STANDARDS
A number of different formats could be selected to limit VOC emissions
from automobile and light-duty truck surface coating operations. The format
ultimately selected must be compatible with any of the three different control
systems that could be used to comply with the proposed standards. One control
system is the use of water-based coating materials in the prime coat, guide
coat, and topcoat operations. Another control system is the use of solvent-
based coating materials and add-on VOC emission control devices such as
incineration. The third control system consists of the use of high solids
coatings. Although the coatings to be used in this system are not demonstrated
at this time, research is continuing toward their development; hence, they
may be used in the future.
The formats considered were emission limits expressed in terms of:
(1) concentration of emissions in the exhaust gases discharged to the atmos-
phere; (2) mass emissions per unit of production; or (3) mass emissions per
volume of coating solids applied.
The major advantage of the concentration format is its simplicity of
enforcement. Direct emission measurements could be made using Reference
Method 25. There are, however, two significant drawbacks to the use of
this format. Regardless of the control approach chosen, emission testing
would be required for each stack exhausting gases from the surface coating
operations (unless the owner or operator could demonstrate to the
9-19
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• 0.10 kilogram of volatile organic compounds per liter of applied
coating solids from prime coat operations
• 0.84 kilogram of volatile organic compounds per liter of applied
coating solids from guide coat operations
• 0.84 kilogram of volatile organic compounds per liter of applied
coating solids from topcoat operations
In all three limits, the mass of VOC is expressed as mass of carbon in accor-
dance with Reference Methods 24 (Candidate 1) and 25. These emission limits
are based on the use of water-based coating materials in the prime coat,
guide coat, and topcoat operations. Water-based coating data were obtained
j
from plants which were using these materials as well as the vendors who
supply them. These data were used to calculate VOC emission limits using a
procedure similar to proposed Reference Method 24 (Candidate 1). A transfer
efficiency of 40 percent was then applied to the values obtained for guide
coat and topcoat emissions. This efficiency was determined to be represen-
tative of a well operated air atomized spray system. The CTG recommended
limits are based on the use of the same coating materials as the proposed
standards. The limits in the CTG are expressed in pounds of VOC per gallon
of coating (minus water) used in the EDP system or the spray device. The
limits in this proposed standard, however, are referenced to the amount of
coating solids which adhere to the vehicle body. Therefore, to compare the
limits in the CTG to those proposed here, it is necessary to account for
the solids content of the coating and the efficiency of applying tne guide
coat and topcoat to the vehicle body. Consideration of transfer efficiency
I
is significant because the recommended standards can be met by using high
solids content coating materials if the amount of overspray is kept to a
minimum. Since this format provides equivalency determinations for systems
9-22
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VOC emissions per unit of production. This format, however, would not account
for differences in surface coating requirements for different vehicles due
to size and configuration. In addition, manufacturers of larger vehicles
would be required to reduce VOC emissions further than manufacturers of
smaller vehicles.
A format of mass of VOC emissions per volume of coating solids applied
also has the advantage of not requiring stack emission testing unless add-on
emission control devices are used to comply with the standards rather than
water-based coatings. The introduction of dilution air into the exhaust
stream would not present a problem with this format. The problem of varying
vehicle sizes and configurations would be eliminated since the format is in
terms of volume of applied solids regardless of the surface area or number
of vehicles coated. This format would also allow flexibility in selection
of control systems, for it is usable with any of the control methods. Since
this format overcomes the varying dilution air and vehicle size problems
inherent with the other formats, it has been selected as the format for the
proposed standards. In order to use a format which is in terms of applied
solids, the transfer efficiency of the application devices must be considered.
Transfer efficiency is an important factor because as efficiency decreases,
more coating material is used and VOC emissions increase. Equations have
been developed to use this format with water-based coating materials as
well as with solvent-based coating materials in combination with high transfer
efficiencies and/or add-on emission controls devices. These equations are
included in the proposed standards.
9.5 SELECTION OF NUMERICAL EMISSION LIMITS
The numerical emission limits selected for the proposed standard are
as follows:
9-21
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Administrator's satisfaction that testing of representative stacks would
•i ;; "; •• •"•• :*•• ;: : ' ' ''" ' '•'[•
give the same results as testing all the stacks). This testing would be
time consuming and costly because of the large number of stacks associated
with automobile and light-duty truck surface coating operations. Another
potential problem with this format is the ease of circumventing the stan-
dards by the addition of dilution air. It would be extremely difficult to
determine whether dilution air were being added intentionally to reduce the
concentration of VOC emissions in the gases discharged to the atmosphere,
1
or whether the air was being added to the application or drying operation
1 '',',." * '• ' 'ii' '" ! "i , i ' "'' • ' ' ' ;" i.,'
to optimize performance and maintain a safe working space.
A format of mass of VOC emissions per unit of production relates emis-
sions to individual plant production on a direct basis. Where water-based
coatings are used, the average VOC content of the coating materials could
be determined by using Reference Method 24 (Candidate 1 or Candidate 2).
The volume of coating materials used and the percent solids could be determined]
from purchase records. VOC emissions could then be calculated by multiplying
the VOC content of the coating materials by the volume of coating materials
used in a given time period and by the percentageof solids, and dividing
the result by the number of vehicles produced in that time period. This
would provide ? VOC emission rate per unit of production. Consequently,
procedures to determine compliance would be direct and straightforward,
although very time consuming^ This procedure would also require data collec-
tion over an excessively long period of time.
Where solvent-based coatings were used with add-on emission control
devices, stack emission tests could be performed to determine VOC emissions.
Dividing VOC emissions by the number of vehicles produced would again yield
9-20
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using-solvent-based coating materials in combination with high transfer
efficiencies and/or add-on control devices, it allows flexibility in selection
of control systems. .
As discussed in previous sections, there are two types of EDP systems.
Anodic EDP was the first type developed for use in automotive surface coating
operations. Cathodic EDP is the second type and is a recent technology
improvement which results in greater corrosion resistance. Consequently,
nearly 50 percent of the existing EDP operations use cathodic systems, and
continued changeovers from anodic to cathodic EDP are expected. Since cathodic
EDP produces a coating with better corrosion resistance, the proposed stan-
dards are based on the best available cathodic EDP systems.
The coating material on which the EDP emission limit was based is presently
in limited production use. Although this low solvent content material is
currently available only in limited quantities, it is expected to be available
in sufficient quantities for use in all new or modified sources before promul-
gation of the standards. The final promulgated standards will be based on
this low solvent content material, rather than the EDP material commonly
used now, if it is determined to be widely available at that time.
The emission limit for guide coat operations is based on a transfer of
technology from topcoat operations. The guide coat is essentially a topcoat
material, without pigmentation, and water-based topcoats are available which
can comply with the proposed limits. Hence, the same emission limit is
proposed for the guide coat operation as for the topcoat operation.
Because of the elevated temperatures present in the prime coat, guide
coat, and topcoat bake ovens, there may be additional amounts of "cure volatile"
VOC emitted. These "cure volatile" emissions are present only at high
9-23
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temperatures and are not measured in the analysis which is used to deter-
mine the VOC content of coating materials. Cure volatile emissions, however,
are believed to constitute only a small percentage of total VOC emissions.
Consequently, due to the complexity of measuring and controlling cure volatile
j
emissions, they would not be considered in determining compliance with the
proposed standards.
.! • i . I .
A large number of coating materials are used in topcoat operations,
and each may have a different VOC content. Hence, an average VOC content
of all the coatings used in this operation would be computed to determine
compliance with the proposed standards. Either of two averaging techniques
could be used for computing this average. Weighted averages provide very
accurate results but would require keeping records of the total volume and
percent solids of each different coating used. Arithmetic averages are not
always as accurate; however, they are much simpler to calculate. In the
case of topcoat operations, normally 15 to 20 different coatings are used,
and the VOC content for most of these coatings is in the same general range.
I
Therefore, an arithmetic average would closely approximate the values obtained
from a weighted average. An arithmetic average would be calculated by summing
the VOC content of each surface coating material used in a surface coating
operation (i.e., guide coat or topcoat), and dividing the sum by the number
of different coating materials used. Arithmetic averages are also consistent
j
with the approach being incorporated into some revised SIPs.
For the EDP process, however, an arithmetic average VOC content is not
appropriate to determine compliance with the proposed standards. In an EDP
system, the coating material applied to an automobile or light-duty truck
body is replaced by adding fresh coating materials to maintain a relatively
9-24
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constant concentration of solids, solvent, and fluid level in the EDP coating
tank. Three different types of materials are usually added in separate
streams—clear resin, pigment paste, and solvent.
The clear resin and pigment paste are very low in VOC content (i.e.,
10 percent or less), while the solvent is very high in VOC content (i.e.,
90 percent or more). The solvent additive stream is only about 2 percent
of the total volume added. Consequently, an arithmetic average of the three
streams seriously misrepresents the actual amount of VOC added to the EDP
coating tank. Weighted averages, therefore, were selected for determining
the average VOC content of coating materials applied by EDP.
If an automobile or light-duty truck manufacturer chooses to use a
control technique other than water-based coatings, the transfer efficiency
of the application devices used becomes very important. As-transfer effi-
ciency decreases, more coating material is used, and VOC emissions increase.
Therefore, transfer efficiency must be taken into account to determine
equivalency to water-based coatings.
Electrostatic spraying, which applies surface coatings at high transfer
efficiencies, can in many industries be used with water-based coatings if
the entire paint handling system feeding the atomizers is insulated electri-
cally from ground. Otherwise, the high conductivity of the water involved
would ground out and make ineffective the electrostatic effect. In the
case of the coating of automobiles, however, because of the large number of
colors involved, the high frequency and speed of color changes required,
the large volume of coatings consumed per shift, and the large number of
both automatic and manual atomizers involved, it is not technically feasible
to combine water-based coatings and electrostatic methods for reasons of
9-25
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Transfer Efficiency
40 percent
75 percent
95 percent
1(30 percent -
complexity, cost and personnel comfort. Consequently, water-based surface
coatings are applied by air-atomized spray systems at a transfer efficiency
of about 40 percent. The numerical emission limits included in the proposed
standards were developed based on the use of water-based surface coatings
applied at a 40 percent transfer efficiency. Therefore, if surface coatings
are applied at greater than 40 percent transfer efficiency, surface coatings
with higher VOC contents may be used with no increase in VOC emissions to
the atmosphere. Transfer efficiencies for various means of applying surface
coatings have been estimated, based on information obtained from industries
and vendors, as follows:
Application Method
Air Atomized Spray
Manual Electrostatic Spray
Automatic Electrostatic Spray
Electrodeposition (EDP)
These values are estimates which reflect the high side of expected
transfer efficiency ranges, and therefore, are intended to be used only for
the purpose of determining compliance with the proposed standards.
Frequently, more than one application method is used within a single
surface coating operation. In these cases, a weighted average transfer
efficiency, based on the relative volume of coating sprayed by each method,
will be estimated. These situations are likely to vary among the different
manufacturers and the estimates, therefore, will be subject to approval by
the Administrator on a case-by-case basis.
9.6 SELECTION OF MONITORING REQUIREMENTS
Monitoring requirements are generally included in standards of perfor-
mance to provide a means for enforcement personnel to ensure that emission
9-26
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control measures adopted by a facility to comply with standards of perfor-
mance are properly operated and maintained. Surface coating operations
which have achieved compliance with the proposed standards without the use
of add-on VOC emission control devices would be required to monitor the
average VOC content (weighted averages for EDP and arithmetic averages for
guide coat and topcoat) of the coating materials used in each surface coating
operation. Generally, increases in the VOC content of the coating materials
would cause VOC emissions to increase. These increases could be caused by
the use of new coatings or by changes in the composition of existing coatings.
Therefore, following the initial performance test, increases in the average
VOC content of the coating materials used in each surface coating operation
would have to be reported as excess emissions on a quarterly basis.
Where add-on control devices, such as incinerators, were used to comply
with the proposed standards, combustion temperatures would be monitored.
Following the initial performance test, decreases in the incinerator combus-
tion temperature would be reported as excess emissions on a quarterly basis.
9.7 PERFORMANCE TEST METHODS
Reference Method 24, "Determination of Volatile Organic Compound Content
of Paint, Varnish, Lacquer, or Related Products," is proposed in two forms;
Candidate 1 and Candidate 2. Candidate 1 leads to a determination of VOC
content expressed as mass of carbon. Candidate 2 yields a determination of
VOC content measured as mass of volatile organics. Either of these candidates
is compatible with the proposed standards, and the decision as to which
candidate will be used depends on the final format selected for the standards.
Reference Method 25, "Determination of Total Gaseous Nonmethane Volatile
Organic Compound Emissions," was proposed as the test method to determine
9-27
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the percentage reduction of VOC emissions achieved by add-on emission control
devices.
9.8 MODIFICATIONS AND RECONSTRUCTIONS !
During the development of the standards, the automobile industry expressed
concern that changes to assembly plants made only for the purpose of annual
model changeovers would be considered a modification or reconstruction as
defined in the Code of Federal Regulations, Title 40, Parts 60.14 and 60.15
(40 CFR 60.14 and 60.15). A modification is any physical or operational
change in an existing facility which increases air pollution from that facility.
A reconstruction is any replacement of components of an existing facility
which is so extensive that the capital cost of.the new components exceeds
50 percent of the capital cost of a new facility. In general, modified and
reconstructed facilities must comply with standards of performance. According
. , |
to the available information, changes to coating lines for annual model
changeovers do not cause emissions to increase significantly. Further,
these changes would normally not require a capital expenditure that exceeds
the 50 percent criterion for reconstruction. Hence, it is very unlikely
• ' : J *
that these annual facility changes would be considered either a modification
or a reconstruction. Therefore, the proposed standards state that changes
to surface coating operations made only to accommodate annual model changeovers
are not a modification or reconstruction. In addition, by exempting annual
model changeovers, enforcement efforts are greatly reduced with little or
no adverse environmental impact.
9-28
>i!;; I liiiiUliH illiillii I
-------
APPENDIX A
EVOLUTION OF PROPOSED STANDARDS
This study to develop proposed standards of performance for new surface
coating operations within the automotive industry began in 1973 under the
direction of the Office of Air Quality Planning and Standards (OAQPS),
Emission Standards and Engineering Division (ESED) with Mr. Richard B. Atherton
of the Industrial Studies Branch (ISB) as the lead engineer. In June 1975,
EPA authorized DeBell and Richardson to continue the study, contract number
68-02-2062, under the direction of Mr. Dave Patrick of the Chemical Petroleum
Branch (CPB). On March 30, 1976, Mr. James Berry (CPB) replaced Mr. Dave Patrick
as lead engineer. Table A-l lists the major events that occurred between
project initiation and October 1978, when Acurex Corporation was retained
by EPA to complete the study under contract number 68-02-3064 with
Mr. Sims L. Roy as the lead engineer, OAQPS, ESED of the Standards Development
Branch.
The overall objective of this study was to compile and analyze data in
sufficient detail to substantiate standards of performance. To accomplish
this objective, the investigators first acquired the necessary technical
information on: (1) coating operations and processes; (2) the release and
controllability of organic emissions into the atmosphere by this source;
and (3) the costs of demonstrated control techniques. A literature search
was conducted and data obtained from the following:
• U.S. Department of Commerce
« Federal Trade Commission Quarterly Reports
• Society of Manufacturing Engineers
-------
Table A-l. MAJOR EVENTS, YEAR 1974 - MID 1978
Equipment Manufacturers Telephone Survey
Equipment Suppliers Telephone Survey
Surface Coating Equipment Manufacturers
Office of Management and Budget (OMB)
Approval of Questionnaire
Industry Completion of Questionnaires
Meeting to Discuss Economic Impacts
Draft Document, "Study to Support NSPS ' ' _..
for Automobile and Light-Duty Trucks," Published by EPA
EPA Memo Suggesting Standards of Performance Sent to Industry
National Air Pollution Control Techniques Advisory Committee
(NAPCTAC) Meeting
Working Group Meeting
JACA Corporation Retained by EPA to Study Economic Impacts
PEDCo Retained by EPA to Prepare an Economic Impact Analysis
Centec Consultants, Inc. Retained by EPA to Revise Draft
Document
Meetings with Various Equipment Manufacturers, Suppliers
and Auto Makers and State Agencies (See Tables A-2, A-3, A-4,
8/11/75
8/15/75
8/20/75
9/26/75
12/75 - 5/76
2/1/76
„ 1 ,
• . , I
6/1/77
8/771
9/27/77
10/6/77
11/77
4/26/78
7/1/78
A-5)
A-2
-------
• U.S. Government Printing Office
• National Technical Information Service
t Various Trade Journals
Through an extensive telephone survey, data were obtained from suppliers
and manufacturers of control equipment and coating materials used within
the surface coating industry. Contacts with trade associations, regional
EPA offices, and State air pollution authorities provided additional tech-
nical information. An EPA questionnaire (industry survey) was approved by
OMB in September 1975 and distributed throughout the automotive industry to
obtain information on plant size, control techniques, production capacities
and emissions data. Direct contacts were supplemented by plant tours and
meetings with the automotive industry to gain firsthand information on
control techniques and emissions data.
The second major step in this study was to determine the environmental
and economic impacts of various alternative regulatory options. The environ-
mental impacts of the various alternative regulatory options were determined
by comparing the projected emissions under each option with those for the
base case. The economic analysis was supported by examining various automotive
plants, contacting the Department of Commerce, and reviewing Wards' Automotive
Yearbooks and various trade journals.
On June 1, 1977, EPA published a draft document, "Study to Support an
NSPS for Automobile and Light-Duty Trucks." A memo suggesting standards of
performance was distributed throughout the automotive industry in August 1977.
DeBell and Richardson presented the draft study to the NAPCTAC meeting held
in Alexandria, Virginia, on September 27 and 28, 1977. On October 6, 1977,
a working group meeting was held to discuss industry comments raised at the
NAPCTAC meeting.
A-3
-------
Upon receipt of this project in October 1978, Acurex began to review
, • '. ::,, J>'; ih 1
and revise the previous documents in light of the comments made by the
' • i
Working Group and NAPCTAC, and the information received from industry since
the preparation and public presentation of the first draft.
Additional data were obtained from Ransburg Corporation on transfer
efficiencies and from General Motors on paint content." The existing docu-
ment was extensively revised from December 1978 to mid-May 1979. The
i
complete Background Information Document (BID) and the FEDERAL REGISTER
. . , . , ,
notice of the proposed regulation were prepared and submitted to the EPA
Steering Committee on May 18, 1979, and the Assistant Administrators for
concurrence on July 18, 1979. The following tables list the various con-
tacts that were made during investigation of this study:
• Table A-2. Suppliers and Manufacturers
• Table A-3. State Agencies
• Table A-4. Plant Visits
V
• Table A-5. Meetings with the Automotive Industry
A-4
-------
Table A-2. SUPPLIERS AND MANUFACTURERS CONTACTED
ADSOX
AER Corporation
Binks
Calgon Activated Carbon Division
Combustion Equipment Associates
DeVilbiss Company
Dexter Corporation
Dow-Corning Corporation
E.I. DuPont de Nemours and Company
Electrostatic Equipment Corporation
George Koch & Sons, Incorporated
High Voltage Engineering Corporation
Hoyt Solvent Recovery Systems
Interrad
Jensen, Incorporated
Lilly Industrial Coatings, Incorporated
Matthey Bishop, Incorporated
Moller Engineering
Nordson Corporation
Polychrome
PPG Industries
Programmed Coating ;. .. .
Ransburg Corporation
RaySolv Incorporated
Regenerative Environmental Equipment Co., Incorporated (Reeco)
Sealectro Corporation
Sherwin Williams
Troy Chemical Corporation
Vulcan-Cincinnati
W.R. Grace and Company
W.S. Rockwell
A-5
-------
Table A-3. STATE AGENCIES CONTACTED
California Air Resources Board
Sacramento, CA
Bay Area Air Pollution Control District
San Francisco, CA
Air Pollution Control District
Louisville, KY
State of Maryland .
Department of Health and Mental Hygiene
Baltimore, MD
Department of Environmental Protection
Hartford, CT
Massachusetts Division of Environmental
Quality Engineering
Boston, MA
State of New Jersey
Department of Environmental Protection
Trenton, NJ
Commonwealth of Virginia
State Air Pollution Control Board
Virginia Beach, VA
A-6
-------
Table A-4. SURFACE COATING OPERATIONS VISITED DURING
PREPARATION OF THE BACKGROUND INFORMATION DOCUMENT
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Ford Motor Corp.
Wayne, MI
General Motors Corp.
Detroit, MI
Chrysler Corp.
Detroit, MI
Ford Motor Corp.
Pico Rivera, CA .^
^'
General Motors..Corp.
Southgate/Van Nuys, CA
General Motors Corp.
Norwood, OH
Ford Motor Corp.
Atlanta, GA
Ford Motor Corp.
Metuchen, NJ
General Motors Corp.
Framingham, MA
Ford Motor Corp.
Norfolk, VA
Roper Eastern Co.
Baltimore, MD
General Motors Corp.
Southgate/Van Nuys, CA
Mack Trucks
Allentown/Macunigie, PA
3/27/73 Gather general information on
Ford's truck plant and the Wayne
auto assembly plant.
3/28/73 Fleetwood plant; gather general
information.
3/29/73 Observe the sources of emissions
and gather general information.
7/11/73 Observe bake ovens.
7/12/73 Observe bake ovens.
9/29/74 Familiarize EPA personnel with
the surface coating operations
within the automotive industry.
2/18/75 Familiarize EPA personnel with the
surface coating operations within
automotive industry.
5/14/75 Powder and conventional coating
operations.
9/9/75 Observe water-based primer process
(EDP) and to discuss powder coatings.
9/12/75 Pickup trucks are assembled at
this location. Gather general
information.
9/26/75 Observation of conventional
coil coating operations
10/7-8/75 Southgate and Van Nuys plants are
the only full scale automotive
assembly plants in the U.S.
employing water-based paints.
10/10/75 Gather general information.
A-7
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Chrysler Corp.
Newark, DE
White Motor Corp.
Exton, PA
General Motors Corp.
Baltimore, MD
General Motors Corp.
Wilmington, DE
Checker Motors Corp.
Kalamazoo, MI
Ford Motor Corp.
Wayne, MI
American Can Co.
Hillside, NJ
American Can Co.
Edison, NJ
Stanley Works Co.
New Britain, CT
General Dynamics Co.
Corvair Division
San Diego, CA
Chrysler Corp.
Detroit, MI
Chrysler Corp.
Detroit, MI
General Motors Corp.
Detroit, MI
10/14/75 Epoxy prime coat and acrylic enamel
topcoat operations.
10/15/75 Gather general information.
10/16/75 Enamel is used for prime coat and
lacquer for topcoat.
10/17/75 Chevettes are assembled at this
location. The Chevette requires
considerable inside painting.
11/11/75 Checker Motors manufactures taxi-
cabs. Checker Motors has had con-
tracts with one or more of the
other auto makers to paint cars
and produce body parts.
11/13/75 Observe conventional coating
operations.
12/2/75 Gather general information.
12/2/75 This location produces two-piece
cans which are coated with solvent-
based materials. The plant is
equipped with incinerators.
I
12/4/75 Observation of coil coating
operati ons
12/7/75 One of three U.S. aircraft indus-
tries employing new technology,
water-based technology.
12/8/75 Longest automobile assembly line in
the world. Considered a good can-
didate for general information pur-
poses.
12/8/75 Autophoretic coating is employed at
this plant.
12/9/75 Fleetwood plant; this coating
operation produces GM's highest
quality paint job.
A-8
li'ji,. ^.LJfan I •h.f'-f iiti!':. L''•.'-' • tin
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
General Motors Corp. 12/10/75
Pontiac, MI
Douglas Aircraft Co. 12/10/75
Long Beach, CA
Virco Manufacturing 12/10/75
Gardena, CA
Rockwell International 12/11/75
Saber!ine Division
El Segundo, CA
General Motors Corp. 12/12/75
Pontiac, MI
California Finished Metals, Inc. 12/12/75
Cucamonga, CA
Supracote Inc. 12/12/75
Cucamonga, CA
International Harvester Co. 12/15/75
Rock Island, IL
International Harvester Co. 12/15/75
East Moline, IL
Deere Co. 12/17/75
Waterloo, IA
Republic Steel Co. 12/17/75
Youngstown, OH
Two identical production lines are
housed at this location. LDL
(solvent-based low dispersion lac-
quer) was employed at this site
with the 1976 models.
To view application of conventional
solvent solution coatings.
Observe Virco's powder coating line
which is fitted with an incinerator.
Conventional coating of aircraft
with solvent-based materials.
Modern truck assembly plant, to
gather general information.
Obtain data on afterburners.
Obtain data on afterburners.
Observation of the manual
electrostatic spray operations.
Application of one coat modified
AKYD solvent-based paints with
electrostatic spray was observed.
Underrating of all tractor parts,
except chassis, is applied with
water-based paint by using the
EDP process.
Observe conventional coil coating
operations.
Armco Steel Corp.
Middletown, Ohio
12/18/75 Observe conventional coil coating
operations.
A-9
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Winnebago Industries
Forest City, IA
All is Chalmers Corp.
La Porte, IN
The Boeing Co.
Everett, WA
Hackney & Sons (East)
Washington, NC
Modern Materials Corp.
Detroit, MI
Litho-Strip Co.
Glenview, IL
Signode Corp.
Bridgeview, IL
Chrysler Corp.
Detroit, MI
Ford Motor Corp.
Wayne, MI
Simmons Co.
Munster, IN
Food Machinery Co.
Tupello, MS
Ford Motor Corp.
Metuchen, NJ
Lau Industries
Dayton, OH
12/18/75 Molding and trim on all Winnebago
mobile homes are electrostatically
sprayed with powder. Cabs are
electrostatically coated with
liquid paints.
12/19/75 Farm machinery is coated with
water-based paints.
12/21/75 Observe application of water-based
coatings.
12/22/75 Beverage trucks are topcoated with
acrylic enamels which are metallic
and nonmetallic.
1/7/76 Coil coating using water-based
materials.,
1/8/76 Solvent-based coating materials
are employed on their coil coating
1i nes.
1/8/76 Company manufactures steel strap-
pings which are coated with epoxy-
based materials.
1/9/76 Trucks are topcoated with solvent-
based coatings at this site.
1/9/76 Truck plant, solvent-based primer
coating operation. Small parts
are powder coated with an acrylic.
1/14/76 Metal drawers are coated with
high solids.
1/14/76 Conveyor parts are powder coated.
1/15/76 Observe powder coating operations.
1/15/76 Blower and fan components are
coated with water reducible
alkyd paint.
A-10
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
American Can Co. 1/16/76
Baltimore, MD
Continental Can Co. 1/16/76
Sparrows Point, MD
H.K. Porter Co. , Inc. 1/16/76
Lynchburg, VA
Teledyne Rodney Metals 1/23/76
New Bedford, MA
Bilco, Inc. 1/28/76
West Haven, CT
Level or Lorenthen, Inc. 1/29/76
Hoboken, NJ
Sun Shipbuilding & Dry Dock 1/30/76
Chester, PA
Lyon Metal Products, Inc. 2/3/76
Aurora, IL
Steel case Co. 2/4/76
Grand Rapids, MI
Ford Motor Corp. 2/5/76
Oakville
Ontario, Canada
Roll Coater, Inc. 2/9/76
Kingsbury, IN
International Harvester 2/10/76
Fort Wayne, IN
Norfolk Shipbuilding & Dry Dock 2/11/76
Norfolk, VA
Newport News Shipbuilding 2/12/76
Newport News, VA
Solvent-based inner lacquer is
employed. The base coat is a
high solids solvent-based material.
Obtain information in ultraviolet
curing.
Observe coating operations of
transformer parts.
Observe and discuss the coil coating
operation of the company. No primer
is applied, only a single solvent-
based topcoat.
Observe the coating operation of
metal doors.
Observation of the coil coating
operation.
Coating materials are solvent-based.
Metal furniture is coated with
solvent-based materials.
Metal furniture is powder coated
at this plant.
Plant has two assembly lines, one
truck and one automobile line.
Water-based coatings are employed.
Gather information on incinerators
and observe coil coating operations.
Truck plant, observe surface
coating operations of Scouts
(light-duty trucks).
The most commonly used coating
materials are solvent-based.
Practically all coating materials
are solvent-based.
A-11
-------
Table A-4 (continued)
COMPANY/LOCATION
General Products
Mayfield, VA
Keller Industries
Mil ford, VA
General Products
Fredericksburg, VA
Keller Industries
Mil ford, VA
Crown Cork and Seal Co., Inc.
Philadelphia, PA
Central Chevrolet Co.
West Springfield, MA
Endure a Lifetime
Miami, FL
Connecticut Auto Body
Bloorafield, CT
Houser Auto Body
Springfield, MA
Raybestos Manhattan, Inc.
Mayheim, PA
Viking Wire
Danbury, CT
Steiber Cycle Corp.
Medford, NY
VISIT
DATE(S)
•^•! ••
2/12/76
2/12/76
2/12/76
2/12/76
2/13/76
2/16/76
2/16/76
2/17/76
2/17/76
2/17/76
2/19/76
2/24/76
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Steel exterior entrance doors are
topcoated with acrylic which is
electrostatically sprayed.
Aluminum patio doors and windows
are coated with a modified polyes-
ter water-based material.
Observe electrostatic spray and
miscellaneous spray booths.
Aluminum patio doors and windows
are coated with a modified polyes-
ter water-based material.
i
Steel sheets for cans, the bulk
of the coating and decorating
materials are solvent-based.
Water-based inner coating materials
are also used.
i
Auto body repair shop which uses
solvent-based materials. Lacquer
is employed for touch-ups and
enamel for whole paint jobs.
Laminated doors are touched up with
an air dry enamel which is applied
with a manual spray.
Acrylic lacquer is used for re-
finishing doors and fenders.
Observe a typical plant spraying
operation.
To view add-on equipment which is
used to reduce hydrocarbon emis-
sions.
Plant uses a catalytic adsorber
and incineration.
Observe powder coating of bicycle
frames.
A-12
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Continental Can Co.
Portage, IN
Continental Can Co.
Weirton, WV
Earl Scheib Auto Body Shops
Providence, RI
Goodman Bros. Mfg. Co.
Philadelphia, PA
Burting Co.
Philadelphia, PA
Joy Manufacturing Co.
Michigan City, IN
Earl Scheib Auto Body Shops
West Haven, CT
Nordson Corp.
Amherst, OH
American Can Co.
Lemoyne, PA
Essex International
Fort Wayne, IN
H.D. Hudson Co.
Hastings, MN
Peachtree Door
St. Joseph, MO
REA Magnet Wire
Fort Wayne, IN
General Motors Corp.
Southgate, CA
General Motors Corp.
Van Nuys, CA
2/24/76 Discuss and observe the use of
incinerators.
2/25/76 Ultraviolet curing technology
employed at this plant.
2/25/76 Observe a typical auto refinishing
operation.
2/25/76 Metal hospital beds are powder
coated at this plant.
2/25/76 Observation of powder coating
outdoor metal furniture.
2/25/76 Observe spray painting of
compressor parts.
2/26/76 Observation of an auto refinishing
operation.
2/26/76 Pump components for spray equipment
are powder coated at this plant.
2/27/76 Observe and discuss the use of a
carbon adsorber for solvent
recovery.
3/4/76 Observe wire coating operations.
3/3/76 Insecticide spray equipment is
powder coated at this plant.
3/3/76 Observation of two finishing lines,
EDP and electrostatic spray
3/4/76 Magnet wire coating operation was
observed.
3/10/76 Water-based coating operations are
employed at this plant.
3/11/76 Water-based topcoating operations
are employed at this site.
A-13
-------
Table A-4 (continued)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Ford Motor Corp.
Milpitas, CA
American Motors Corp.
Mishawaka, IN
General Electric Co.
Schenectady, NY
Phelps Dodge Magnet Wire
Fort Wayne, IN
National Can Corp.
Danbury, CT
Chicago Magnet Wire
Elks Grove Village, IL
Dupont Corp.
Fairfield, CT
General Electrical Corp.
Louisville, KY
Hazen Paper Co.
Holyoke, MA
Brown-Bridge Mills
Troy, Ohio
Scott Graphics
South Hadley, MA
Fasson Co.
Painesville, OH
Chrysler Corp.
Belvidere, IL
3/12/76
3/15/76
3/16/76
3/19/76
3/24/76
I
4/7/76
4/30/76
5/4/76
5/19/76
6/30/76
7/1/76
7/14/76
10/12/76
Observation of typical coating
operations. Incinerators are
housed at this site (auto
and truck plant).
Bus manufacturing, observe coating
operations and gather general
information.
Observation of wire
coating operations
Observation of wire
coating operations
Observation of typical coating
operations of cans. Obtain
information on incinerators.
Observation of wire
coating operations.
To obtain information on botn
fabric coating and solvent emission
control by catalytic incineration.
Large appliances are powder coated
at this site. Observe EDP coating
facilities.
Solvent-based coating line equipped
with an incinerator.
:: . : : , •
To view the paper coating operation
and carbon adsorption system.
Discuss solvent recovery process
and observe the carbon adsorption
system and paper coating operation.
To view the paper coating operation
and carbon adsorption system.
Plant represents the typical adhe-
sives (solvent-based) operation.
A-14
-------
Table A-4 (concluded)
COMPANY/LOCATION
VISIT
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
General Motors Corp.
Ypsilanti, MI
Ford Motor Corp.
Dearborn, MI
Sebring-Vanguard Corp.
Sebring, FL
General Motors Corp.
Van Nuys/South Gate, CA
Ford Motor Corp.
Dearborn, MI
General Motors Corp
Oklahoma City, OK
10/10/76 Compact sized cars manufactured
at this site. Plant employs the
operation of typical adhesives.
11/11/76 Sporty compact cars manufactured
at this site. Typical adhesives
are used at this location.
3/1/77 Largest producer of electric cars
in the world. Determine the
ability of small automobile or
light-duty truck producers to
meet an NSPS that might be promul-
gated for the auto industry.
9/25 and Observe water-based painting
9/26/78 operations.
5/29 and Observe a pilot carbon adsorp-
5/30/79 tion program.
8/22 and Observe water-based coating
8/23/79 operations.
A-15
-------
Table A-5. MEETINGS WITH THE AUTOMOTIVE INDUSTRY'
Date
Association
or Firm
Other Attendees
a,b
Report Date
3/31/77
4/6/77
12/19/77
3/28/78
4/21/78
8/2/78
8/14/79
MVMA
GM
GM
GM
GM
Ford
GM
AMC, Chrysler
Corp., Ford Motor,
and GM
GM
4/4/77
4/14/77
1/10/78
4/3/78
5/18/78
8/29/78
8/17/79
aAll meetings were held in Durham, North Carolina unless specified otherwise,
and were attended by representatives of EPA.
bAMC - American Motors Corporation
GM - General Motors
MVMA - Motor Vehicle Manufacturers Association.
A-16
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APPENDIX
Location Within the Background
Information Document
iline for Preparing Regulatory Action
.al Impact Statements (39 FR 37419)
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The environmental and energy impai
proposed regulations are discusse
Chapter 7, Chapter 8, and Chapter
nomic impacts are discussed in Ch
Chapter 8. The inflationary impa
cussed in Chapter 1 and Chapter 8
economic impact is discussed in C
analysis should be sufficiently de-
ied to reveal the Agency's comparative
uation of the beneficial and adverse
ironmental, health, social, and eco-
ic effects of the proposed action and
each reasonable alternative.
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Section 111 of the Clean Air Act
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The legislative history of new so
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The proposed regulations are reqi
Clean Air Act amendments of 1977,
in Chapter 9.
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Secondary impacts are indirect or induce
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APPENDIX C
EMISSION SOURCE TEST DATA
The proposed standards of performance for automobile and light-duty
truck surface coating operations are based on the use of water-based coating
materials in the prime coat, guide coat, and topcoat operations. The
numerical emission limits, however, were not developed from actual stack
test data. Instead, they were based on determinations of the solvent
content of the coating material and the assumption that all the volatile
organic compounds (VOC) in the coating material is emitted into the atmos-
phere through the stacks.
Since two General Motors plants in California and one in Oklahoma are
currently operating with water-based coating materials, General Motors was
asked to supply EPA with a complete analysis of its coating materials.
Other manufacturers and vendors were also asked to supply additional infor-
mation on the coating materials used in the electrodeposition (EDP) prime
system. These sources provided the following type of information; volume
percent of each solvent, volume percent total solvent and solids, solvent
density, carbon atoms per molecule of solvent, and molecular weight for
each solvent. These data were then used to calculate a VOC content using a
procedure similar to proposed Reference Method 24 (Candidate 1). Hence,
the results from this calculation are the same as those which would have
been obtained if coating solids had been tested by proposed Reference
Method 24 (Candidate 1). The following equation was then used to calculate
the basic VOC emission level corresponding to this coating material.
-------
I (si Di Ni k/Mi)
C = : n
Where:
C
Si
Di
Ni
Mi
Mass of volatile organic carbon/volume of solid, g/1
Percent by volume of solvent component i.
i
Density of solvent component i, g/ml.
Moles of carbon atoms per mole of solvent component
•
Molecular weight of solvent component i, g/mole.
k = Constant = 12,000
g-i .
v_ =
mole-1
Percent by volume of solids.
In order to give credit for improved coating transfer efficiency,
which also reduces emissions, the proposed standards are written in terms
i
of volume of applied solids. Thus, the mass of carbon per unit volume of
solids in the coating material, as calculated above, is divided by the
weighted average transfer efficiency of the operation. EDP is considered
to be 100 percent efficient, while guide coat and topcoat operations range
from 40 to 95 percent efficient, depending upon the application method used
(see Section 4.2). In calculating the emission levels of the water-based
systems, a transfer efficiency of 40 percent was used for the guide coat
and topcoat operations.
For the cathodic EDP prime coat material analyses, the procedure
outlined above yielded a value of 0.10 kilogram of VOC (measured as mass of
carbon) per liter of coating solids. Since the transfer efficiency of an
C-2
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EDP system is considered to be 100 percent, the computed emissions are 0.26
kilogram of VOC (measured at mass of carbon) per liter of applied coating
solids.
The numerical value obtained from an analysis of the General Motors
guide coat material was 0.368. Dividing by the 40 percent transfer effi-
ciency for spraying water-based coatings yields a value of 0.92 kilogram of
VOC (measured as mass of carbon) per liter of applied coating solids.
Approximately 25 different coating formulations are used in the topcoat
operation at the General Motors water-based plants. For the analysis of
these materials, General Motors provided one formulation which represented
the average of all topcoat formulations. Analysis of this formulation
yielded a value of 0.34 kilogram of VOC (measured as total carbon) per
liter of coating solids. Dividing by the 40 percent transfer efficiency
resulted in predicted emissions of 0.84 kilogram of VOC (measured as total
carbon) per liter of applied coating solids.
Although several other factors were considered in the evolution of the
emission limits, the values obtained by this procedure were the basis for
the numerical emission limits for prime coat and topcoat in the recommended
standards. The emission limit for guide coat operations is proposed to be
the same as for topcoat operations. Since the guide coat is essentially a
topcoat material without pigment, it was decided that, with a transfer of
technology, the same emission level could be reached.
C-3
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APPENDIX D--EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS '
A. During the emission measurement program, data
were collected at the inlet and outlet of a gas-fired
thermal incinerator controlling the emissions from a first
body coat paint oven. The objective of this test was to
evaluate test procedures, as well as to determine the
efficiency of the control unit. Two different test methods
were used to simultaneously collect the organic compounds
emission data. During each test run, three repetitive
samples were taken with each test method to provide data
for determining the precision of the test procedures. The
two test procedures used were:
1. Total Combustion Analysis (TCA)J
2. Direct Flame lonization Analysis.
The sampling apparatus for the TCA method consisted
of a stainless steel probe, glass fiber filter,2 condensate
trap, and evacuated gas sample tank. The glass fiber filter
was maintained at 250°F and prevented any particulate matter
from entering the portion of the sampling apparatus that
was later analyzed for gaseous organics. The major portion
l._ Salo, A.E.; Oaks, W.L.; and MacPhee, R.D., Total
combustion Analysis. Air Pollution Control District,'County
of Los Angeles (August 1974).
2. Filter not used in the LAAPCD procedure.
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of the non-methane organics In the effluent was collected
in the condensate trap; any non-methane organics which
passed the condensate trap were collected in the evacuated
tank. Analysis consisted of oxidizing the entire trap
contents and a portion of the tank contents (after chromato-
graphic separation of CO, C02, and methane) to carbon dio-
xide followed by quantitative determination with a non-
dispersive infrared (NDIR) analyzer. The results were
reported as total gaseous non-methane organics (TGNMO) as
carbon (ppm C).
The Flame lonization Analysis procedure followed
during the test program utilized a commercially available
flame ionization analyzer to directly measure the gaseous
organics from the source after filtration. An integrated
bag sample was collected, and the methane content of the
effluent was determined by gas chromatography. total gase-
ous non-methane organics were quantitatively determined
from the total gaseous organics by subtracting the measured
methane.
Results of the test program indicated that the con-
" i' I- ' • "" _ '' : •. '•>$: ' ;,[;',". | '' , " ,:, ,
centrations obtained from the flame ionization analysis
technique were significantly lower than the concentrations
3. Emission Test Report: Ford Motor Company,
Pico Rivera, California, ESED Report No. 78-ISC-l.
D-2
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obtained by the TCA methods; this was particularly true
at the incinerator outlet. It is known that flame ioniza-
tion analyzers have a depressed response (compared to
methane) for certain species of organic compounds, espe-
cially oxygenated compounds. Therefore, it was not sur-
prising that the flame ionization analyzer gave lower
results than the TCA method at the incinerator outlet.
Due to possible inaccuracies caused by varying response
to different carbon species, the flame ionization techni-
que is not considered adequate for use as a reference
test method. Therefore, a modification of the TCA proce-
dure has been chosen as the reference method (see Section
D.3).
During the test program, one problem was encountered
with the application of the TCA method: Although precision
at the inlet location was good for all sample runs, very
poor precision was obtained for the first five test runs
conducted at the outlet sampling location. For these five
test runs, it was suspected that the condensate traps being
used were slightly contaminated by organics left as a
residual from the inlet sampling. Hence, special pre-
cautions were taken to assure that during analysis no resi-
dual was left in the condensate traps. Improved precision
among triplicate samples was obtained for the remaining
four test runs at the source outlet. The reference test
D-3
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method (see Section D.3) is a modified version of the
procedure used in the emission measurement program and
is expected to have improved precision at low emission
levels (less than 100 ppm C.).
B. The testing program for the volatile organic
content of automotive coatings was limited to evaluating
available procedures to determine their applicability to
a representative group of coatings.
At the beginning of the program, it was expected
that the standard would be expressed in terms of mass of
volatile organic compounds per volume of coating excluding
water. Industrial 'and literature sources were consulted
for methods to measure the volatile content. There were
no procedures that measured this quantity directly, but
there were ASTM methods that, when properly combined, could
be used to calculate the desired result. The methods that
were chosen for evaluation were ASTM D 2369-73, Standard Test
• , ' • " •• ff. > :"4; • :. " ; -
Method for Volatile Content of Paints, and ASTM D 1475-60,
Standard Test Method for Density of Paint, Varnish, Lacquer,
and Related Products. A group of coatings supplied by
industrial users were tested for volatile fraction using
ASTM D 2369-73. The experimental values were then com-
pared with formulation data supplied by the manufacturer.
In general, single determinations showed a great deal of
0-4
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variation, but when the procedure was performed in tripli-
cate and the results averaged, precision improved markedly.
Variation between triplicates was always less than 6 per-
cent and, in all cases except one, experimental values were
within 6 percent of the theoretical value. The density of
the various coatings was measured using ASTM D 1475-60.
Since there were no formulation data, no attempt was made
to determine the accuracy of the method. By combining the
results from the two methods, the mass of volatile organic
compounds per volume of solvent can be calculated.
A question remained about the effect of higher tempera-
tures and longer drying times than those specified in ASTM
D 2369-73 on the measured volatile organic, particularly
for coatings that were normally dried at elevated tempera-
tures. A number of the samples that had already been dried
according to ASTM D 2369-73 were heated to 350°F for an
additional hour. Most of these samples showed an additional
weight loss which was less than 5 percent. However, some
samples had an additional weight loss of as much as 30 per-
cent. This was apparently due to the formation of volatile
reaction products during the curing of the coating film.
Since there are a number of different coatings of this type,
each having its own curing procedure, it was decided that
for the present there would not be any attempt to measure
D-5
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this additional volatile organic material and the method
would limit its scope to the volatile organic contributed
by the solvent.
Another question that was raised concerned the measure-
ment of water in water reducible coatings, the standard pro-
cedure used by industry is the Karl Fischer titration which
.was developed to determine the water content of coatings
with 1 - 2 percent water. For water based coatings the
!
water content may be as much as 90 percent which is too
concentrated for'the procedure as written. A modified
Karl Fischer procedure was evaluated using a group of
water reducible coatings. The experimental values using
the modified procedure agreed well with the formulation
data but an additional problem remained. Since the
final result was to be expressed as the mass of volatile
organic compounds per volume of coating excluding water,
the water content had to be subtracted from the total vola-
tile mass and volume of coating. Thus relatively small
errors in measuring the water content could produce much
larger errors in the final result, depending on the relative
concentration of water and organic compounds in the solvent.
The issue of accurate water measurement and its effect on
the volatile organic content determination remains and is
currently under study by the ASTM.
D-6
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To by-pass the question of inaccuracies introduced
by the water determination and to make the measurement
of VOC content compatible with the method for determining
control device efficiency, it was decided to measure the
VOC content as equivalent organic carbon per volume of
solids. Thus, the standard was changed from mass of vola-
tile organic compounds per volume of coating to mass of
organic carbon per volume of solids.
Again there was a search for existing procedures to
make this measurement, but there was no single procedure
to do this directly. As a starting point, methods to
measure the volume of solids in the coating were evaluated.
There were only two available methods to measure the vol-
ume solids. One was ASTM D 2697-73, Standard Test Method
for Volume Non-Volatile Matter in Clear or Pigmented Coat-
ing. This procedure measures the volume of a thin paint
film by a weight displacement technique. The second method
used the ASTM methods already evaluated along with ASTM D
3272-76, Standard Recommended Practice for Vacuum Distilla-
tion of Solvents from Solvent-Base Paints for Analysis, to
calculate the volume solids. Since the other necessary ASTM
methods had already been evaluated and the distillation method
produced a clean solvent for the carbon content determination,
it was decided to evaluate the latter procedure.
0-7
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I
Both solvent reducible and water reducible coatings
were distilled using this procedure. After distillation
the density of the solvent was determined using ASTM D 1475-
60. No problems were encountered distilling the solvent ;
reducible coatings, but there were some problems with the •
water reducible ones. These coatings foamed on heating, !
spilling over into the collection flask, and the water in !
the distilled solvent froze in the collection flask stopping
the flow in the delivery line. It was found that the foam-
ing could be eliminated by adding a small amount of inorganic
antlfoam compound to the sample. An additional collection :
flask packed in an ice bath and placed in front of the collec- >
tlon flask in dry ice-acetone effectively prevented the
I
frozen delivery line. '.
As already noted an additional benefit, of the distillation
technique is that it provided a clean solvent sample which
could be analyzed for volatile carbon content. The analysis j
procedure involved catalytically oxidizing the sample to car- :
bon dioxide which Is then measured by a non-dispersive infrared
analyzer. Attempts to directly measure the volatile carbon coh
tent failed because of volatile losses during sample transfer.
However, the VOC content determined from the distilled solvent
and compared to the VOC calculated from the formulation data '
showed very good agreement. For a solvent reducible coating
the experimental value averaged about 1 percent lower than the
D-8
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calculated value, while for a water reducible coating the
results were about 5 percent lower.
Alternatively, if sufficient formulation data are
available, the VOC content per volume of solid can be cal-
culated. The simplest procedure, although not the only one,
uses the percent solids by volume and the percent of each
solvent constituent by volume to calculate the volatile
organic carbon content according to Equation 1.
Where:
C = Mass of volatile organic carbon/volume of solid,
9/1.
S. = Percent by volume of solvent component i.
D. = Density of solvent component i, g/ml.
N.. = Moles of carbon atoms per mole of solvent com-
ponent i.
M.. = Molecular weight of solvent component i, g/mole.
k
V.
Constant = 12,000—^1
mole-1
•s Percent by volume of solids.
This was the procedure used to collect the data on
which the standard is based.
It was concluded that the procedures evaluated would
be adequate for testing automotive coatings and that their
0-9
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combined results could be expressed as mass of volatile
organic carbon per volume of solids.
D.2 MONITORING SYSTEMS AND DEVICES
Since continuous monitoring requirements are not
being considered for this industry, discussion of avail-
able systems is not applicable.
D.3 PERFORMANCE TEST METHODS
A. "Determination of Total Gaseous Non-methane
Organic Emissions as Carbon" (TGNMO) is recommended as
the Reference Test Method. The sampling procedures of
,;, , ! . , :..,',' '';•;, , ; (• • ! . ' "'• ' "
the reference method are the same as those used in the
1 •'' "'!• i
emission measurement program except for the fact that
the reference method does not include a heated filter in
the sampling train. Deletion of the filter from the
sample train is not expected to alter the sampling results.
The analytical procedure of this method differ from |
that of the method used in the emission measurement pro-
gram. In the emission measurement program, the non-methane
organics were measured as carbon by oxidizing the non-methane
organics to carbon dioxide and subsequently determining the
carbon dioxide concentration with a NDIR Analyzer. The
Reference Method adds the additional step of reducing to
methane the carbon dioxide formed from the oxidation of
the organics; a flame ionization detector is used to quan-
tify the methane. This procedure was chosen over the NDIR
D-10
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procedure because an FID is simpler to calibrate and use
and has greater sensitivity. Use of the FID, in lieu of
the NDIR, for the analytical portion of this method is
expected to increase the precision of the test method at
low concentration levels (less than 100 ppm as carbon).
Since an increase in precision is the only effect expected
from this analytical change, the test data collected dur-
ing the emission measurement program are representative of
data which would be collected with the Reference Method.
Although a flame ionization detector is used as the
analytical instrument in the Reference Test Method, this
method differs greatly from use of a flame ionization
detector to.directly measure the organics in the source
effluent CDirect Flame Ionization Analysis). The proce-
dures of the Reference Method require that the sampled
gas first be conditioned by oxidation to carbon dioxide
and reduction to methane. Since the flame ionization
detector used in the reference method measures all the non-
methane organics as methane, all carbon atoms give an
equivalent instrument response. Therefore, the problem
of varying response ratios for different organic compounds
(typical of all flame ionization units) is avoided. The
TGNMO method gives a more accurate measurement of total
gaseous non-methane organics than the Flame Ionization
D-ll
-------
Method; this is the primary rationale for recommending
the TGNMO test procedure as the Reference Test Method.
B. "Determination of Volatile Content (as Carbon)
of Paint, Varnish, Lacquer, or Related Products" is
recommended as the Reference Test Method for measuring
the volatile content of automotive coatings.
D-12
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APPENDIX E
ENFORCEMENT ASPECTS
E.I ENFORCEMENT
The rules and regulations for determining if a source will be subject
to new source performance standards by reason that the source is new,
modified, or reconstructed, are given in Subpart A, Part 60, Subchapter C,
Chapter 1, Title 40, Code of Federal Regulations. It is suggested that
interpretation of the foregoing rules and regulations be reviewed through
the U.S. Environmental Protection Agency Regional Office Enforcement Divi-
sion for the region where a source will be located.
The locations and addresses of these regional offices are as follows:
Region I - Connecticut, Maine, Massachusetts, New Hampshire
Rhode Island,'Vermont
John F. Kennedy Federal Building
Boston, MA 02203
Telephone: 617-223-7210
Region II - New Jersey, New York, Puerto Rico, Virgin Islands
26 Federal Plaza
New York, NY 10007
Telephone: 212-264-2525
Region III - Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
Telephone: 215-597-9814
Region IV - Alabama, Florida, Georgia, Mississippi,
Kentucky, North Carolina, South Carolina,
West Virginia
345 Courtland, N.E.
Atlanta, GA 30308
Telephone: 404-881-4727
4. If add-on emission control is required, calculate the emission
reduction efficiency in VOC emissions which is required using the
equations included in the standards.
5. In cases where all exhaust gases are not .vented to an emission
control device, the percentage of total VOC emissions which enter
the add-on emission control device would have to be determined by
sampling all the stacks and using the equations included in the
standards. Representative sampling, however, could be approved
by the Administrator, on a case-by-case basis, rather than requiring
sampling of all stacks for this determination.
E-3
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Region V - Illinois, Indiana, Michigan, Minnesota,
Ohio, Wisconsin
230 South Dearborn
Chicago, IL 60604
Telephone: 312-353-2000
Region VI - Arkansas, Louisiana, New Mexico, Oklahoma, Texas
First International Building
1201 Elm Street
Dallas, Texas 75270
Telephone: 214-767-2000
Region VII - Iowa, Kansas, Missouri, Nebraska
1735 Baltimore Street
Kansas City, MO 64108
Telephone: 816-374-5493
Region VIII - Colorado, Montana, North Dakota,
C/Mi*h_HaJ^ota ILhaii Ux/nmlno
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