EPA-450/3-79-030
Automobile and  Light-Duty Truck
   Surface Coating Operations-
     Background Information for
         Proposed  Standards
          Emission Standards and Engineering Division
          U.S. ENVIRONMENTAL PROTECTION AGENCY
             Office of Air, Noise, and Radiation
          Office of Air Quality Planning and Standards
          Research Triangle Park, North Carolina 27711

                 September 1979

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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication.  Mention of trade
names or commercial products is not intended to constitute
endorsement or recommendation for use.   Copies of this report
are available through the Library Services Office (MD-35),
U. S. Environmental Protection Agency,  Research Triangle
Park, N. C.  27711, or from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
                 PUBLICATION NO.  EPA-450/3-79-030

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                         Background Information
                                and Draft
                     Environmental Impact Statement
               for Automobile and Light-Duty Truck Surface
                           Coating Operations

                     Type of Action:   Administrative

                             Prepared by:
Don R.  Goodwn
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C.  27711
                              Appro
                                                                7 //• <"/
                                                                  (Date)
David G. Hawkins
Assistant Administrator for Air, Noise and Radiation
Environmental Protection Agency
Washington, D. C. 20460

Draft Statement Submitted to EPA's
Office of Federal Activities for Review on
This document may be reviewed at:

Central Docket Section
Room 2903B, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460

Additional copies may be obtained at:

Environmental Protection Agency Library (MD-35)
Research Triangle Park, N. C.  27711

National Technical Information Service
5284 Port Royal Road
Springfield, Virginia  22161
                                                                  (Date)
                                                                  (Date)

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                             TABLE OF CONTENTS
Chapter
   1
SUMMARY  ......................
1.1    Proposed Standards  ... .  .  ...... .  .  .
1.2    Environmental, Energy and Economic Impacts
Page
1-1
1-1
1-2
          1.2.1  Background  .  ..,-..-. .... .- •. -. . . ••:•'• • • •  1"2
          1.2.2  Impacts	  . •,.:.:• ,-,.•..• • • •  1-5
          1.3   , Inflationary Impact .  .   ......... .	1-8
          INTRODUCTION                  ;
          2.1    Authority for the Standards ...'.""	2-1
                 Selection of Categories  of Stationary Sources . . .  2-5
2.2
2.3
                 Procedure for Development of Standards of
                 Performance	 . ... . . . .  2-8
          2.4    Consideration, of Costs  .. ... ...:.....  . .  .  2-10
          2.5    Consideration of Environmental Impacts  ... ...  . .  .  2-12
          ,2.6    Impact on Existing Sources  .. ... .  ...  . •  •  2-13
          2.7    Revision of Standards of Performance. .  . . ...  . .  .  2-14
          THE AUTOMOBILE AND LIGHT DUTY TRUCK INDUSTRY ....  . .  .  3-1
          3,1    General Description ..... ... .  .  . .......  3-1
          3.1.1  Automobile Industry ................  3-1
          3.1.2  Truck Industry	  ...  ........  3-7
          3.2    Processes or Facilities and Their  Emissions  .  . .  .  3-14
          3.2.1  The Basic Processes - Automobile Industry 	  3-14
          3.2.2  The Basic Processes - Light-Duty Truck  Industry .  .  3-30

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                      TABLE OF CONTENTS (Continued)


Chapter
                                                                      i
   4      EMISSION CONTROL TECHNIQUES  	   4-1 ,

          4.1    General	4-1

          4.2    The Alternative Emission Control  Techniques ....   4-2

          4.2.1  Water-Based Coatings  	   4-2
                                                                      i

          4.2.2  Powder Coating	4-13

          4.2.3  New Coating Development	4-15

          4.2.4  Carbon Adsorption 	   4-19

          4.2.5  Incineration	4-22

          4.3    Emission Reduction Performance of Control
                 Techniques	4-32

          4.3.1  General	4-32

          4.3.2  Electrodeposition of Water-Based Coating	4-33

          4.3.3  Water-Based Spray 	   4-34

          4.3.4  Powder Coating-Electrostatic Spray  	   4-38

          4.3.5  Higher Solids Coatings	   4-38

          4.3.6  Carbon Adsorption	 .'	4-42

          4.3.7  Incineration	4"42

   5      MODIFICATIONS AND RECONSTRUCTIONS	   5-1

          5.1    Background	5-1

          5.2    Potential Modifications 	  	   5-2
                                                                      I
          5.3    Reconstructions	5-5

   6      EMISSION  CONTROL SYSTEMS 	  	   6-1

          6.1    General	6-1
                                                                      I
          6.2    Base  Case	6-2
                                                                      i
          6.3    Regulatory Options   	   6-2
                                      n

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                       TABLE OF CONTENTS (Continued)

Chapter                                  :
   7      ENVIRONMENTAL IMPACT .  .  .  .	'.'....'	7-1
          7.1    Air Pollution Impact	7-1
          7.1.1  General	•  •  •   7-1
          7.1.2" State Regulations and Controlled Emissions  ....   7-3
          7.1.3  Comparative Emissions from Model  Plants
                 Employing Various Operating Options 	   7-5
          7.1.4  Estimated VOC Emission Reduction
                 in Future Years	7-10
          7.2    Water Pollution Impacts 	   7-14
          7.2.1  Ultrafiltration . .	7-14
          7.2.2  Dripping, Spills, and Cleanup 	   7-14
          7.2.3  Dragout	7-15
          7.2.4  Overspray Removal	  -   7-15
          7.3    Solid Waste Disposal Impact . . .	7-16
          7.4    Energy Impact	7-19
          7.5    Other  Environmental Impacts ...  	   7-28
          7.6    Other  Environmental Concerns	   7-28
          7.6.1  Irreversible and Irretrievable Commitment
                 of Resources	7-28
          7.6.2  Environmental Impact of Delayed Standards  	   7-30
          7.6.3  Environmental Impact of No Standards   	   7-30
    8     ECONOMIC  IMPACT   	  ...........   8-1
          8.1    Industry  Economic Profile	   8-2
          8.1.1  Role of the  Motor Vehicle  Industry
                 in the U.S.  Economy	8-2
          8.1.2  Structure of the Industry	   8-3

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                       TABLE OF CONTENTS (Continued)
Chapter
Page
          8.1.3  Projected Demand  	   8-20

          8.1.4  Determination of Existing Capacity  	   8-21

          8.1.5  Determination of New Sources  .	8-26

          8.2    Cost Analysis	8-27

          8.2.1  Introduction	8-27

          8.2.2  Capital  Cost of Control  Options	8-30

          8.2.3  Annualized Cost of Control  Options	8-39

          8.2.4  Cost-Effectiveness of the Control  Options 	   8-55

          8.2.5  Control  Cost Comparison    	8-67

          8.2.6  Base Cost of the Facility	8-68
                                                                      !
          8.3    Other Cost Considerations	8-75

          8.4    Potential Economic Impact 	   8-75

          8.4.1  Grass Roots New Lines   	8-75

          8.4.2  Control  Costs   	8-75

          8.4.3  Potential Price Effect	'	8-81

          8.4.4  Sensitivity Analysis  	   8-83

          8.5    Potential Sociceconomic  and
                 Inflationary Impacts  	  	   8-84

   9      RATIONALE	9-1

          9.1    Selection of Source and  Pollutants	9-1

          9.2    Selection of Affected Facilities   	   9-3

          9.3    Selection of Best System of
                 Emission Reduction  	   9-5

          9.3.1  Control  Technologies	9-5

          9.3.2  Regulatory Options  	   9-8

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                       TABLE OF CONTENTS (Continued)
Chapter
                                                            Page

9.3.3  Environmental, Energy and Economic
       Impacts	9-9
          9.3.4  Best System of Emission Reduction	9-18

          9.4

          9.5

          9.6

          9.7
       Selection of Format for the
       Proposed Standards	   9-19
       Selection of Numerical Emission Limits  	   9-21

       Selection of Monitoring Requirements  	   9-26

       Performance Test Methods	   9-27
          9.8
       Modifications and Reconstructions 	  ....   9-28
APPENDIX A (Evolution of Proposed Standards) 	   A-l

APPENDIX B (Index to Environmental Impact
            Considerations)	B-l

APPENDIX C (Emission Source Test Data) .  .	   C-l

APPENDIX D (Emission Measurement and
            Continuous Monitoring) .	D-l

APPENDIX E (Enforcement Aspects)	   E-l

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                              LIST OF FIGURES
Figure

 3-1      Automobile Production Trends ...............   3-8

 3-2      Traditional Coating Operations of an Automobile
          and Light-Duty Truck Assembly Line ............   3-15

 3-3      Flow Diagram - Application of Solvent-Based Primer
          and Topcoat - Automobile and Light-Duty Truck Bodies .  .  .   3-18

 4-1      Typical Electrodeposition System .............   4-5
                                           1 •                          !
 4-2      Forced-Draft System Eliminating Solvent Vapors from
          Surface Coating Process  ...... ......  .....   4-24

 4-3      Coupled Effects of Temperature and Time on Degree of
          Pollutant Destruction  ..................   4-26

 4-4      Schematic Diagram of Catalytic Afterburner Using
          Torch-Type Preheat Burner with Flow of Preheated
          Process Vapors Through a Fan to Promote Mixing ......   4-29

 4-5      Effect of Temperature on Oxidation Conversion of Organic
          Vapors in a Catalytic Incinerator  ............   4-31
                                                                      |
 4-6      Emission Reduction Potential (Percent) Versus Solids
          Content of Higher Solids Coatings Placing 16 Volume Percent
          Lacquers (50 Percent Deposition Efficiency)  . .....  .   4-40

 4-7      Emission Reduction Potential (Percent) Versus Solids
          Content of Higher Solids Coatings Placing a 28 Volume
          Percent Enamel (50 Percent Deposition Efficiency) .....   4-41

 8-1      Available Options for Control of VOC Emissions
          Due to the Painting of Automobiles and Light-Duty
          Trucks ..........................   8-28

 8-2      Cost Differential - Control Option 1A for Guide
          Coat and Topcoat, Water-Based Enamel Versus Solvent-
          Based  Enamel .......................   8-50

 8-3      Cost Differential - Control Option 1A for Guide
          Coat and Topcoat, Water-Based Enamel Versus Solvent-
          Based  Lacquer  ......................   8-50

 8-4      Cost Effectiveness of Water-Based Control Options   .* . . .   8-65

 8-5      Cost Effectiveness of Incineration Control Options  ....   8-66

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                        LIST OF FIGURES (Continued)
Figure

 8-6


 8-7


 8-8
Comparison of Purchase Prices of Catalytic
Incinerators with Primary Heat Recovery  .
Comparison of Purchase Prices of Thermal
Incinerators with Primary Heat Recovery
Comparison of Purchase Prices of Thermal
Incinerators with Primary and Secondary Heat
Recovery 	  	
Page


8-69


8-70



8-71
                                      vn

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                              LIST OF TABLES
Table

 1-1


 3-1

 3-2

 3-3

 3-4

 3-5


 3-6

 3-7


 3-8

 3-9


 3-10


 3-11


 3-12


 3-13


 3-14


 3-15


 3-16


 3-17
                                                            :Page
                                                            I

Matrix of Environmental and Economic Impacts of
Regulatory Options (Alternatives)  	   1-9

Direct Employment in the Production of Automobiles ....   3-2

Share of Total U.S.  Production	3-3

Automobile Assembly Plant Production Model Year 1977 .  .  .   3-4

Automobile Assembly Plants Model Year 1978 . 	   3-6

1975 U.S. Truck and Bus Factory Sales by Body Types
and Gross Vehicle Weight, Pounds 	   3-10
Light-Duty Truck Assembly Plant Model Year 1975
3-11
Light-Duty Truck Assembly Plant Locations
Model Year 1978	3-12

Estimated Light-Duty Truck Production  .  	  3-13

Energy Balance of Prime Coat Applications for
Automobiles	3-20
                                                            i
Material Balance for Spray Application of
Solvent-Based Primer to Automobiles  	  3-21

Material Balance for Spray Application of
Solvent-Based Enamel Topcoat to Automobiles  	  3-22

Energy Balance for Application of Solvent-Based
Enamel Topcoat to Automobiles  	  3-24

Average Emissions for Automobile Surface Coating
Operations   	3-28

Average Solid Waste Generated for Automobile
Surface" Coating Operations	3-29

Material Balance for Spray Application of
Solvent-Based Primer to Light-Duty Trucks  	  3-32

Energy Balance of Prime Coat Applications or
Solvent-Based Primer to Light-Duty Trucks  	  3-33
Material Balance for Spray Application of
Solvent-Based Enamel Topcoat to Light-Duty Trucks
                                                                      3-34
                                    vm

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                        LIST OF TABLES (Continued)
Table                                                                 Page
 3-18     Energy Balance for Application of Solvent-Based
          Enamel Topcoat to Light-Duty Trucks  	  ....   3-35
 3-19     Average Emissions for Light-Duty Truck Surface
          Coating Operations	   3-36
 3-20     Average Solid Waste Generated for Light-Duty Truck
          Surface Coating Operations 	   3-38
 4-1      Water-Based Coatings 	   4-3
 4-2      Theoretical Emission Reduction Potential Associated
          with Various New Coating Materials for Use as
          Automobile Body Coatings	4-36
 6-1      Automobile and Light-Duty Truck Surface Coating Lines
          Emission Control Options Evaluated 	   6-4
 7-1      Operating Options	   7-6
 7-2      Uncontrolled and Controlled Emissions from Automobile
          Surface Coating Operations 	   7-7
 7-3      Uncontrolled and Controlled Emissions From Light-Duty
          Truck Surface Coating Operations	7-9
 7-4      Automobile Emissions Projections	 .   7-12
 7-5      Light-Duty Trucks Emissions Projections	   7-13
 7-6      Energy Balance - Base Case Model and Process Modifica-
          tion, Automobile Body Primer Application   	   7-20
 7-7      Energy Balance - Add-On Emission Control Systems,
          Automobile Body Primer Application 	   7-21
 7-8      Energy Balance --' Base Case Model and Process Modifica-
          tion, Automobile Body Topcoat Application  ... 	   7-22
 7-9      Energy Balance - Add-On Emission Control Systems,
          Automobile Body Topcoat Application  	   7-23
 7-10     Energy Balance - Base Case Model and Model Process
          Modification, Light-Duty Truck Body Primer Application  . .   7-24
 7-11     Energy Balance - Add-On Emission Control Systems,
          Light-Duty Truck Body Primer Application 	   7-25

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                        LIST OF TABLES (Continued)
Table

 7-12


 7-13


 7-14

 8-1

 8-2

 8-3


 8-4


 8-5


 8-6


 8-7


 8-8


 8-9


 8-10



 8-11


 8-12

 8-13


 8-14
Energy Balance - Base Case Model and Process Modifica-
tion, Light-Duty Truck Body Topcoat Application  .  .  .
Page


7-26
Energy Balance - Add-On Emission Control Systems,
Light-Duty Truck Body Topcoat Application  	   7-27

Summary of Energy Requirements from Regulatory Options .  .   7-29

North American Automobile Assembly Locations 	   8-6

North American Light-Duty Truck Assembly Locations ....   8-8

U.S. and Canadian Projected Demand for North American-
Made Passenger Cars 1978-1983  	   8-22

Projected U.S. and Canadian Demand for North American-
Made Light-Duty Trucks 1978-1983	   8-23

Estimated Passenger Car Production Capacity
in North America, 1978	8-24
Estimated Light-Duty Truck Production Capacity
in North America, 1978 	
8-25
Average Solvent-Based Paint Usage for Automobile
and Light-Duty Truck Bodies  	 	  8-31

Coating Equipment Requirements in a Plant Producing
55 Vehicles Per Hour	8-32

Turnkey Costs of Automobile and Light-Duty Truck
Coating Equipment Costs   	  8-33

Incremental Capital Costs of Water-Based Guide Coat
and Topcoat System Versus Conventional  Solvent-Based
Systems, Guidecoat   	  8-35

Technical  Parameters Used in Developing Costs of
Incinerators for Control  System   	  	  8-36
                                                            i
Delivered  Cost of Exhaust Gas  Incinerators  	  8-38

Capital Costs of Control  Option IB-T  for Surface
Coating of Automobiles	8-40

Capital Costs of Control  Option IB-C  for Surface
Coating of Automobiles  	  8-41

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                        LIST OF TABLES (Continued)
Table                                                                 Page

 8-15     Capital Costs of Control Option II-T for Surface
          Coating of Automobiles	8-42

 8-16     Capital Costs of Control Option II-C for Surface
          Coating of Automobiles 	   8-43

 8-17     Capital Costs of Control Option IB-T for Surface
          Coating of Light-Duty Trucks 	   8-44

 8-18     Capital Costs of Control Option IB-C for Surface
          Coating of Light-Duty Trucks 	   8-45

 8-19     Capital Costs of Control Option II-T for Surface
          Coating of Light-Duty Trucks .... 	   8-46

 8-20     Capital Costs of Control Option II-C for Surface
          Coating of Light-Duty Trucks 	 	   8-47

 8-21     Cost Factors Used in Computing Annualized Costs
          for Control Options, 1977 values	8-48

 8-22     Incremental Annualized Costs of Control Option IA for
          Surface Coating of Automobiles	 .   8-52

 8-23     Incremental Annualized Costs of Control Option IA for
          Surface Coating of Light-Duty Trucks ... .  .	   8-53

 8-24     Incremental Annualized Costs of Control Option IB-T
          for Surface Coating of Automobiles  ...... 	 8-56

 8-25     Incremental Annualized Costs of Control Option IB-C
          for Surface Coating of Automobiles  ............   8-57

 8-26     Incremental Annualized Costs of Control Option II-T
          for Surface Coating of Automobiles  	   8-58

 8-27     Incremental Annualized Costs of Control Option II-C
          for Surface Coating of Automobiles  	   8-59

 8-28     Incremental Annualized Costs of Control Option IB-T
          for Surface Coating of Light-Duty Trucks  . ..  ,	8-60

 8-29     Incremental Annualized Costs of Control Option IB-C
          for Surface Coating of Light-Duty Trucks  	   8-61

 8-30     Incremental Annualized Costs of Control Option II-T
          for Surface Coating of Light-Duty Trucks  	   8-62

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                        LIST OF TABLES (Continued)
Table
 8-31

 8-32

 8-33

 8-34
 8-35

 8-36

 8-37
 8-38

 8-39
 9-1

 9-2
 9-3

 A-l
 A-2
 A-3
 A-4
 A-5
                                                            Page
Incremental Annualized Costs of Control Option II-C
for Surface Coating of Light-Duty Trucks 	   8-63
Aggregate Lengths of Spray Booths, Flash-Off Tunnels
and Ovens for Paint Shops Handling 55 Vehicle Per Hour .  .   8-73
                                               1
Base Cost of an Automobile and Light-Duty Truck Paint
Shop That Uses Solvent-Based Enamel	8-74
Base Cost of an Automobile and Light-Duty Truck Paint
Shop That Uses Solvent-Based Lacquer	8-74
                                         •                   !
Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Passenger Car - GM)	8-76
Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Light-Duty Trucks - GM) .
Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Light-Duty Trucks - Ford)
Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Passenger Car - Chrysler)
8-77
I

8-78
]

8-79
Inflationary Impact Assessment, 1983 	  8-85
                                                            i
Automobile and Light-Duty Truck Surface Coating Lines -
Emission Control Options Evaluated . .	  9-10
Incremental Control Costs
(Compared to the Cost of Lacquer Plant)	9-15
Incremental Control Costs
(Compared to the Cost of Enamel Plant)	9-16
Major Events, Year 1974-Mid 1978	  A-2
Suppliers and Manufacturers Contacted  . , 	  A-5
State Agencies Contacted 	  A-6
Surface Coating Operations Visited . .	  A-7
Meetings with the Automotive Industry	A-16
                                     xn

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                                1.   SUMMARY
1.1  PROPOSED STANDARDS
     Standards of performance for automobile and light-duty truck surface
coating operations have been proposed under Section 111 of the Clean Air
Act.   The proposed standards would limit emissions of volatile organic
compounds (VOC) from new, modified, and reconstructed facilities.   Volatile
organic compounds are organic compounds which participate in atmospheric
photochemical reactions or are measured by the proposed Reference Methods 24
(Candidates 1 and 2) and 25.
     Numerical emission limits for each "affected facility" have been
selected as follows:

     0.10 kilogram of VOC (measured as mass of carbon) per liter of applied
     coating solids from each prime coat operation
     0.84 kilogram of VOC (measured as mass of carbon) per liter of applied
     coating solids from each guide coat operation
     0.84 kilogram of VOC (measured as mass of carbon) per liter of applied
     coating solids from each topcoat operation

these limits are based on the use of water-based coating materials in the
prime coat, guide coat, and topcoat operations.  Usually water-based prime
coat is applied by electrodeposition (EDP).  A transfer efficiency of
40 percent is assumed for spray application of these coatings.  The emission
limits may also be achieved by using add-on control devices, such as thermal
or catalytic  incineration, to reduce VOC from solvent-based coatings.
     Reference Method 24 (Candidate 1), "Determination of Volatile Content
(as Carbon)  of Paint, Varnish, Lacquer, or  Related Products," has been

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proposed in two forms - Candidate 1 and Candidate 2.   Candidate 1 leads to
a determination of VOC content expressed as the mass of carbon.  Candidate 2
yields a determination of VOC content measured as mass of volatile organics.
                                                                       ]
The decision as to which candidate will be used depends on the final format
selected for the proposed standards.  Reference Method 25, "Determination
of Total Gaseous Nonmethane Organic Emissions," has been proposed as the
test method to determine the percentage reduction of VOC emissions achieved
by add-on control devices.
1.2  ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS
     The 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 controls, or a combination of the two.  Low organic
solvent coatings consist of water-based enamels, high solids enamels, and
                                                                       i
powder coatings.  Add-on controls consist of such techniques as incineration
and carbon adsorption.
1.2.1  Background
     New Coatings.  Water-based coating materials are applied  either by
conventional spraying  or by EDP.  In the EDP process the  automobile or
light-duty truck to be coated  is dipped into a bath containing a dilute
water  solution of the  coating  material.  When  charges of  opposite polarity
are applied  to the dip tank and vehicle, the coating material  deposits on
the latter.  As  the  coating material deposits  on the surface,  it acts  as  an
insulator  between the  bare metal surface and the EDP tank, thus  limiting
the film thickness which  can be applied by  EDP.  Consequently, EDP  is
limited to application of prime coats,  and  spraying  is  used  for  guide  coat
and topcoat  application of water-based coatings.   Currently,  nearly half  of
                                   1-2

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the domestic automobile assembly plants use EDP for prime coat application,
but only two domestic plants use water-based coatings for guide coat and
topcoat applications.
     High solids coatings, which include coatings of 45 to 60 percent
solids, are being developed by a number of companies.  While high solids
coatings have the potential for use in the automotive industry, there are
problems which must be overcome.  These coatings have a high working vis-
cosity which makes them unsuitable for use in many existing application
devices.  There are also some problems with the finish produced by high
solids coatings.  Since the viscosity of the material is very high, it
often produces an "orange peel," or uneven, surface.  High solids coatings
are also limited because metallic finishes cannot be applied.  However,
techniques such as heated application are being investigated to reduce
these problems, and it is expected that by 1982, high solids coatings will
be considered 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.
     Add-on Controls.  Incineration may be either thermal or catalytic.
Thermal  incineration has been used to control emissions from bake ovens in
automobile and light-duty truck assembly plants because of the fairly low
volume and high VOC  concentration in the exhaust stream.  These units
                                  1-3

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normally achieve a VOC emissions 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) very low in concentration of
VOC (about 50 ppm).  Thermal incineration of this exhaust stream would
require a large amount of supplemental fuel, either oil or natural gas.
There are, however, no technical problems with the use of thermal incineration.
     Catalytic incineration permits lower incinerator operating temperatures
and, therefore, requires about 50 percent less energy than thermal inciner-
ation.  While catalytic incineration is not currently being employed in the
automobile and light-duty truck industry for control of VOC emissions,
there are no major technical problems which would preclude its use on bake
oven exhaust gases.  However, catalytic incineration requires the use of
                                                                      i
natural gas to preheat the exhaust gases since oil firing tends to foul the
catalyst.  With regard to spray booth emission control, the same consider-
ations apply as in the case of thermal incineration (i.e., a high energy
impact and requirement for use of natural gas, whose future availability
for incinerator use is questionable).
     Carbon adsorption has been used successfully to control VOC emissions
                                                                      i
in a number of small industrial applications.  However, the ability of
                                                                      !
carbon adsorption to control VOC emissions from spray booths and bake ovens
in automobile and light-duty truck surface coating operations is uncertain.
The high volume/low VOC exhaust streams from spray booths would require
carbon adsorption units much larger than any that have ever been built.
Work is continuing, however, on efforts to apply carbon adsorption to the
automotive industry, and it may become a demonstrated technology in the
future.
                                  1-4

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     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
two VOC emission control techniques, two regulatory options were evaluated.
The two options are summarized in the following paragraphs.  In both options,.
the prime coat is water-based and applied by EDP.
     Regulatory Option I includes two alternatives which achieve essen-
tially equivalent control of VOC emissions.   Alternative A is based on the
use of a water-based prime coat, guide coat,  and topcoat.  Alternative B is
based on the use of water-based prime coat and a solvent-based guide coat
and topcoat with incineration of the exhaust gas stream from the topcoat
spray booth and bake oven to control emissions.
     Regulatory Option II is based on the use of a water-based prime coat
and a solvent-based guide coat and topcoat.   In this option, the exhaust
gas streams from both the guide coat and topcoat spray booths and bake
ovens are incinerated to control emissions.
1.2.2  Impacts
     the incremental impacts of the proposed standards would be determined
by the final emission limitations adopted by the State Implementation Plans
(SIPs) which are currently being revised.  The impacts presented throughout
this document were evaluated using the SIPs in existence at the end of 1978
as a basis.  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 an automobile or light-duty truck assembly plant
using solvent-based coatings with no add-on control devices.  Growth
                                  1-5

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projections indicate there will be four new automobile assembly plants
constructed by 1983.  Based on this assumption, it is estimated that by
1983 national emissions of VOC would be reduced by about 4,800 metric tons
per year with standards based on Regulatory Option I, or about 5,400 metric
tons per year with standards based on Regulatory Option II.   Thus,  both
regulatory options would result in a significant reduction in emissions of
                                                   i,                    i
VOC from automobile and light-duty truck surface coating operations.
     With regard to the water pollution impact, standards of performance
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 Regulatory Option I(A),, however, would result
in a slight increase in the chemical oxygen demand (COD) of wastewater
being generated from automobile and light-duty truck assembly plants.
However, the increase in COD under Regulatory Option I(A) would be small
relative to current COD levels at plants meeting existing SIP's, and would
not result in a significant increase in the water treatment requirements.
     The solid waste impact of the proposed standards would be negligible.
The volume of sludge generated from water-based coating operations is
approximately the same as that generated from a solvent-based operation.
The solid waste generated from solvent-based coatings, however, is 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
conventional landfill procedures without leachate problems.
     With regard to the energy impact, standards of performance 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
                                  1-6

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by the equivalent of about 18,000 barrels of fuel oil per year, representing
an additional 25 percent over the current annual consumption rate.  Regula-
tory Option I(B) would cause an increase of about 150 to 425 percent in
energy consumption, equivalent to 100,000 to 300,000 barrels of the oil per
year.  Standards based on Regulatory Option II would result in an increase
of 300 to 700 percent in energy consumption, representing an additional
200,000 to 500,000 barrels of fuel oil per year.  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, and the
ranges reflect the difference between catalytic and thermal incineration.
     In determining the economic impacts of the proposed standards, costs
were estimated for applying each control option to the four new assembly
lines which are expected to be built by 1983.  Of these four lines, two are
General Motors lines (one passenger car and one light-duty truck), one is a
Ford light-duty truck line, and the other is a Chrysler passenger car line.
In the absence of any air pollution regulations, General Motors plants
would be designed to use solvent-based lacquer coatings in guide coat and
topcoat; Ford, Chrysler, and all other manufacturers would use solvent-
based enamels in guide coat and topcoat.
     Capital costs for the four new facilities planned by 1983 would be
increased by approximately $19 million as a result of the proposed standards.
This incremental capital cost for control represents about 0.2 percent of
the  $10 billion planned for capital expenditures during the same time
period.  The corresponding annualized costs would be increased by approxi-
mately $9 million  in 1983.  The price of an automobile or  light-duty truck
manufactured at a  new plant which complies with the  proposed standards of
performance would  be increased by much  less than 1 percent.
                                   1-7

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1.3  INFLATIONARY IMPACT
     The projected economic impacts of each alternative control  system are
small, and the costs of the proposed standards of performance should not
preclude future construction of coating lines.  Effects on production of
automobiles and light-duty trucks and on employment should be insignificant.
     Total investment costs are projected to be approximately $19 million.
                                                                      i
The fifth-year annualized costs, including depreciation and interest, are
estimated at approximately $9 million.  The maximum anticipated unit price
increase is much less than 1 percent.  Therefore, the Agency feels that an
economic impact analysis is not required.
                                   1-8

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                             2.   INTRODUCTION
     Standards of performance are proposed following a detailed investigation
of air pollution control methods available to the affected industry and the
impact of their costs on the industry.   This document summarizes the informa-
tion obtained from such a study.  Its purpose is to explain in detail the
background and basis of the proposed standards and to facilitate analysis
of the proposed standards by interested persons, including those who may
not be familiar with the many technical aspects of the industry.
2.1  AUTHORITY FOR THE STANDARDS
     Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, here-
after referred to as the Act.  Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which "... causes or contributes significantly to
air pollution which may reasonably be anticipated to endanger public health
or welfare."
     The Act requires that standards of performance for stationary sources
ref>ect "... the degree of emission limitation achievable through the
application of the best technological system of continuous emission reduc-
tion . . . the Administrator determines has been adequately demonstrated."
The Act also provides that the  cost of achieving the necessary  emission
reduction, the nonair quality health and environmental impacts, and the
energy requirements all be taken into account in establishing standards of
performance.  The standards  apply only to stationary sources, the construc-
tion or modification of which commences after regulations are proposed by
publication in the FEDERAL REGISTER.

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     The 1977 amendments to the Act altered or added numerous provisions
which apply to the process of establishing standards of performance.
     1.   EPA is required to list the categories of major stationary sources
          which have not already been listed and regulated under standards
          of performance.  Regulations must be promulgated for these new
          categories on the following schedule:
               25 percent of the listed categories by August 7, 1980
               75 percent of the listed categories by August 7, 1981
               100 percent of the listed categories by August 7, 1982
          A Governor of a State may apply to the Administrator to add a
          category which is not on the list or to revise a standard of
                                                                      I
          performance.
     2.   EPA is required to review the standards of performance every
          4 years and, if appropriate, to revise them.
     3.   EPA is authorized to promulgate a design, equipment, work practice,
          or operational standard when an emission standard is not feasible.
     4.   The term "standards of performance" is redefined and a new term
          "technological system of continuous emission reduction" is defined.
          The new definitions clarify that the control system must be
          continuous and may include a low-polluting or nonpolluting pro-
          cess or operation.
     5.   The time between the proposal and promulgation of a standard
          under Section 111 of the Act may be extended to 6 months.
     Standards of performance, by themselves, do riot guarantee protection
 of  health or welfare because they are not designed to achieve any specific
 air quality levels.  Rather, they are designed to reflect the degree of
                                   2-2

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emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
nonair quality health and environmental impact, and energy requirements.
     Congress had several reasons for including these requirements.  First,
standards with a degree of uniformity are needed to avoid situations in
which some States may attract industries by relaxing standards relative to
other States.  Second, stringent standards enhance the potential for long-term
growth.  Third, stringent standards may help achieve long-term cost savings
by avoiding the need for more expensive retrofitting if pollution ceilings
are reduced in the future.  Fourth, certain types of standards for coal
burning sources can adversely affect the coal market by driving up the
price of low-sulfur coal or effectively excluding certain coals from the
reserve base because their untreated pollution potential is high.  Congress
does not intend for new source performance standards to contribute to these
problems.  Fifth, the standards setting process should create incentives
for improved technology.
     Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources.  States are free under Section 116 of the Act to establish
even more  stringent emission limits than those established under Section 111
or those necessary to attain or maintain the national ambient air  quality
standards  (NAAQS) under  Section 110.   Thus, new sources may in some cases
be subject to  limitations more stringent than  standards of performance
under  Section  111, and prospective  owners  and  operators of new sources
should  be  aware  of this  possibility in planning for  such  facilities.
                                   2-3

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     A similar situation may arise when a major emitting facility is to be
constructed in a geographic area which falls under the prevention of signi-
ficant deterioration of air quality provisions of Part C of the Act.  These
provisions require, among other things, that major emitting facilities to
be constructed in such areas be subject to best available control technology.
The term "best available control technology" (BACT), as defined in the Act,
means ". . .  an emission limitation based on the maximum degree of reduction
of each pollutant subject to regulation under this Act emitted from or
which results from any major emitting facility, which the permitting authority,
on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such facility
through application of production processes and available methods, systems,
and techniques, including fuel cleaning or treatment or innovative fuel
combustion techniques for control of each such pollutant.  In no event
shall application of best available control technology result in emissions
of any pollutants which will exceed the emissions allowed by any applicable
standard established pursuant to Section 111 or 112 of this Act"
(Section 169(3)).
     Although standards of performance are normally structured in terms of
numerical emission limits where feasible, alternative approaches are some-
times necessary.  In some cases, physical measurement of emissions from a
new source may be impractical or exorbitantly expensive.  Section lll(h)
provides that the Administrator may promulgate a design or equipment stan-
                                                                      i
dard in those cases where it is not feasible to prescribe or enforce a
standard of performance.  For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
                                  2-4

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The nature of the emissions—high concentrations for short periods during
filling and low concentrations for longer periods during storage—and the
configuration of storage tanks make direct emission measurement impractical.
Therefore, a more practical approach to standards of performance for storage
vessels has been equipment specification.
     In addition. Section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology.  In order to grant the waiver, the Administra-
tor must find:  (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards require, or an
equivalent reduction at lower economic, energy or environmental cost;
(2) the proposed system has not been adequately demonstrated; (3) the
technology will not cause or contribute to an unreasonable risk to public
health, welfare or safety; (4) the Governor of the State where the source
is located consents; and (5) the waiver will not prevent the attainment or
maintenance of any ambient standard.  A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS.  Any such
condition will have the force of a performance standard.  Finallyt waivers
ha'e definite end dates and may be terminated earlier if the conditions are
not met or if the system fails to perform as expected.  In such a case, the
source may be given up to 3 years to meet the standards, with a mandatory
progress schedule.
2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
     Section  111 of the Act directs the  Administrator to list categories of
stationary sources.  The Administrator ". . . shall include a category of
sources in such a list if  in his judgment it causes, or contributes
                                   2-5

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significantly to, air pollution which may reasonably be anticipated to

endanger public health or welfare."  Proposal and promulgation of standards

of performance are to follow.
                                 i
     Since passage of the Clean Air Amendments of 1970, considerable atten-

tion has been given to the development of a system for assigning priorities

to various source categories.  The approach specifies areas of interest by

considering the broad strategy of the Agency for implementing the Clean Air

Act.  Often, these "areas" are actually pollutants which are emitted by

stationary sources.  Source categories which emit these pollutants have

been evaluated and ranked by a process involving such factors as:  (1) the

level of emission control (if any) already required by State regulations;

(2) estimated levels of control that might be required from standards of

performance for the source category; (3) projections of growth and replace-

ment of existing facilities  for the source category; and (4) the estimated

incremental amount of air pollution that could be prevented, in a prese-

lected future year, by standards of performance for the source category.

Sources for which new source performance standards were promulgated, or
                                                                      j
were under development during 1977 or earlier, have been selected on these
                                                                      ,
                                                                    ;.—*•
criteria.

     The Act amendments of August 1977 establish specific criteria to be

used in determining priorities  for all major source categories not yet
                                                                      I
listed by EPA.   These are:
                                                                      i
     1.   The quality of  air pollutant emissions which each such category

          will  emit, or will be designed to  emit;

     2.   The extent to which  each such pollutant may  reasonably be antici-

          pated to  endanger  public health  or welfare;  and
                                   2-6

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     3.    The mobility and competitive nature of each such category of
          sources and the consequent need for nationally applicable new
          source standards of performance.
     The Administrator is to promulgate standards for these categories
according to the schedule referred to in Section 2.1 of this chapter.   In
some cases, it may not be feasible to immediately develop a standard for a
source category with a high priority.  This might happen when a program of
research is needed to develop control techniques or because techniques for
sampling and measuring emissions may require refinement.  In the developing
of standards, differences in the time required to complete the necessary
investigation for different source categories must also be considered.  For
example, substantially more time may be necessary if numerous pollutants
must be investigated from a single source category.   Further, even late in
the development process, the schedule for completion of a standard may
change.   For example, inability to obtain emission data from well-controlled
sources in time to pursue the development process in a systematic fashion
may force a change in scheduling.  Nevertheless, priority ranking is,  and
will continue to be, used to establish the order in which projects are
initiated and resources assigned.
     After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be deter-
mined.  A source category may have several facilities that cause air pollu-
tion, and emissions from some of these facilities may be insignificant or
very expensive to control.  Economic studies of the source category and of
applicable control technology may show that air pollution control is better
served by applying standards to the more severe pollution sources.  For
                                  2-7

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this reason, and because there may be no adequately demonstrated system for
controlling emissions from certain facilities, standards often do not apply
to all facilities at a source.  For the same reasons, the standards may not
apply to all air pollutants emitted.  Thus, although a source category may
be selected to be covered by a standard of performance, not all pollutants
or facilities within that source category may be covered by the standard.
2.3  PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
                                                                       I
     Standards of performance must:  (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, nonair quality
health and environmental impacts, and energy requirements of such control;
(3) be applicable to existing sources that are modified or reconstructed as
well as new installations; and (4)  meet these conditions for all variations
of operating conditions being considered anywhere  in the country.
     The objective of  a program  for development  of  standards is to identify
the best technological system of continuous emission reduction which  has
been  adequately  demonstrated.  The  legislative history  of Section 111 and
                                                   1                    i
various court  decisions make  it  clear that the Administrator's judgment of
what  is adequately demonstrated  is  not  limited to  systems in actual  routine
use.   The  search may include  a technical assessment of  control systems
which have been  adequately demonstrated but  for  which  there  is  limited
operation  experience.   In most cases, determination of the,".  .  .  degree of
emission  reduction achievable ..." is based on results  of  tests  of emis-
sions from well-controlled existing sources.   At times, this has  required
                                                     .:       .'          i
the investigation and measurement of emissions  from control  systems  found
 in other industrialized countries that  have developed  more  effective sys-
 tems of control  than those available in the United States.
                                   2-8

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     Since the best demonstrated systems of emission reduction may not be
in widespread use, the data base upon which standards are developed may be
somewhat limited.  Test data on existing well-controlled sources are obvious
starting points in developing emission limits for new sources.  However,
since the control of existing sources generally represents retrofit techno-
logy or was originally designed to meet an existing State or local regula-
tion, new sources may be able to meet more stringent emission standards.
Accordingly, other information must be considered before a judgment can be
made as to the level at which the emission standard should be set.
     A process for the development of a standard has evolved which takes
into account the following considerations:
     1.   Emissions from existing well-controlled sources as measured.
     2.   Emissions data from such sources which are assessed with considera-
          tion of such factors as (a) the representativeness of the tested
          source in regard to feedstock, operation, size, age, etc.;
          (b) age and maintenance of the control equipment tested; (c)
          design uncertainties of control equipment being considered;  and
          (d) the degree of uncertainty that new sources will be able  to
          achieve similar levels of control.
     3.   Information from pilot and prototype installations, guarantees by
          vendors of control equipment, unconstructed but contracted pro-
          jects, foreign technology, and published literature are also
          considered during the standard development process.  This  is
          especially important for sources for which "emerging" technology
          appears to be a significant alternative.
                                  2-9

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    4.   Where possible, standards are developed which permit the use of
                                                        •
         more than one control technique or licensed process.
                                                                      i
    5.   Where possible, standards are developed to encourage or permit
         the use of process modifications or new processes rather than
         "add-on" systems as methods of air pollution control.
    6.   In appropriate cases, standards are developed to permit the use
         of systems capable of controlling more than orie pollutant.  As an
                                                                      i
         example, a scrubber can  remove both gaseous and particulate emis-
         sions, but an  electrostatic precipitatof  is specific to particu-
         late matter.
    7.   Where  appropriate, standards  for visible  emissions  are developed
         in conjunction with  concentration/mass emission standards.  The
         opacity  standard is  established at  a  level  that will require
         proper operation and maintenance of the emission  control  system
         installed  to meet the concentration/mass  standard on a day-to-day
         basis.   In some  cases,  however,  it  is not possible to develop
         concentration/mass standards, such  as with fugitive sources  of
          emissions.   In these cases,  only  opacity  standards may  be developed
          to limit emissions.
2.4  CONSIDERATION OF COSTS                                           !
     Among the requirements of Section 317 of the Act is an economic impact
assessment with respect to any standard of performance established under
                                                                      i
Section 111 of the Act.  The assessment is required to contain an analysis
of:
      (1)  the costs of compliance with the regulation and standard, including
                                                                      j
          the extent to which the cost of compliance varies depending on
                                  2-10

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          the effective date of the standard or regulation and the develop-
          ment of less expensive or more efficient methods of compliance;
     (2)  the potential inflationary/recessionary effects of the standard
          or regulation;
     (3)  the effects on competition of the standard or regulation with
          respect to small business;
     (4)  the effects of the standard or regulation on consumer cost; and
     (5)  the effects of the standard or regulation on energy use.
     Section 317 requires that the economic impact assessment be as exten-
sive as practicable, taking into account the time and resources available
to EPA.
     The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and by comparison with the control costs
that would be incurred as a result of compliance with typical existing
State control regulations.  An incremental approach is taken since both new
and existing plants would be required to comply with State regulations in
the absence of a Federal standard of performance.  This approach requires a
detailed analysis of the impact upon the industry resulting from the cost
differential that exists between a standard of performance and the typical
State standard.
     The costs for control of air pollutants are not the only costs con-
sidered.  Total  environmental costs for control of water pollutants as well
as air pollutants.are analyzed wherever possible.  A thorough study of the
profitability and price-setting mechanisms of the industry is essential to
the analysis so that an accurate estimate of potential adverse economic
impacts can be made.  It is also essential to know the capital requirements
                                  2-11

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placed on plants in the absence of Federal standards of performance so that
the additional capital requirements necessitated by these standards can be
placed in the proper perspective.  Finally, it is necessary to recognize
any constraints on capital availability within an industry, as this factor
also influences the ability of new plants to generate the capital required
for installation of additional control equipment needed to meet the standards
of performance.
2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(c) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment.  The objec-
tive of NEPA is to build  into the decision-making process of  Federal agen-
cies a careful consideration of  all environmental aspects of  proposed
actions.
     In a  number of  legal challenges  to standards of performance for various
industries, the United States Court of Appeals  for the District of Columbia
                                                                       I
Circuit has held that environmental impact statements need not be prepared
by the Agency  for proposed actions under  Section 111 of the Clean Air  Act.
Essentially,  the Court of Appeals  has determined that "...  the best
system of  emission reduction,  .  .  . require(s)  the Administrator to take
into account  counterproductive  environmental  effects of a  proposed standard,
as well as economic  costs to  the industry ..."  On this  basis, therefore,
the courts "...  established a narrow  exemption from NEPA for  EPA
determination under  Section  111."
                                   2-12

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     In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of-1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "no action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969" (15 U.S.C. 793(c)(l)).
     The Agency has concluded, however, that the preparation of environmen-
tal impact statements could have beneficial effects on certain regulatory
actions.  Consequently, while not legally required by Section 102(2)(c) of
NEPA, environmental impact statements will  be prepared for various regula-
tory actions, including standards of performance developed under Section 111
of the Act.  This voluntary preparation of environmental impact statements,
however, in  no way legally subjects the Agency to NEPA requirements.
     To implement this policy, a separate section is included in this
document which is devoted solely to an analysis of the potential environ-
mental impacts associated with the proposed standards.  Both adverse and
beneficial impacts in such areas as air and water pollution, increased
solid waste  disposal, and increased energy consumption are identified and
discussed.
2.6  IMPACT  ON EXISTING SOURCES
     Section 111 of the Act  defines a  new source  as ".  .  . any stationary
source, the  construction or  modification of which is commenced ..." after
the  proposed standards are published.  An existing source  becomes a new
source  if  the  source  is modified  or reconstructed.  Both  modification and
reconstruction are defined in amendments to the  general provisions  of
                                   2-13

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Subpart A of 40 CFR Part 60 which were promulgated in the FEDERAL REGISTER
on December 16, 1975 (40 FR 58416).  Any physical or operational change to
an existing facility which results in an increase in the emission rate of
any pollutant for which a standard applies is considered a modification.
Reconstruction, on the other hand, means the replacement of components of
an existing facility to the extent that the fixed capital cost exceeds
50 percent of the cost of constructing a comparable entirely new source and
that it be technically and economically feasible to meet the applicable
standard.  In such cases, reconstruction is equivalent to new construction.
     Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
                                     1
hazardous pollutant under Section 112).  If a State does not act, EPA must
establish such standards.  General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on
November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level of air pollution control achievable
                                                                      .
by any industry may improve with technological advances.  Accordingly,
Section 111 of the act provides that the Administrator ". . .  shall, at
least every four years, review and, if appropriate, revise ..." the
standards.  Revisions are made to ensure that the standards continue to
reflect the best systems that become available in the future.   Such revi-
                                                                      i
sions will not be retroactive but will apply to stationary sources con-
structed or modified after the proposal of the revised standards.
                                  2-14

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                3.   THE AUTOMOBILE AND LIGHT-DUTY TRUCK INDUSTRY
3.1  GENERAL DESCRIPTION
3.1.1  Automobile Industry
     The automobile* industry is the largest manufacturing industry in the
United States.   Motor vehicle and allied industries account for one-sixth
of the Gross National Product.    In 1977, the four major automobile manufac-
turing companies—General Motors Corporation, Ford Motor Company, Chrysler
Corporation, and American Motors Corporation—had combined sales of $111
billion.  Any significant change in the automobile industry affects the
entire economy of the United States.  According to the U.S. Department of
Commerce, for every 10 workers producing automobiles, trucks, and parts, 15
additional people are employed in industries that provide the materials and
manufacture components for these industries.  Employment figures for the
automobile industry are given in Table 3-1.
     Among the four automobile manufacturers, General Motors accounts for
the largest portion, 57 percent, of the total market.  Table 3-2 shows
domestic production by manufacturer.  Automobile assembly plants are located
in 19 states and 43 cities, as shown in Table 3-3.  However, over 32 percent
of all automobiles  produced in the U.S. are manufactured in Michigan.
Table 3-4 summarizes the automobile assembly plants by manufacturer, location,
and make of automobile.
     On the average, automobile assembly plants operate approximately 4000
hours per year at production rates averaging more than 45 vehicles per hour for
 The terms "automobile," "passenger car," and "car" are used interchangeably
 throughout this report.

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Table 3-1.  DIRECT EMPLOYMENT IN THE PRODUCTION
            OF AUTOMOBILES
         1967
         1971
         1972
         1973
         1974
         1975
         1976 (Est.)
341,000
382,000
412,000
450,000
350,000
380,000
390,000
                     3-2

-------
         Table 3-2.  SHARE OF TOTAL U.S. PRODUCTION
                                                   2,3
      Make
American Motors
Chrysler Corp.
Ford Motor Co.
                        237,785
                      1,341,392
                      1,851,440
General Motors Corp.  4,139,037
Miscellaneous           787,767
12-Month Total
      New Car Registration
       by Company in U.S.
1967           1972
              301,973
            1,466,141
            2,549,296
            4,635,656
                5,326
                      8,357,421      8,958,392
                      Production Summary:
            1974 Total U.S. Production = 7,324,504
            1975 Total U.S. Production = 6,716,951
            1976 Total U.S. Production = 8,497,893
            1977 Total U.S. Production = 8,784,165
   1977
  181,433
1,181,140
2,431,126
4,985,150
    5,316
8,784,165
                               3-3

-------
Table 3-3.   AUTOMOBILE ASSEMBLY  PLANT PRODUCTION
               (Model  Year 1977)2
State
CALIFORNIA
DELAWARE
FLORIDA
GEORGIA
ILLINOIS
KANSAS
KENTUCKY
MARYLAND
MASSACHUSETTS
MICHIGAN
MINNESOTA
City
(Total)
Fremont
Los Angeles
San Jose
South Gate
Van Nuys
(Total )
Newark
Wilmington
(Total)
Sebring
(Total )
Atlanta
Doraville
Lakewood
(Total )
Belvidere
Chicago
(Total)
Fairfax
(Total)
Louisville
(Total)
Baltimore
(Total )
Framinghara
(Total )
Dearborn
Detroit
Flint
Hamtramck
Kalamazoo
Lansing
Pontiac
Wayne
Willow Run
Wixom
(Total)
Twin Cities
Percentage
8.1
1.8
1.4
0.7
1.4
2.8
4.0
2.5
1.5

6.6
2.0
2.7
1.9
4.5
1.9
2.6
2.9
2.9
1.1
1.1
2.7
2.7
1.5
1.5
32.3
1.4
6.4
4.6
4.2
4.4 !.
3.6
3.0
2.8
1.9
1.3
1.3
Units
740,492
164,216
128,143
59,744
131,233
257,156
363,202
226,435
136,767
-
595,926
186,130
241,423
168,373
409,062
173,178
235,884
267,110
267,110
101,057
101,057
241,171
241,171
135,776
135,776
2,948,759
131,016
587,342
416,459
379,562
404,000
326,231
273,150
255,078
175,921
115,464
115,464
                      3-4

-------
                          Table 3-3.   (Continued)
    State
UNITED STATES
City
                                             Percentage
Units
MISSOURI
NEW JERSEY
NEW YORK
OHIO
TEXAS
WISCONSIN
(Total)
Kansas City
Leeds
St. Louis
(Total )
Linden
Mahwah
Metuchen
(Tota.l)
Tarrytown
(Total)
Avon Lake
Lorain
Lordstown
Norwood
(Total)
Arlington
(Total )
Janesville
Kenosha
11.1
1.0
2.8
7.3
6.6
2.7
2.9
1.0
2.5
2.5
7.3
0.4
2.7
1.8
2.4
2.5
2.5
' 5.0
3.0
2.0
1,010,786
93,946
252,119
664,721
596,791
243,455
260,560
92,776
230,894
230,894
660,101
36,136
241,017
162,029
220,919
230,371
230,371
457,581
275,576
182,005
                         TOTAL
                                              100.0
                                    9,104,543
                                  3-5

-------
                         Table 3-4.  AUTOMOBILE ASSEMBLY PLANTS

                                    (Model Year 1977)
Manufacturer
American Motors
Chrysler Corp.







Ford Motor Co.













Location
Kenosha, Wisconsin
Belvidere, Illinois
Haatrarack, Michigan
Jefferson Ave. , Detroit
Lynch Rd. , Detroit
Newark, Delaware
St. Louis, Missouri
Wyoming, Michigan

Atlanta, Georgia
Avon Lake, Ohio
Chicago, Illinois
Dearborn, Michigan
Kansas City, 'Missouri
Lorain, Ohio
Los Angeles, Calif.
Louisville, Kentucky
Mahwah, New Jersey
Hetuchen , New Jersey
St. Louis, Missouri
San Jose, California
Twin Cities, Minnesota
Wayne, Michigan
Wixom, Michigan
Make of Automobile
Hornet, Gremlin, Pacer, Matador
Gran Fury, Royal Monaco, Chrysler
Volare, Aspen
Chrysler
Monaco, Fury
Volare, Aspen
Diplomat, LeBaron
Voyager, Sportsman, Volare, Aspen
Export
LTD II, Cougar/XR7
Club Wagon
Thuflderbird
Mustang II
Maverick, Comet
Cougar, LTD II
LTD, Thuriderbird
LTD
Granada, Monarch
Pinto, Bobcat
Mercury
Pinto, Mustang II, Bobcat
LTD 	
Granada, MoTTarch, Versailles
Lincoln, Mark V
General Motors Corp. Arlington, Texas
                     Baltimore, Maryland
                     Detroit, Michigan
                     Doraville, Georgia
                     Fairfax, Kansas
                     Flint, Michigan
                     Fraraingham, Mass.
                     Fremont, California
                     Janesvilie, Wisconsin
                     Lakewood, Georgia
                     Lansing, Michigan
                     Leeds, Missouri
                     Linden, New Jersey
                     Lordstown, Ohio
                     Norwood, Ohio
                     Pontiac, Michigan
                     St. Louis, Missouri
                     South Gate, Calif.
                     Tarrytown, New York
                     Van Nuys, California
                     Willow Run, Michigan
                     Wilmington, Delaware
                           Chevelle, Monte Carlo, Cutlass
                           Monte Carlo, Chevelle, Century, LeMans
                           Cadillac, Eldorado, Seville
                           Monte Carlo, Cutlass, Chevelle
                           Pontiac, Oldsmobile 88, Le Sabre
                           Buick, Century, Riviera
                           Century, Cutlass
                           Monte Carlo, Century, Chevelle
                           Chevrolet
                           Grand Prix, LeMans
                           Oldsmobile, Cutlass, Toronado
                           Monte Carlo, Nova, Skylark, Chevelle
                           Cadillac, Oldsmobile, Buick
                           Sportvan, Sunbird, Monza, Vega, Astre
                           Camaro, Firebird
                           Pontiac, LeMans, Grand Prix
                           Chevrolet, Corvette
                           Chevrolet, Le Sabre, Oldsmobile 88
                           Nova, Skylark, Ventura
                           Camaro, Firebird
                           Nova, Omega, Ventura, Skylark
                           Chevette
Checker Motors
Kalamazoo, Michigan
Checker
Sebring-Vanguard     Sebring, Florida
                           CitiCar
Volkswagen
New Stanton, Pa.
Rabbit
                                           3-6

-------
midsized passenger cars.  In 1973, production of automobiles was 9.7 million,
a 10 percent increase over 1972.  Production of cars decreased considerably
to 7.3 million in 1974 and 6.7 million in 1975.  The major factor that
brought about the decline in production was the serious shortage of gasoline
and diesel fuel which developed at the end of 1973.  Consequently, con-
sumers began seeking small economical models, which were not yet available
in the domestic market.  Many American assembly plants producing large cars
were converted to production of compact and subcompact models.  As a result,
plants had to close down; production fell sharply; and at one time there
were nearly 150,000 auto workers out of work.
     Following this decrease, an upward trend occurred in 1976, with produc-
tion reaching the level of 8.6 million cars.  The increase can be attributed
first to the economic recovery during 1976 which allowed higher automobile
sales.  Secondly, a wide range of sizes—subcompacts, compacts, inter-
mediate, and full-sized automobiles—became available.  There is now evidence
of down-sizing with each car size category.  According to product mix plans
through 1980, demand for domestic new cars is expected to be nearly constant
over the next 4 years, with 1980 sales projected at 10,400,000 units, as
                    4
sh^-wn in Figure 3-1.
     Sales of imported cars, which reached a peak of 18.4 percent of the
U.S. market in 1975, have held fairly steady over the last several years
with minor fluctuations.  Several foreign car manufacturers plan to produce
cars in the United States.  Volkswagen is already producing cars for sale
in America at its new plant in New Stanton, Pennsylvania.
3.1.2  Truck Industry
     The truck industry manufactures a wide range of vehicles designed for
personal and commercial applications.  Different models of vehicles are
                                  3-7

-------
•8
 to
 o
            Figure  3.1  Automobile production trends,
                                 3-8

-------
classified by gross vehicle weight (GVW) and body type, as summarized in
Table 3-5.
     Almost 39 percent of the total production is comprised of vehicles
with GVW of under 6,000 pounds, and about 75 percent of the total produc-
tion consists of trucks with less than 8,500 pounds GVW.  The term "light-
duty truck" as used in this study indicates all vehicles with ratings of
8,500 pounds or less GVW.  Thirty-five percent of all light-duty trucks are
produced in Michigan.   The remaining 65 percent are made in other states.
Table 3-6 shows light-duty truck assembly locations in cities and states.
Table 3-7 summarizes the light-duty truck assembly plants by manufacturer
and location.
     As in the automobile industry, the truck industry has been affected by
recession in recent years.  After the record production of 3,007,495 units
in 1973, production slackened in 1974 and 1975.  In 1976, however, pro-
duction of trucks reached 3,015,000 units, and production in 1977 was
3,433,569 units.  The major factors contributing to this growth were the
overall economic growth, the new popularity of light-duty trucks and vans
for personal use, and the improved availability of gasoline.
     Assuming that another petroleum embargo does not occur and the
improvement  in the general economy continues as forecast, the annual growth
rate is expected to be 4 percent per annum until 1980.  A modest growth
                                                     4
of 1 percent per annum is projected for 1980 to 1985.   As with the
automobile industry, however, the  demand for light-duty trucks will be
influenced by monetary policy,  fiscal policy, and other economic developments.
     General Motors as a total  entity again dominated the light-duty truck
market with  45 percent of the total production in 1975.   Light-duty truck
production by model is shown  in Table 3-8.
                                   3-9

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-------
              Table 3-6.   LIGHT-DUTY TRUCK ASSEMBLY PLANTS
                         (Model  Year 1975)4'5'6
State
CALIFORNIA
GEORGIA
KENTUCKY
MARYLAND
MICHIGAN
MISSOURI
NEW JERSEY
DHIO
VIRGINIA
WISCONSIN
City
(Total )
Fremont
San Jose
(Total)
Atlanta
Lakewood
(Total)
Louisville
(Total)
Baltimore
(Total)
Detroit
Flint
Warren
Wayne
(Total )
Kansas City
St. Louis
(Total )
Mahwah
(Total)
Avon Lake
Lordstown
Toledo
(Total )
Norfolk
(Total)
Janesville
Percentage
8
3
5
4
1
3
9
9
4
4
35
1
14
12
8
10
4
6
3
3
20
9
6
3
3
3
4
4
Units
130,829
53,000
77,829
61,925
13,228
48,697
153,404
153,404
72,175
72,175
601,456
10,543
250,050
212,033
128,830
181,377
67,946
113,431
42,925
42,925
357,502
143,895
102,763
110,844
54,777
54,777
62,153
62,153
UNITED STATES
TOTAL
                                              100
1,718,523
                                     3-11

-------
    Table 3-7.  LIGHT-DUTY TRUCK ASSEMBLY PLANT LOCATIONS

                     (Model Year 1978)6
Manufacturer
        Location
Chrysler Corp.


Ford Motor Co.
General Motors Corp.
Warren, Michigan
St.  Louis, Missouri

Atlanta, Georgia
Kansas City, Missouri
Lorain, Ohio
Louisville, Kentucky
Mahwah, New Jersey
Wayne, Michigan
Norfolk, Virginia
San  Jose, California
Twin Cities, Minnesota

Baltimore, Maryland
Detroit, Michigan
Flint, Michigan
Fremont , Cal i f ornla^
Janesville, Wisconsin
Lakewood^ fieorgi a
Lords.;tGw~ri, Ohio
jPpjjtiac, Michigan     ^
     Louis, Missouri,, ~
     '     "'       "'-
Jeep

International Harvester
Toledo, Ohio

Fort Wayne, Indiana
,,/
                                3-12

-------
      Table 3-8.   ESTIMATED LIGHT-DUTY TRUCK PRODUCTION4'6'7

Make
Chevrolet
Dodge
Ford
General Motors
International Scout
Jeep
1974
724,052
309,810
687,788
138,625
77,411
114,132
1975
624,061
270,926
493,182
182,954
32,772
106,704
TOTAL
2,051,818
1,656,599
                               3-13

-------
3.2  PROCESSES OR FACILITIES AND THEIR EMISSIONS

3.2.1  The Basic Processes - Automobile Industry

3.2.1.1  General

     The finishing process of an automobile body is a multistep operation

carried out on a conveyor system known as the assembly line.   Such a line

operates at a speed of 9 to 25 feet per minute and generally produces 30 to
                                                     , .               i
70 units per hour.  The plant may operate up to three 8-hour shifts per

day.  Usually the third shift is used for cleanup and maintenance.  Plants

usually stop production for several weeks during the summer season for

inventory and model changeover.

     Although finishing processes vary from plant to plant, they have some

coranon characteristics.  Major successive steps of such processes are given

below:

     •    Solvent wipe*
                                                                     I

     «    Phosphating treatment

     •    Application of primer coat

     •    Curing of the primer coat

     •    Application of guide coat

     t    Curing of guide coat
                                                                     i

     •    Application of the topcoat(s)
                                                                     i
     •    Curing of the topcoat(s)

     •    Paint touchup operations

     A process diagram of these consecutive steps of the automobile finish-

ing process is presented in Figure 3-2.  These steps are explained in more

detail in Sections 3.2.1.2 through 3.2.1.4 of this; document.   Minimal
 The term "solvent" in this document means organic solvent.
                                  3-14

-------
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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

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          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

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   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

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     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

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      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

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          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

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        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

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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

-------
    VVJ-V
                                                    O)
                                                    to
                                                    o
                                                    Q.
                                                    O)
                                                    •o
                                                    o

                                                    +J
                                                    u
                                                    O)
                                                    o
                                                    •r—

                                                    ft
                                                    O)
4-5

-------
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

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       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

-------
 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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(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

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                                                           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

-------
                                 REFERENCES
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                                                                     I
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                                                                     i
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                                   4-44

-------
17.  Levinson, S.B.  Electrocoat.  Journal of Paint Technology.  44
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31.  Pegg, F.E.  Applying Plastic Coatings with the Fluidized Bed Process.
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                                   4-45

-------
34.  Iverson Powder Coats Bicycles in 20 Colors.  Industrial Finishing.
     50(9):58-63.  September 1974.
                                                     :                 i
35.  Cole, E. N.  Coatings and Automobile Industries Have Common Interest.
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36.  Gabris, T.  Trip Report — Ford Motor Company, Metuchen Plant.  DeBell &
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37.  Schrantz, J.  Powder Coating Brings Advantages to Baldwin.  Industrial
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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
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40.  Robinson, G. T.  Powder Coating Trailer Hitches.  Products Finishing.
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41.  How Nylon Powder Coatings Help.  Products Finishing.  38(7):81.  April
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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

-------
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

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 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

-------
      •    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

-------
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

-------
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

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-------
                         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

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     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

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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

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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

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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

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                                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

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                            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

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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

-------
                                                                              !	.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

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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

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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

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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

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       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

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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

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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

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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

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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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Incinerated Air 1
Type of Incinerator

.
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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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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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  • o •* 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

  • -------
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           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
    

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                           Costs  from  Reference  9
                                      10              15
                                        Capacity,  Nm3/s
                                                                    20
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                                   20             30
    
    
                                     Capacity, 1000 scfm
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    50
                Figure 8-6.
                            Comparison of purchase price values:  catalytic
                            incinerators with primary heat recovery.
                                            8-69
    

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                                            8-70
    

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                     10
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    Comparison of purchase price values:  thermal
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                                            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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    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
    

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    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
    

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           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
    

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           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
    

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    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
    

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                   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
    

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                                    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
    

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    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: ,::„
    

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    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
    

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     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
    

    -------
                                                                           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
    

    -------
     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
    

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                                     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
    

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                  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
    

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               •    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
    

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         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
    

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                  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
    

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                        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
    

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                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
    

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                                  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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    Location Within the Background
    Information Document
    
    
    
    
    
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    analysis should be sufficiently de-
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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.
    

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                            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
    

    -------
    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
    

    -------
    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
    

    -------
    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
    

    -------
         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
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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
    

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    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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