EPA-450/3-79-030b
Automobile and Light-Duty Truck
Surface Coating Operations-
Background Information for
Promulgated 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 1980
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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 o, 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 National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-79-030b
11
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and
Final Environmental Impact Statement
for
Automobile and Light-Duty Truck
Surface Coating Operations
Prepared by:
Don R. ^
Director, Emis'sion Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, NC 27711
(Date)
1. The promulgated standards would limit emissions of volatile organic
compounds from new, modified, and reconstructed automobile and
light-duty truck surface coating operations. Section 111 of the
Clean Air Act (42 U.S.C. 7411), as amended, 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." All regions of the United
States would be affected by these standards except the Northwest.
2. Copies of this document have been sent to the following Federal
departments: Labor; Health and Human Services; Education; Defense;
Transportation; Agriculture; Commerce; Interior; and Energy; National
Science Foundation; and the Council on Environmental Quality; to
members of the State arid Territorial Air Pollution Program Adminis-
trators (STAPPA) and the Association of Local Air Pollution Control
Officers (ALAPCO); to EPA Regional Administrators; and to other
interested parties.
3. For additional information contact:
•Mr. Gene Smith
Chief, Standards Preparation Section (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
4. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
.Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
m
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IV
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TABLE OF CONTENTS
Chapter Page
1 SUMMARY .................. 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of the Impacts of the Promulgated
Action ........ 1-4
1.2.1 Alternatives to the Promulgated Action ... 1-4
1.2.2 Environmental and Energy Impacts of the
Promulgated Action ............. 1-4
1.2.3 Economic Impact of the Promulgated Action . 1-5
1.2.4 Irreversible and Irretrievable Commitments
of Resources 1-5
2 SUMMARY OF PUBLIC COMMENTS 2-1
2.1 General 2-1
2.2 Emission Control Technology 2-11
2.3 Economic Impacts 2-14
2.4 Legal Considerations 2-17
2.5 Reference Methods and Monitoring 2-17
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LIST OF TABLES
List of Commenters on the Proposed Standards of
Performance for Automobile and Light-Duty Truck
Surface Coating Operations. .
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VI
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CHAPTER 1
SUMMARY
On October 5, 1979, the U.S. Environmental Protection Agency (EPA)
proposed standards of performance for automobile and light-duty truck
surface coating operations (44 FR 57802) under authority of Section 111
of the Clean Air Act. Public comments were requested on the proposal in
the FEDERAL REGISTER. There were a total of 22 commenters. Five presenta-
tions were made at the public hearing and seventeen additional comments
were received after the hearing. The majority of comments were received
from representatives of automobile and light-duty truck manufacturers
and coatings suppliers. Also commenting were State air pollution control
agencies, trade and professional associations, and several Federal
agencies. The comments that were submitted, along with responses to
these comments, are summarized in this document. A list of commenters
their affiliations, and the corresponding docket reference presented in
Table 2-1. The summary of comments and responses serves as the basis
for the revisions which have been made to the standards between proposal
and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL :
The significant changes to the standards involve the monitoring and
reporting requirements. Affected facilities will now be required to
determine the mass of VOC per liter of applied coating solids each
calendar month using a volume weighted average VOC content of applied
coating instead of the arithmetic average proposed. The use of a
volume weighted average will more accurately reflect actual use of
different coatings and allow sufficient flexibility for use of special
coatings and colors in small volumes. In addition, to demonstrate
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continual compliance, the owner or operator of affected facilities will
be required to calculate the volume weighted average mass of VOC per
liter of applied solids for each calendar month and report, within ten
days, any month in which the facility is not in compliance with the
standards. In addition, the owner or operator of an affected facility
which utilizes incineration to meet the standards must submit reports
quarterly on incinerator performance.
Two comments were received requesting that the standards be revised
to exclude coating of plastics on automobile bodies. EPA has reviewed
the data available regarding the coating of plastics and has concluded
that the comments are justified. Therefore, the coating of plastic
components or all-plastic bodies on separate coating lines has been
excluded.
Data received during the comment period indicated that the effect
i
of line purging on transfer efficiency was not adequately addressed.
EPA has reviewed the data on which the proposed standards were based and
the new data submitted by commenters and has concluded that changes were
required in the transfer efficiencies used in the determination of the
numerical emission limits. The baseline transfer efficiencies for air
atomized spray systems of waterborne coatings have been changed from
40 percent to 39 percent for guide coat and from 40 percent to 37 percent
for topcoat operations. As a result, the emission limit for guide coat
operations has been changed to 1.40 kilograms of VOC per liter of applied
coating solids and for topcoat operations to 1.47 kilograms of VOC per
liter of applied coating solids. In addition, the standards have been
changed to include transfer efficiencies for spray systems which utilize
line purging and do not collect any of the purged material and for
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systems that collect 100 percent of the purged material.
Reference Methods 24 and 25 were proposed along with the standards
for automobile and light-duty truck surface coating operations. Sub-
sequently, these reference methods have been promulgated separately from
the standards for automobile and light-duty truck surface coating operations
( FR ). A revised version of the proposed Method 24 (Candidate 2)
will be used as the reference method to .determine data used in the
calculation of the VOC content of coatings since conclusive data were
presented by commenters showing that certain coatings representing a
significant portion of those in use could not be distilled as required
by the proposed Method 24.
Several procedural and editorial changes have been made to the
promulgated Method 24 and Method 25 as proposed in order to clarify and
to improve the sampling and analytical procedures. These changes were
based on additional information obtained by EPA from experience with the
methods and on the public comments received. In addition, procedures
have been added to ensure that analytical data fall within established
precision limits. Also, to eliminate the possibility of an erroneous
determination of noncompliance with waterborne coatings, a procedure has
been added to modify analytical results obtained with waterborne coatings.
Based on comments from manufacturers that ASTM 2697 has only been
shown to be applicable to architectural coatings, the laboratory procedure
for determining volume fraction of solids has been eliminated. Method 24
now requires that the volume solids be determined from coatings manufacturers'
formulation data. In addition, the coatings classification step in the
proposed method was eliminated because industry comments indicated that
it was only necessary to separate waterborne and solvent-borne coatings.
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The majority of the changes to Method 25 relate to calibration require-
ments and are meant to improve quality assurance and simplify "the daily
operation of the analytical equipment. This is accomplished by requiring
performance test reference values to determine whether the performance
of the analytical equipment is still acceptable.
Finally, since only minimum performance specifications for several
important system components were provided, an addendum which lists
specific information regarding system components found to be acceptable
has been added to the method to provide guidance for users. Detailed
comments and responses regarding Methods 24 and 25 are presented in
Reference Methods 24 and 25 - Background Information for Promulgated Test
Methods (EPA-450/3-79-030c).
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED ACTION
While a number of changes were made in the standards since proposal,
the affected facilities and the regulatory alternatives on which the
standards are based remain the same. The environmental, energy, and
economic impacts remain as presented in the document, .Automobile and Light-
Duty Truck Surface Coating Operations - Background Information for Proposed
Standards (EPA-450/3-79-030[BID]).
1.2.1 Alternatives to the Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the BID.
The analyses of these alternatives remain as outlined in the BID.
1.2.2 Environmental and Energy Impacts of the Promulgated Action
The change in the emission limits for guide coat and topcoat operations
and the exclusion of the surface coating of plastic components and of
all-plastic automobile bodies will have negligible effect on the environ-
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mental or energy impacts ascribed to the standard as originally proposed.
Thus the environmental and energy impacts of the standards remain as
discussed in Chapter 7 of the BID.
1.2.3 Economic Impact of the Promulgated Action
The economic impact of the promulgated action remains unchanged
from that of the proposed standards as described in Chapter 8 of the
BID.
1.2.4 Irreversible and Irretrievable Commitments of Resources
The impact is discussed in Chapter 7 of the BID and remains unchanged
since proposal.
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CHAPTER 2
SUMMARY OF PUBLIC COMMENTS
The list of commenters and their affiliations is shown in Table 2-1
*,
of this chapter. In addition to the five presentations at the public
hearing, seventeen letters were received with comments on the proposed
standards and the document Automobile and Light-Duty Truck Surface
Coating Operations - Background Information for Proposed Standards (EPA-
450/3-79-030 [BID]),. The comments on the proposed standards have been
combined into the following five major areas:
1. General
2. Emission Control Technology
3. Economic Impacts
4. Legal Considerations
5. Reference Methods and Monitoring
The comments, issues, and responses to them are discussed in the
following sections of this chapter. A summary of the changes to the
regulations is included'in Section 1.1 of Chapter 1.
The comments specific to the test methods, Methods 24 and 25 and
the respo.nses to them are discussed in detail in Reference Methods 24
and 25 - Background Information for Promulgated Test Methods (EPA-
450/3-79-030c).
2.1 GENERAL
2.1.1 One commenter recommended that "Engineering Design Changes"
defined as "those minor changes made during a model year to improve the
quality or performance of the finished product" be exempted under the
modification section (§60.395) to provide for those minor changes made
during the model year to improve quality or performance of the finished
product.
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No changes were made in the standard as a result of this comment.
While requested, the commenter did not supply data to support his
recommendation. EPA, therefore, re-examined the available data. Under
§60.397, changes in the application of coatings to increase coating film
thickness are already exempted. In addition, minor operational changes
which would include design changes are allowed a;; long as emissions are
not increased. Therefore, EPA has concluded that, sufficient relief is
already provided in the standards and "engineering design changes" will
not be specifically exempted.
2.1.2 A commenter requested specific exemption under the modification
section (§60.395) for changes made to an existing facility in order for
them to comply with State Implementation Plans (SIPs).
If changes made to a facility in order to meet requirements of a
SIP result in reduced emissions, it would not fall under the modifica-
tion clause. If 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 affected facility," then the changes could
come under the reconstruction clause. However, the general provisions
also provide for a case-by-case determination of technical and economic
feasibility before a reconstructed facility is required to meet the
NSPS. EPA believes that this provision provides sufficient relief from
the reconstruction clause and no further specific exemption is required.
2.1.3 One comment indicated that the standards should include all
sources of VOC emissions from an assembly plant.
As originally stated under "Selection of Affected Facilities," the
prime coat, guide coat, and topcoat operations account for more than 80
percent of the uncontrolled VOC emissions from automobile and light-duty
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truck assembly plants. Final topcoat repair, cleanup, and coating of
various small component parts account for the remaining VOC emissions
and may be much more difficult to control for several reasons. Waterborne
coatings cannot be used for final topcoat repair because the temperature
required to cure waterborne coatings may damage heat sensitive parts
which have been attached to the vehicle by this stage of production.
Solvents are required for equipment cleanup and the cost of add-on
controls may not be reasonable for these numerous small operations
located throughout the plant. The use of waterborne coatings for topcoat
operations on small component parts has not been adequately demonstrated.
Often, these parts are plastic and the coating of plastic parts on a
separate coating line has been exempted for reasons discussed in 2.1.9.
Therefore, the standards will not be changed to include these additional
sources of VOC at this time.
2.1.4 One commenter requested that the term "guide coat" be changed to
"primer-surfacer" in order to better relate these standards with the majority
of Statexregulations which have limits expressed for "primer-surfacer"
operations.
EPA feels that the term "guide coat" is generally accepted by
industry and since a specific definition is given for the term ( §60.391),
there should be no confusion created by its use. The term "primer-
surfacer," therefore, will 'not be used.
2.1.5 One commenter recommended that the definition of transfer efficiency
exclude line purging and that transfer efficiency for air atomized spray
systems for waterborne coatings should be 36 percent. ..
The transfer efficiency data originally collected for these standards
and presented in the background information document (BID) included the
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effect of line purging but it was believed that the effects of line
purging on transfer efficiency were insignificant. Specific data on
line purging were not available from automobile manufacturers when the
BID was being prepared. The transfer efficiency data provided in the
BID and subsequently used in developing these standards were generally
collected by methods that did not identify the effect of line purging.
Studies submitted by the commenter in support of his position were
conducted at one of his existing facilities and demonstrated that line
purging can have an important effect on transfer efficiency. The data
indicated that the transfer efficiency for waterborne coatings applied
with air atomized spray systems was 39 percent with no line purging.
The data were obtained by block painting vehicles without a color change,
i.e., no line purging. The data also indicated that the transfer efficiency
for waterborne coatings applied with air atomized spray systems was 30
percent with each vehicle coated with a different color coating, i.e.,
line purging after each vehicle. Considering the average color schedule
at this plant, an overall transfer efficiency with line purging but no
purge capture was estimated to be 36 percent.
Subsequent discussions with and tests by the manufacturer indicated
that the purged material could be effectively captured. A system using
automatic purge capture is installed at one existing facility and a
system using manual purge capture is installed at another existing
facility. It was determined that if partial purge capture, i.e.,
approximately 50 percent, were taken into account an overall transfer
efficiency of 37 percent can be achieved.
After evaluating these data, EPA agrees with the manufacturer that
changes should be made to the standards. The baseline transfer efficiency
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for an air atomized spray system using waterborne coatings and partial
purge capture has been changed from 40 percent to 37 percent. The
baseline transfer efficiency for an air atomized spray system without
purge has been changed from 40 percent to 39 percent. As the emission
limits for guide coat and topcoat operations were based on air atomized
applied waterborne coatings, the limits for these operations have been
changed from 1.36 kilograms of VOC per liter of applied coating solids
to 1.40 kilograms of VOC per liter of applied coating solids for guide
coat operations (typically no purge conditions) and to 1.47 kilograms
VOC per liter of applied coating solids for topcoat operations (assuming
line purge with partial purge capture).
The standards have also been changed to include tables of transfer
efficiencies for application systems which collect 100 percent of the
purged material and for systems which purge after each vehicle and do
not collect any of the purged material. In addition, as the transfer
efficiency for air atomized spray of solvent-borne coatings is typically
higher than that for waterborne coatings, separate transfer efficiencies
have been included for solvent-borne and waterborne coatings applied by
air atomized spray systems.
Provisions have also been made to allow the use of appropriate
transfer efficiencies for systems with different purge and purge capture
conditions.
2.1.6 Comments were received which requested exemptions for "special
paints and colors" that are used in small volumes because the arithmetic
average of all coatings as required in the proposed standards could
result in values greatly different than a volume weighted average.
EPA agrees with the commenters and a change has been made which
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will result in allowing more flexibility in the use of "special paints
and colors" in small volumes. Originally, an arithmetic average was
used in the proposed standards for determination of the "VOC content of
all coating materials used in each surface coating operation that uses
spray application." tPA believed that the arithmetic average would
closely approximate a volume weighted average of VOC content and would
simplify compliance calculations. However, data from recent lowest
achievable emission rate determinations indicate that an arithmetic
average is not an acceptable approximation of a weighted average for VOC
content of topcoating materials planned for use in new plants. A major
factor in this change is a trend in the industry toward the use of
metallic base coat-clear coat finishes. These finishes have higher VOC
contents than solid color finishes and their use will result in inaccuracies
if an arithmetic average is used to determine the average VOC content of
all topcoating materials. Consequently, the standards have been changed
to require a volume weighted average to determine the VOC content of
coating materials. EPA believes that the use of a volume solids weighted
average for VOC content determinations will avoid misleading values and
allow sufficient flexibility for the use of special paints and colors in
small volumes. Therefore, no specific exemptions are provided in the
standards for special paints and colors.
2.1.7 One comment suggested that the standards should specifically
exempt final topcoat repair. This suggestion was based on the fact that
waterborne coatings are not available for final off-line topcoat repair.
The affected facilities for these standards, as defined in §60.390,
are "each prime coat operation, each guide coat operation, and each
topcoat operation" of an automobile or light-duty truck surface coating
line. This definition includes only the main surface coating operations
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and does not include final off-line topcoat repair for reasons discussed
in "Selection of Affected Facilities." Thus, EPA believes it is sufficiently
clear that final off-line topcoat repair is not covered by the standards
and no changes will be made to the standards.
2.1.8 Several commenters recommended that EPA adopt the CT6 units for
use in the proposed standards as most existing State regulations for
automobile coating operations are written in those units. It was stated
that emissions limits for existing plants in one set of units and
emissions limits for new, modified, or reconstructed plants in another
set of units could lead to confusion and result in erroneous calculations.
EPA agrees that there would be some advantage in retaining the CTG
units for the new source performance standards. However, to facilitate
equivalency determinations, VOC emissions reported in terms given in the
CTG document Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume II: Surface Coating of Cans, Coil, Paper, Fabrics, Automobiles,
and Light-Duty Trucks (EPA-450/2-77-008 [CTG]) must be recalculated to
include transfer efficiencies and the volume of solids. Consideration
of transfer efficiencies is significant because the standards can be met
by using higher solids content coatings if the amount of overspray is
kept to a minimum. In addition, this format allows equivalency determinations
for systems using solvent-borne coatings in combination with high transfer
efficiencies or capture systems and control devices. Therefore, the
advantage to the CTG format is outweighed by the necessity of including
transfer efficiency to obtain an accurate measure of the VOC emissions
from surface coating operations. The units will remain as written in
the standards.
2.1.9 Two commenters requested that the standards be revised to exclude
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the coating of plastics used on car bodies.
Data provided by the commenter indicated significant problems
associated with the use of surface coatings designed for sheet metal on
plastic car bodies or parts. A summary of these problems follows:
(a) Ruptures and delaminations in the plastic substrate. Incidence
of these defects is partially determined by the temperatures to
which the plastic is subjected with the number of defects increasing
with increasing temperatures. One automobile manufacturer has
found the incidence of these defects unacceptable at temperatures
130°C(270°F). The incidence of these problems can also be increased
by solvents used in enamels and laers.
(b) Cracking, pitting, and shrinking of adhesives used for structural
joints between body panels. These defects occur at temperatures
over 130°C (270°F). In those cases in which the joints are also
coating-finish surfaces, any of these defects would be unacceptable.
Also, exposure of the joint material to temperatures over 130 C
(270°F) could affect the strength and flexibility of the bond.
The temperature required to cure topcoats applied with waterborne
coatings is approximately 160°C (325°F). This is significantly in •
excess of the 130°C (270°F) limit for plastic parts and materials.
Therefore, since current industry practice is to coat plastic bodies and
components on separate coating lines, the standards have been changed to
exclude these operations. However, plastic body parts that are attached
to the metal body before the body is coated do not cause the coating
operation of that body to be excluded.
2.1.10 The projected adverse environmental impacts of waterborne coatings
were questioned by one commenter. It was stated that the solid waste
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impact did not reflect reality as waterborne coatings contain materials
which are more soluble in water than the materials currently used in
solvent-borne coatings. _
The commenter did not provide adequate data to document the claim
that waterborne and high-solids coatings have greater water and solid
waste impacts than estimated by EPA. Such data were requested from the
commenter, but have not been received. However, EPA has re-examined the
assessment of water and solid waste impacts made in the BID and has
found no evidence that the sludge from waterborne coatings is more
difficult to dispose of than the sludge from solvent-borne coatings. The
impacts summarized in the preamble to the proposed regulation are
considered correct and no changes to the standards are required.
2.1.11 One commenter pointed out that, in previous work, EPA had in-
cluded a list of "regulation excludable solvents", which were not con-
sidered in this standard. The commenter recommended that these solvents
be specifically excluded in the definition of VOC. EPA's "Recommended
Policy on Control of Volatile Organic Compounds," 42 FR 35314 (July 8,
1977), 44 FR 32042 (June 4, 1979), and 45 FR 48942 (July 22, 1980),
exempts the following compounds from regulation under State Implementation
Plans because they have negligible photochemical reactivity: methane,
ethane, 1,1,1-trichloroethane (methyl chloroform); methylene chloride;
and the following chlorofluorocarbons (CFC) or fluorocarbons (FC):
trichlorofluoromethane (CFC-11); dichlorodifluoromethane (CFC-12);
chlorodifluoromethane (CFC-22); trifluoromethane (FC-23); trichlorotri-
fluoroethane (CFC-113); dichlorotetrafluoroethane (CFC-114); and chloro-
pentafluoroethane (CFC-115). These compounds were not ignored in the
NSPS for automobile surface coatings. Rather, they were taken into
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account in the definition of VOC added to 40 CFR 60.2, which defines VOC
as organic compounds which participate in atmospheric photochemical
reactions or which are measured by an applicable reference method.
This VOC definition exempts organic compounds which have a negligible
photochemical reactivity even though the reference methods specified for
VOC emissions do not provide procedures for excluding these compounds
when emission measurements are made. While this may appear inconsistent,
EPA believes this approach is reasonable and practical. This is because
there is currently little, if any, known use of the exempt compounds,in
automobile coatings. Also, use of incineration devices and bake ovens
can oxidize non-reactive solvents to a reactive form, thus further
reducing the likelihood of non-reactive solvents being present in automobile
coating plant emissions. Furthermore, while selective test methods are
available which could be used to exclude the exempt compounds, these
test methods which would require sophisticated gas chromatographic
and/or mass spectographic techniques, are more expensive and complicated
than the reference methods. EPA would, however, allow these techniques
as alternative methods if an owner or operator were to use a coating
which contains a significant amount of an exempted compound.
In addition to the above, the VOC definition is consistent with
EPA's continuing concern over the possible environmental effects from
emissions of certain of these compounds and it should be understood that
EPA is not precluding the possible future regulation of these compounds.
It should be noted that EPA has proposed a NSPS for organic solvent
cleaners (45 FR 39766, June 11, 1980) which would limit emissions of the
reactive volatile organic compounds trichloroethylene and perch!oroethylene
as well as methyl chloroform, methylene chloride, and trichlorotrifluoroethane
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(CFC-113) from new, modified, and reconstructed organic solvent degreasers.
If these standards are promulgated, EPA will develop a guideline document
for States to use in developing regulations required under Section
m(d) for existing organic solvent cleaners that use any of the designated
compounds.
Whether, and to what extent, methyl chloroform and methylene chloride
are human carcinogens or have other toxic effects, and to what extent
methyl chloroform, CFC-113, and other CFC's deplete the ozone layer, are
issues of considerable debate. Detailed health assessments of methyl
chloroform, methylene chloride, and CFC-113 are being prepared by EPA's
Office of Research and Development. These assessments will be submitted
for external review, including a review by the Science Advisory Board,
prior to promulgation of the regulations and the proposal of EPA guidance
to States for developing existing source control measures. The extent
to which the preliminary findings are affirmed by the review process may
affect the final rulemaking for new as well as existing sources.
Until these issues of environmental impact are fully resolved, EPA
remains concerned that the exemption of these chemicals from regulation
may be misinterpreted as an encouragement for the substitution of exempt
for nonexempt solvents with resulting large increases in emissions of
pollutants that may have adverse health impacts.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Two comments recommended that EPA consider revising the baseline
transfer efficiency value of 40 percent, which was used in determining
the emission limits. It was stated that modified or reconstructed
facilities would have particular difficulties in obtaining 40 percent
transfer efficiency.
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At the time the 40 percent transfer efficiency value was chosen for
use in the standards, it was based on the latest industry data. Since
that time tests have indicated that transfer efficiency at retrofitted
facilities using waterborne coatings is approximately 30 percent, but
that the transfer efficiency at a new facility is 37 percent with partial
block painting and partial purge capture. Changes have been made in the
standards to reflect these data (see 2.1.5). However, no changes were
made to reflect different transfer efficiencies for new affected facilities
versus modified or reconstructed affected facilities. It is believed
that the baseline transfer efficiency can be achieved at modified or
reconstructed affected facilities with proper design which incorporates
the experience gained at existing facilities.
2.2.2 Two commenters objected to the solids weighted average method of
determining the VOC content of prime coat material because of problems
they anticipate with "flow control" additives which are normally added
to the electrodeposition process (EDP) tank to maintain or improve the
application process. These additives are added to the tank on a periodic
basis and the commenters claim that they should not be included when
determining VOC emissions because of the potential wide fluctuations in
the calculated VOC emissions.
The prime coat emission limit is based on a volume solids weighted
average VOC content of all makeup material including flow control additives
added to an EDP tank during one calendar month. Flow control additives
are high in VOC content but are added only periodically. If a short time
period (such as a day) is used to calculate VOC emissions, the effect of
flow control additives could be significant causing wide daily fluctuations.
A longer averaging period dampens these fluctuations. Information
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supplied to EPA during the development of these standards indicates that
makeup material which includes flow control additives is available to
meet the emission limit of 0.16 kilograms of VOC per liter of applied
coating solids averaged over a calendar month. Therefore, a volume
solids weighted average over a calendar month period allows plants to
achieve the proposed value (including flow control additives) and flow
control additives will continue to be included when determining VOC
emissions from the prime coat operation.
2.2.3 These commenters also objected to the proposed emission limit for
prime coat operations which is equivalent to 1.2 pounds of VOC per
gallon of coating minus water claiming that such prime coat materials
are not available.
As indicated in 2.2.2, data from one automobile manufacturer
indicate that prime coat material including flow control additives is
available and operating experience demonstrates that the emission limit
calculated on a calendar month basis for prime coat operations is achievable.
Therefore, the emission limit will not be changed.
2.2.4 One commenter opposed the statement in the preamble that predicted
that high solids coatings will be technically demonstrated for use in
the auto industry by 1982. The commenter stated that "current development
forecasts indicate that it will be 1984 at the earliest before high
solids topcoat coatings will generally be available for use in automobile
and light-duty truck assembly plants."
EPA agrees that the projection of a date by which a product will be
available depends on a number of factors and that high solids topcoat
coatings may not be available by 1982. The reference to the year 1982
is incorrect and should read "in the near future". However, this does
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not affect the regulatory alternative, waterborne coatings, on which the
standards are based. .
2.2.5 One comment contained a statement that since spray booth exhaust
incineration is not technically feasible it should not be considered as
an alternative control technique. The commenter claimed that the huge
volume of air with low VOC concentration makes incineration unreasonable
and impractical.
EPA has reviewed the available data and believes that spray booth
exhaust incineration is technically feasible. As originally stated
under "Selection of Best System of Emission Reduction," there are no
facilities that use thermal or catalytic incineration to control VOC
emissions from spray booths. In addition, it was stated that the reason
incineration is not used is not due to technical problems, but to the
high use of supplemental fuel. A review of the available data confirms
that spray booth exhaust incineration is an available, although energy
intensive, control technique.
2.3 ECONOMIC IMPACTS
2.3.1 There were some comments which claimed that the economic impacts
given in the standards for new facilities were underestimated. One
commenter claimed that the costs could be two to three times that estimated
for various regulatory alternatives.
I
EPA used the best data available at the time the background information
document was written. Analyses of those data resulted in an estimated
incremental cost per vehicle produced at the facility of $17.23 for
waterborne coatings and $19.65 for catalytic incineration. Prices for
automobiles and light-duty trucks are set by averaging production costs
over all facilities producing a given vehicle. Using this approach, the
2-14
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estimated cost increase from this standard for a typical vehicle is less
than 0.1 percent. Since the data for the BID were gathered, inflation
and more stringent water and solid waste regulations may have increased
the economic impacts. EPA believes that the increase is not two to three
times the impact presented in the BID. However, even if the actual
economic impacts were in that range, the estimated cost increase would
be 0.2 or 0.3 percent, a price increase per vehicle which EPA would view
as acceptable for the standards. Therefore, no change in the standards
has been made as a result of this comment.
2.3.2. Two comments were received which recommended.that separate
standards be proposed for new plants versus modified or reconstructed
facilities because of the differences in economic impact.
If a physical or operational change were made to an existing facility
at an automobile or light-duty truck plant which would potentially
increase VOC emissions, the owner or operator would implement the changes
necessary to hold VO.C emissions at or below the previous level so as not
to be subject to the standards. This course of action would be less
costly to the plant than implementing control strategies to meet the new
source performance standards. This reduction could be accomplished by
switching to a coating with a lower VOC content or by incineration of a
portion of the VOC emissions. Both of these options are available to
all plants. The cost of switching to a coating with a lower VOC content
or to incineration of a portion of the VOC emissions is affordable and
reasonable.
Although it is unlikely to happen, if an existing facility is
modified and is required to meet the limits of the NSPS, it would be
more costly than the previous options described above but would still be
affordable. Some existing plants may not be able to use the full range
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of control options because of physical constraints. For example, an
existing enamel plant may not have enough room in its existing spray
booths to use waterborne coatings as the enamel booths are shorter than
i
the ones required for waterborne coatings. Nevertheless, the enamel
plant has other options such as the use of high solid enamels or incin-
eration which would be available to all such plants.
Control options that are affordable are available to all existing
plants to reduce emissions to premodification levels or to meet the
levels of the NSPS; therefore, the development of a separate NSPS for
modifications is not justified.
If physical or operational changes were made to an existing plant
which would qualify as a reconstruction under §60.15, the fixed capital
cost of new components would exceed 50 percent of the fixed capital cost
that would.be required to construct a comparable entirely new facility.
During development of the standards, EPA found that the capital cost of
a new coating facility is approximately $30,000,000 (average of solvent-
borne enamel and lacquer systems) and that the capital cost of implementing
the standards approximately $750,000 for that facility. In the extreme
situation under reconstruction where the cost of a reconstructed facility
would be $15,000,000, or 50 percent of the cost, of a new facility, the
cost of implementing the standards would still be $750,000 or 0,5 percent
of the capital cost of the facility. The Administrator believes that
this cost is not unreasonable and that relief is provided for a source
in unusual financial situations through §60.15 which requires that it be
economically feasible for a reconstructed source to meet the applicable
standards. Therefore, separate standards for reconstructed plants are
not justified. The standards will apply to modified and reconstructed
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facilities as well.as new facilities.
2.4 LEGAL CONSIDERATIONS
2.4.1 One comment suggested that EPA develop criteria to identify
innovative control technologies for which "innovative waivers" may be
granted.
On October 31, 1979, the White House issued a fact sheet on the
President's Industrial Innovation Initiatives. Included in this fact
sheet is a directive for the EPA Administrator to "develop and publicize
a clear implementation policy and set of criteria for the award of
innovative waivers" and to "assess the need for further regulatory
authority." EPA is committed to carrying out this directive; therefore,
the Administrator has requested that the Office of Enforcement initiate
an implementation policy regarding the award of innovative technology
waivers.
EPA will consider, but is not committed to, the commenter's request
for specific innovative control technology criteria or procedures for
issuing waivers for automobile and light-duty truck surface coating
operations. EPA's decision will, in part, depend upon the outcome of
the development of general criteria for innovative technology waivers.
Until the innovative control technology criteria are issued, EPA
will continue to handle Section lll(j) waiver requests on a case-by-case
basis.
2.5 REFERENCE METHODS AND MONITORING
2.5.1 Several commenters stated opposition to the parts of §60.393 that
deal with the monitoring of incinerators which are used to control VOC
emissions. It was stated that the required accuracy of the temperature
monitoring device +2°C (+3.6°F) is too restrictive and unnecessary
2-17
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because of the normal operating temperature range. Concern was also
expressed that the reporting requirement under §60.393 did not allow
enough time for normal operation shutdowns such as breaks and lunch.
The commenter did not provide information to'support his claim,
however data were solicited from vendors of incinerators and temperature
recorders. Because of the high temperatures (760-820°C [1400-1500°F])
at which these incinerators operate K60.394 has been changed to read
"the device shall have an accuracy of the greater of 0.75 percent of the
temperature being measured expressed in degrees Celsius or +2.5 C." In
addition, Method 25 requires that the destruction efficiency of an
incinerator be based on the average of three one-hour tests during which
the temperature is monitored. Therefore, it was decided, in order to
exclude normal short-term interruptions from the reporting requirement,
to change the 15 minute period to a three-hour period corresponding to
the three-hour period for which temperature was originally monitored.
2.5.2 There were comments objecting to the proposed requirement that
analysis of VOC content be performed "whenever a change occurs in the
composition of any of these coating materials."
EPA realizes that, in a coating operation, frequent adjustments
occur in the type and quantity of reducing solvents used in the coatings,
The wording of appropriate sections has been revised so manufacturers'
data may be used in demonstrating compliance. This will significantly
reduce the burden of requiring an analysis for each change in coating.
This change, while reducing the number of analyses, could result in a
slight increase in the quantity of records being maintained. It is
believed that this is a reasonable alternative.
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2.5.3 One commenter recommended that a schedule should be specified for
recalibrating-any continuous monitoring devices required for compliance
with the standards.
The temperature monitoring device necessary for monitoring incinerator
operations will require recalibration annually according to the procedure
already established in §60.13. Therefore, no schedule is necessary in
the regulation. ~-
2.5.4 One comment suggested that industry be required to disclose
information showing any "day" during which the emission limits are
exceeded.
It is EPA's opinion that requiring the reporting of daily excess
emissions would create an undue burden on industry and EPA. Because of
the variable nature of the operation, daily reporting might also be
misleading. For example, solvents are added to the EDP tank in batches
and a daily reporting requirement would incorrectly indicate excess
emissions for those days when solvents are added. A longer averaging
time is necessary to give an accurate indication of emissions. While a
rolling 30 day average could have been used, this would impose an undue
burden on industry as data are already maintained by industry on a
calendar month basis. Therefore, the standards have not been changed.
2-19
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TABLE 2-1
LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF PERFORMANCE
FOR AUTOMOBILE AND LIGHT-DUTY TRUCK SURFACE COATING OPERATIONS
Public Hearing
Commenter
Victor Sussman, Director
Stationary Source Environmental
Control Office
Ford Motor Company
One Parklane Boulevard
Dearborn, Michigan 48126
Douglas A. Frank
Staff Engineer
Environmental Activities Staff
General Motors Corporation
Warren, Michigan 48090
Hiro Fujimoto
Technical Manager
Analytical Services
Automotive Division
5935 Mil ford Avenue
Detroit, Michigan 48210
Byron C. Behr, President
Byron Instruments, Inc.
520 South Harrington
Raleigh, North Carolina 27601
Richard H. Schenkel, Manager
Plant Engineering
American Motors Corporation
14250 Plymouth Road
Detroit, Michigan 48232
Docket Reference
A-79-05
76/2-IV-F-l
A-79-05
76/2-IV-F-l
A-79-05
76/2-IV-F-l
A-79-05
76/2-IV-F-l
A-79-05
76/2-IV-F-l
Written Comments
William T. Cavanaugh
Managing Director-ASTM
1916 Race Street
Philadelphia, Pennsylvania
A-79-05
76/2-IV-D-l
19103
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H. 0. Stremba
Deputy Managing Director
ASTM
1916 Race Street
Philadelphia, Pennsylvania
19103
John E. Lowe
Environmental Coordinator
Finishes Division
E.I. Dupont De Nemours & Company
Wilmington, Delaware 19898
Larry L. Thomas, Executive Director
National Paint and Coatings Association
1500 Rhode Island Avenue, N.W.
Washington, D. C. 20005
Robert H. Collom, Chief
Air Protection Branch
State of Georgia
Department of Natural Resources
Environmental Protection Division
270 Washington Street, S. W.
Atlanta, Georgia 30334
Victoria Hathaway-Sarver
Air Pollution Control Specialist
Abatement Unit
Regional Air Pollution Control Agency
451 W. Third Street
P.O. Box 972
Dayton, Ohio 45422
R. J. Anderson, Vice-President
DeSoto, Inc.
1700 South Mount Prospect Road
Des Plaines, Illinois 60010
W. R. Johnson, Director
Plant Environment
Environmental Activities Staff
General Motors Corporation
Warren, Michigan 48089
C. B. Potelunas, Manager
Air and Water Pollution Control
American Motors Corporation
14250 Plymouth Road
Detroit, Michigan 48232
A-79-05
76/2-IV-D-la
A-79-05-
76/2-IV-D-2, D-2a
A-79-05
76/2-IV-D-3
A-79-05
76/2-IV-D-4
A-79-05
76/2-IV-D-5
A-79-05
76/2-IV-D-6
A-79-05
76/2-IV-D-7
A-79-05
76/2-IV-D-8
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R. W. Vorhees, Manager
Environmental Engineering & Manufacturing
Standards
Chrysler Corporation
P.O. Box 1919
Detroit, Michigan 48288
Richard L. Strombotne, Director
Office of Automotive Fuel Economy Standards
U. S. Department of Transportation
National Highway Traffic Safety Administration
Washington, D. C. 20590
A. B. M. Houston, Manager
Compliance and Liaison Department
Stationary Source Environmental Control
Ford Motor Company
One Parklane Boulevard
Dearborn, Michigan 48126
Delbert Rector, Chief
Air Quality Division
State of Michigan
Department of Natural Resources
Stevens T. Mason Building
Box 30028
Lansing, Michigan 48909
Sue Nelson, Director
Directorate of Policy,
Legislation and Interagency Programs
U.S. Department of Labor
Occupational Safety and Health Administration
Washington, D. C. 20210
Daniel J. Goodwin, Manager
Division of Air Pollution Control
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
J. C. Weaver, Chairman of 001-21-13
Task Group on VOC
ASTM
1916 Race Street
Philadelphia, Pennsylvania 19103
A-79-05
76/2-IV-D-9
A-79-05
76/2-IV-D-10
A-79-05
76/2-IV-D-ll
A-79-05 •
76/2-IV-D-12
A-79-05
76/2-IV-D-13
A-79-05
76/2-IV-D-14
A-79-05
76/2-IV-D-15
2-23
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9. PERFORMING ORGANIZATION NAME AND ADDRESS .
Office of Air Quality Planning and Standards
U.S.Environmental Protection Agency
. Research Triangle Park, NC 27711
TECHNICAL REPORT DATA
read Jiizisurtiuns on the reverse bcfurc coin/tic ling)
1, REPORT NO.
EPA/450-3-79-030b
A. TITLE AND SUBTITLE
2.
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
Automobile and Light-Duty Truck Surfacing Coating
Operations
Background Information for Promulgated Standards
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NOJ
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air and Waste Management
U.S.Environmental Protection Agency
Research Triangle Park, NC 27711 '
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3064
13 TYPE OF RF.PORT AND PE RIOD .COVERED j
FINAL
14. SPONSORING AGENCY CODE
EPA 200/04
15. SUPPLEMENTARY NOTES
16, ABSTRACT "
This document contains a summary of public comments EPA responses and a discussion
of differences between the proposed and'promulgated standards-of-performance to control
volatile organic compounds (VOC) emissions from new-, modified, and reconstructed,
automobile and light-duty truck surface coating operations in the U.S-. "T1^ *+=«*=
are being promulgated under Section 111 of the Clean Air Act.
"The standards
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Automobile
Air pollution control
Light-Duty Truck
Standards of Performance
Surface coatings operations
Volatile Organic Compounds (VOC)
18, DISTRIBUTION STATEMEN1
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS (This Report)
unclassified
EPA Form J22O-1 13-73)
2D. SECURITY CLASS (This page)
unclassified '
2-24
c. COSATI Field/Group
13 B
21. NO. OF PAGES
-3Q
22. PRICE
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