United States Air and Radiation EPA 340/1-88-003
Environmental Protection (EN-341) July 1989
Agency
c/EPA Recordkeeping
Guidance Document
For Surface Coating
Operations
And The Graphic Arts
Industry
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EPA 340/1-88-003
RECORDKEEPING GUIDANCE DOCUMENT FOR
SURFACE COATING OPERATIONS
AND THE GRAPHIC ARTS INDUSTRY
STATIONARY SOURCE COMPLIANCE DIVISION
U.S ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C 20460
July 1989
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TABLE OF CONTENTS
Page
TABLE OF CONTENTS i i i
LIST OF FIGURES v
LIST OF TABLES vi
PREFACE vi i
1. INTRODUCTION 1-1
2. SURFACE COATING OPERATIONS 2-1
2.1 Process Description 2-1
2.2 VOC Emissions and Coating Formulations 2-6
2.3 VOC Emission Regulations and Compliance
Requi rements 2-8
2.4 VOC Control Equipment 2-13
2.5 VOC Measurement Methods 2-15
2.6 References for Chapter 2 2-19
3. RECORDKEEPING PROCEDURES 3-1
3.1 Recordkeeping Needs and Requirements 3-1
3.2 Standard Forms 3-2
3.3 References for Chapter 3 3-14
4. DATA VERIFICATION PROCEDURES 4-1
4.1 Preliminary Data Verification Activities 4-1
4.2 Data Verification Procedures During On-Site
Inspecti ons 4-3
4.3 Post-Inspection Data Verification Procedures 4-5
4.4 References for Chapter 4 4-6
i i i
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TABLE OF CONTENTS
(Continued)
Page
5. COMPLIANCE DETERMINATION 5-1
5.1 Compl 1 ant Coat 1 ngs 5-2
5.2 Add-On Control Equipment 5-9
5.3 Transfer Efficiency Enhancement 5-11
5.4 Bubbles 5-13
5.5 References for Chapter 5 5-16
6. RECORDKEEPING PROCEDURES FOR
THE GRAPHIC ARTS INDUSTRY 6-1
6.1 Graphic Arts Processes 6-1
6.2 VOC Emission Limitations 6-3
6.3 Add-On Control Systems 6-4
6.4 Recordkeeping and Data Verification
Procedures 6-4
6.5 Compl i ance Determi nati ons 6-5
6.6 References for Chapter 6 6-5
APPENDIX A. ALLOWABLE VOC LIMITS FOR SURFACE
COATING OPERATIONS
APPENDIX B. SUGGESTED SURFACE COATING TERMS
APPENDIX C. REFERENCE TEST METHODS 24, 24A, AND 25
(Excerpted from 40 CFR 60)
IV
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LIST OF FIGURES
Figure No. Title Page
2-1 Metal Coating Operation 2-2
3-1 Recordkeeping Form for General Information 3-3
3-2 Recordkeeping Form for Process Information 3-4
3-3 Recordkeeping Form for Coating Formulation
Data 3-5
3-4 Recordkeeping Form for Coating Consumption
Data 3-6
3-5 Recordkeeping Form for Control Equipment
Data 3-7
3-6 Recordkeeping Form for Transfer Efficiency
Data 3-10
5-1 Example 5-1 Data 5-4
5-2 Example Formulation Data for Calculating
Ibs VOC/gal Solids 5-8
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LIST OF TABLES
Table No. Title Page
2-1 Surface Coating Processes and Application
Methods 2-3
2-2 Exempt Solvents 2-7
2-3 Coatings and Diluents Used by Surface
Coating Operations 2-9
2-4 Control Devices Used by Surface Coating
Operations 2-16
5-1 Compliance Determination for a Line Using
Mul ti pie Coatings 5-6
5-2 Daily VOC Emissions from a Plant with a
Bubble 5-14
vi
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PREFACE
This guideline document is a product of the combined efforts of
many individuals within and outside of the U.S. Environmental Protection
Agency (EPA).
The document was prepared by and under the direction of Mr. Vishnu
Katari, P.E., Stationary Source Compliance Division, U.S. Environmental
Protection Agency, Washington, DC. Mr. Glenn T. Reed, P.E., of Pacific
Environmental Services, Inc. wrote portions of Chapters 3, 4, 5, and 6.
A portion of Chapter 2 was provided by PEI Associates, Inc., Arlington,
Texas.
The members of EPA's VOC Compliance Workgroup and several other
individuals from the EPA Regional Offices and Headquarters, including
the Air Quality Management Division, the Emission Standards Division,
and the Stationary Source Compliance Division of the Office of Air
Quality Planning and Standards and the Office of Enforcement and
Compliance Monitoring, have made valuable contributions to the report by
providing a detailed review and comments on the report as it was being
written. The D01 Committee of the American Society for Testing and
Materials also contributed significantly to the quality of the report by
reviewing it extensively.
Originally, the document was written to address the recordkeeping
requirements for surface coating operations only. However, the record-
keeping requirements for both surface coating operations and the graphic
arts industry are similar.. The recordkeeping provisions described in
the document are applicable to the graphic arts industry as well as to
surface coating operations. In this final document, the original mate-
rial written for surface coating operations has been retained as it was
originally written, and a separate chapter has been added to discuss the
graphic arts industry and to indicate the differences between the
graphic arts industry and surface coating operations as they may affect
recordkeeping requirements.
vii
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1. INTRODUCTION
A surface coating operation involves the application of decora-
tive, functional, or protective coating (such as paint, lacquer, var-
nish, ink, or other related material) to a substrate, such as metal,
wood, paper, plastic, fabric or masonry. Volatile organic compounds
(VOC) are emitted from surface coating operations mainly as a result of
the evaporation of volatile organic compounds, chiefly solvents in for-
mulation or that added (as diluent or thinner) to the coating mixture or
the curing process. Because all the process solvent input is evaporated
and, if uncontrolled, emitted to the atmosphere (with little alteration
by reaction), the process input data serves as a basis for both emission
limit setting and emission compliance calculation. The compliance
limits for surface coating operations restrict the amount of VOC emitted
from a coating as applied. For most other VOC sources the compliance
limitations are control technology based.
A source may comply directly or by the use of an alternative means
with these emission limits. It may comply directly by using compliant
coatings (those with VOC content equal to or lower than that allowed) or
by installing add-on controls to achieve emission reduction while using
noncompliant coatings. Of course, in order to reduce emissions, a
source may also change the process or paint application equipment.
Because of the various options, the documentation of coating consumption
data and process operating parameters is essential for a source compli-
ance determination and monitoring. Such data must be routinely col-
lected and maintained by the surface coating facility for review by the
enforcement agency.
The primary purposes of this report are to 1) identify the data to
be documented and maintained by the surface coating facility; 2) suggest
a standardized format for the data presentation; 3) indicate possible
data verification methods; and 4) suggest inspection and compliance pro-
cedures.
Although this report is directed towards surface coating opera-
tions, the recordkeeping provisions described are applicable to the
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graphic arts industry, as well. The nature and manner of emissions from
graphic arts sources are similar to those from surface coating opera-
tions.
Chapter 2 of this report presents an overview of surface coating
operations and formulations, regulations, emissions, monitoring methods,
and control equipment. Recordkeeping requirements and data verification
procedures are presented in Chapters 3 and 4, respectively. Chapter 5
presents sample compliance determinations and calculations. In Chapter
6, the graphic arts industry is discussed, and the differences between
the graphic arts industry and surface coating operations as they affect
recordkeeping requirements are identified. Appendices A, B and C dis-
cuss allowable limits for surface coating operations, surface coating
terms, and VOC measurement methods.
1-2
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2. SURFACE COATING OPERATIONS
The purpose of this Chapter is to familiarize the reader with
coating operations, formulations, emission regulations, control equip-
ment, and emission measurement methods.
2.1 PROCESS DESCRIPTION
Although surface coating operations vary from process to process,
a typical surface coating operation includes the following four steps:
1. Surface preparation
2. Coating application
3. Flash-off
4. Drying (curing)
Figure 2-1 illustrates these operations for a metal furniture manufac-
turing facility.
The surface is prepared to ensure proper bonding between the sur-
face and the coating. For coating a metal substrate, surface prepara-
tion can be achieved by aqueous washing, solvent degreasing, or both,
which may be followed by a phosphate treatment step to set up the metal
surface to improve bonding between the metal surface and the coating.
In some cases, the surface is mechanically or chemically treated.
Coatings are commonly applied by different methods including
spray, roller, dip, flow, and brush techniques. In spray coating, elec-
trostatic, air-assisted/airless, airless, low pressure-high volume
(LPHV), and conventional air-spray methods are used. Methods which are
more efficient in applying a coating are advantageous since they improve
transfer efficiency, decrease paint use, and reduce VOC emissions.
Table 2-1 illustrates the types of coating methods used. Rotogravure
and flexographic printing processes are discussed in Chapter 6 of this
document.
Surface coating may be completed in a single step or in several
steps using primers, sealers, printing, top coating, touch-up opera-
tions. These process steps may be done in a single spray booth or in a
series of booths, separated by flash-off areas and ovens. The purpose
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FROM
MACMINF SHOP
PRIME COAT. Fl ASHOFF AREA
AND OVEN
(OPTIONAL)
CIEAMSING AND
PRFTREATMENT
FLOWCOATING
TOPCOAT OR SINGLE
COAT APPLICATION
Figure 2-1. Metal Coating Operation
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TABLE 2-1. SURFACE COATING PROCESSES AND APPLICATION METHODS
Operation
Coating process
sequence
Application method
Can coating
Two-piece
Three-piece
Paper coating
Fabric coating
Coil coating
Flatwood paneling
coating
Basecoat
Printing (Inks)
Overvarnish
Inside coat
End Sealing
Basecoat
Printing (Inks)
Overvarnish
Inside spray and
roll coat
Side seam spray
End sealing
One or more coats
to paper web (one
or both sides.
Single coat
Prime coat (one
or both sides)
Top coat
Grove coat
Filler
Sealer
Primer
Stain
Basecoat
Inks
Top coat
Reverse roll coating
Flexography (graphic arts)
Roll coating
Spraycoating
Spray coating
Roll coating
Lithography (graphic arts)
Roll coating
Spray and roll coating
Spray coating
Spray coating
Knife coating, reverse
roll coating,or gravure
printing
Knife coating or roll coating
Reverse roll coating
Reverse roll coating
Various methods
Reverse roll coating
Direct roll coating
Direct roll coating
Direct roll coating
Direct roll coating
Lithography and gravure print-
ing
Direct roll coating
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TABLE 2-1. SURFACE COATING PROCESSES AND APPLICATION METHODS
(Continued)
Operation
Coating process
sequence
Application method
Automotive and
light duty truck
coating (Locomo-
tives and heavy-
duty trucks.hopper
car and tank
interiors, and
paint and drum
interiors are
covered under
miscellaneous metal
parts)
Large appliance
coating
Metal furniture
coating
Magnetic tape
coating
Magnetic wire
coating
Miscellaneous metal
parts and products
coating
Prime coat
Top coat
Prime surfacer
Final repair
Prime coat
Top coat
Mostly single
coat
(If necessary:
Prime coat and
top coat)
Single coat
Single coat
Single coat
Electrodeposition
Manual or automatic spray
coating with or without use
of electrostatic techniques.
Spray applicators include car
electrostatic rotary atomizers
(minibells), robot electro-
static airsprayguns, automatic
electrostatic air spray guns,
hand held electrostatic air
spray guns, and hand held
conventional air spray guns.
Manual or automatic spraying
(Same as for Top coat)
Dip coating, flow coating, or
electrostatic spraying
Electrostatic spray coating
Electrostatic or conventional
spray coating, dip coating,
flow coating, or powder
coating
Roll coating
Coating bath
Electrostatic or conventional
spray coating, dip coating,
flow coating, or powder
coating
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TABLE 2-1. SURFACE COATING PROCESSES AND APPLICATION METHODS
(Concluded)
Operation
Coating process
sequence
Application method
Architectural
coating
Aerospace coating
Wood furniture
coating
Ship and boat
Plastic parts for
business machines
coating
Adhesive coating
Flexible and rigid
disc manufacturing
Flexible vinyl and
urethane coating
Traffic paints
Single coat
Prime coat
Top coat
Maskin
Prime coat
Top coat (may be
more than one)
Single coat
Single coat
Single coat
Single coat
Urethane -single
coat
Vinyl-Base coat
Top coat
Single coat
Brush coating, roll coating,
or spray coating
Spray coating
Spray coating
Flow coating
Spray coating
Spray coating
Roll coating, spray coating,
brush coating
Spray coating
Roll coating
Dip coating
Roll coating
Roll coating
Spray coating
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of the flash-off is to allow solvent to rise to the surface of the coat-
ing before high temperature curing operations can occur. In air dried
coatings, which do not use ovens, the flash-off operation and the drying
operation become indistinguishable.
The coating is dried or cured using direct (gas-fired) or indirect
methods (ultraviolet and infrared).
For automobile coatings, a new paint coating technology, base
coat/clear coat (BC/CC), is used mainly for top coat and final repair
operations. BC/CC is a two step coating process (as opposed to the con-
ventional one solid color operation) in which a metallic or color base
coat is applied followed by a clear coat.
2.2 VOC EMISSIONS AND COATING FORMULATIONS
According to the EPA definition, a VOC is any organic compound
which participates in atmospheric photochemical reactions. This
includes any organic compound other than those listed in Table 2-2,
determined to have negligible photochemical reactivity. For purposes of
determining compliance with emission limits, VOC will be measured by the
approved test methods. Where such a method also inadvertently measures
compounds with negligible photochemical reactivity, generally the State
Implementation Plan allows an owner or operator to exclude these negli-
gibly reactive compounds when determining compliance with an emissions
standard^.
The main source of the VOC emitted from surface coating operations
is from the solvents used in the paint formulations, used to thin the
paints at the coating facility, or used for cleanup. The VOC emitted
from paint solids or products of.condensation from reactive coatings,
i.e., "cure-volatiles" may be a significant factor for some coatings.
Reduced monomer and low molecular weight organic compounds can be emit-
ted from some coatings that do not include solvents. The primary emis-
sion points are the coating application areas, the ovens, and the flash-
off areas.
A typical coating consists of solids and liquid solvents. The
solids fraction contains pigments and resins (binders or film formers),
and at times plasticizers. The solvent fraction may include VOC
2-6
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TABLE 2-2. EXEMPT SOLVENTS3.a
Methane
Ethane
1,1,1-trichloroethane (Methyl chloroform)
Methylene chloride
Tri chlorotri f1uoroethane(CFC-113)
Tri chlorof1uoromethane(CFC-11)
Dichlorodifluoromethane (CFC-12)
Chlorodifluoromethane (CFC-22)
Tri f1uoromethane(CFC-23)
Di chlorotetraf1uoroethane (CFC-114)
Chl oropentaf 1 uoroethane (CFC-115)
a) These organic compounds have been determined to have negligible pho-
tochemical reactivity.
2-7
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(solvents), exempt solvents, and water. Table 2-3 shows the types of
coatings and solvents used for different coating operations.
Solvents used in coatings include: aromatic hydrocarbons (toluene,
xylene), aliphatic hydrocarbons (heptane, hexane, mineral spirits, naph-
tha), ketones (methyl ethyl ketone, methyl isobutyl ketone, acetone),
alcohols (methanol, ethanol, isopropanol, butanol), acetates (ethyl
acetate), chlorinated solvents (methylene chloride, trichloroethane),
esters, ethers, and turpenes.
Coatings are used to protect surfaces or provide decorative and
functional requirements. Different types of coatings are used in sur-
face coating operations. Conventional coatings normally contain 70 to
80 percent solvent. Waterborne coatings are those that contain water as
a solvent or diluent. Merely having water in a coating, however, does
not ensure that the coating complies with applicable regulations as many
water borne coatings also contain VOC. "High solids" coatings, that
commonly have solids contents greater than 60 percent, have a reduced
VOC content. Powder coatings, that typically contain from less than 1
percent to 2 percent, may emit small amounts of monomer or low molecular
weight components during the cure cycle; they require special electro-
static application. Other types of coatings used include: two-part cat-
alyzed coatings; hot melts; and radiation cured (ultraviolet and elec-
tron beam) coatings and inks.
2.3 VOC EMISSION REGULATIONS AND COMPLIANCE REQUIREMENTS
Emissions of volatile organic compounds (VOCs) from surface coat-
ing operations may be limited by various environmental regulations.
State Implementation Plans (SIPs) for ozone nonattainment areas contain
regulations limiting VOC emissions from surface coating operations. SIP
regulations apply to existing sources and require at least reasonably
available control technology (RACT) as defined in Control Technique
Guidelines (CTGs). SIP regulations can be more stringent than the RACT
limits. In areas where the ozone standard is being attained, the SIP
may or may not contain any VOC emission limitations for surface coating
operations. Other regulations that might limit VOC emissions from sur-
face coating operations are New Source Performance Standards (NSPS) 'dnd
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TABLE 2-3. COATINGS AND DILUENTS USED BY
SURFACE COATING OPERATIONS
Operation
Type of coating used
Solvents/diluents used
Can coating
Paper coating
Fabric coating
Coil coating
Flatwood panel
ling coating
Automotive and
light duty
truck coating
Solvent borne, water-
borne
Solventborne, rubber
adhesive, glaze
waterborne coatings
Solvent borne, water-
borne, latex, acrylics
polyvinyl chloride,
polyurethane, natural
and synthetic rubber
Solvent borne, acry-
lic, alkyd, epoxy,
fluorocarbon, phe-
nol ic.organosol ,
plastisol, polyester,
si 11 cone, vinyl
Lacquer, polyurethane,
alkyd-urea, vinyl
polyester
Acrylic, polyester
enamel, alkyd resin
Aromati c hydrocarbons,
aliphatic hydrocarbons,
ketones,alcohols, acetates,
chlorinated hydrocarbons
Aromatic hydrocarbons,
ketones, alcohols
Aromatic hydrocarbons
Aromatic hydrocarbons,
ali phati c hydrocarbons,
kstones, alcohols,
acetates,chlori nated
hydrocarbons
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones, alcohols,
acetates,chlori nated
hydrocarbons
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones, alcohols,
acetates, chlorinated
hydrocarbons
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TABLE 2-3. COATINGS AND DILUENTS USED BY
SURFACE COATING OPERATIONS
(Continued)
Operation
Type of coating used
Solvents/diluents used
Large appli-
ance coating
Metal furni-
ture coating
Magnetic tape
coating
Magnetic wire
coating
Miscellaneous
metal parts
and products
coating
Architectural
coating
Epoxy, epoxy-acrylic,
polyester enamels,
resin
Alkyd resin, enamel
Magnetic oxide
Polyester amide,
polyester, polyure-
thane, epoxy, vinyl
All forms
Alkyds, vinyls, acry-
lics
Esters, ketones, aliphatic
hydrocarbons,alcohols,
aromatic hydrocarbons,
ethers, and terpene
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones,alcohols, acetates,
chlorinated hydrocarbons
Tetrahydrofuran
Aromatic hydrocarbons,
ali phati c hydrocarbons,
ketones, alcohols,
chlorinated hydrocarbons.
(Cresylic acid and various
cresols are major solvents.
Xylene and mixtures of
C8-C12 Aromatic hydrocar-
bons are widely used.)
Aromatic hydrocarbons,
ali phati c hydrocarbons,
ketones, alcohols,
acetates, chlorinated
hydrocarbons
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones, alcohols,
acetates
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TABLE 2-3. COATINGS AND DILUENTS USED BY
SURFACE COATING OPERATIONS
(Concluded)
Operation
Type of coating used
Solvents/diluents used
Aerospace
coating
Wood furniture
coating
Ship and boat
coating
Plastic parts
for business
machines
coating
Adhesive
coating
Flexible and
rigid disc
manufacturing
coating
Flexible vinyl
and urethane
coating
Traffic paints
Epoxy, epoxy-acrylic,
acrylic, polyester
enamel, alkyd resin,
waterborne coatings
Lacquer, urethane
Epoxy, epoxy-acrylic,
acrylic, polyester
enamel, alkyd resin
Vinyl, acrylic
Adhesive
Plastisol, vinyl,
urethane
Urethane
Vinyl
Alkyd
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones, alcohols,
acetates, chlorinated
hydrocarbons
Aromatic hydrocarbons,
alcohols, acetates
Aromatic hydrocarbons,
aliphatic hydrocarbons,
ketones, alcohols,
acetates, chlorinated
hydrocarbons
Tetrahydrofuran, ketones,"
acetates
Aromatic hydrocarbons,
aliphatic hydrocarbons
Tetrahydrofuran
Alcohols
Ketones
Aromatic hydrocarbons,
aliphati c hydrocarbons
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requirements of new source review (NSR) including prevention of signifi-
cant deterioration (PSD) of air quality and permits for new sources
locating in nonattainment areas, all of which apply to new sources.
Appendix A summarizes CTG limits and NSPS limits for each surface coat-
ing operation. Appendix A also lists those State limits that are more
stringent than or different from the CTG limits. These State limits may
not reflect recent changes that State or local agencies have made to
surface coating regulations.
SIP surface coating VOC emission limitations generally are
expressed as mass of VOC per unit volume of coating less water and
exempt solvents, i.e. pounds of VOC per gallon of coating less water and
exempt solvents. The only exception is that the limit for flatwood pan-
eling coating is stated in terms of pounds of VOC per 1,000 square feet
of finished product. NSPS surface coating VOC emission limitations are
generally expressed in terms of VOC emitted per unit volume as applied
solids, i.e. pounds of VOC per gallon of applied solids.
To meet surface coating VOC limits, sources can use coatings that
comply with the VOC emission limit or install control equipment that
will reduce the emissions from noncompliant coatings to the level
required by the regulations. In addition, some SIPs allow sources to
use a combination of compliant coatings and control equipment to comply
on a net facility-wide basis4. Regardless of the method of compliance
with the regulations, EPA's ozone policy requires continuous compliance.
SIPs generally require compliance on a line-by-line, if not a color-by-
color, basis over some period of time, usually daily.
Another approach that is used in paint spraying operations to
reduce VOC emissions is through improvement in the transfer efficiency
(TE) of paint application equipment. Sources may use the improvement in
TE for achieving equivalent compliance with SIP limitations if the SIP
allows this approach. Some State regulations for automotive assembly
plants allow for equivalence to be achieved through improved transfer
efficiency in addition to the use of add-on controls or other means.
For equivalency purposes, EPA has established, through later guidance
concerning CTGs, baseline TE for spray'applications in several surface
coating operations^. As seen from Appendix A, baseline TEs have been
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established in CTGs, (i.e. through later guidance) for spray applica-
tions in automotive assembly plants, surface coating of large appli-
ances, and surface coating of metal furniture. TE is also a major com-
ponent of the VOC control approach incorporated by EPA in the NSPS for
these sources. Transfer efficiency is defined as the ratio of the amount
of coating solids deposited on the coated part to the total amount of
coating solids used, and is usually expressed as a percent. Basically,
TE is a reflection of the fact that more coating must be used than that
which actually coats the product because spray systems are not 100 per-
cent efficient. The choice of the spraying method -- air atomization,
electrostatic, or other - is a factor in determining the amount of
"overspray," that is, the amount of sprayed coating that misses or does
not adhere to the article being coated. The configuration of the sur-
face to be sprayed is another factor influencing the amount of over-
spray. For conventional spraying, TE can be extremely low. Higher TEs
are claimed with electrostatic spray equipment.
2.4 VOC CONTROL EQUIPMENT
An add-on control system includes the capture device and the con-
trol device. A capture device may be a hood over a roll coater which
intakes the VOC emissions and ducts the emissions to a control device.
Another example of a capture device is complete enclosure around a coat-
ing line which intakes all VOC emissions from the process and ducts the
emissions to the control device. If the capture efficiency is poor,
then poor VOC control results. Only the amount of VOC captured can be
retained or destroyed by a control device. To determine compliance for
sources using add-on controls for reducing VOC emissions, the inspector
should emphasize the necessity of capture efficiency determination to
the surface coating source. Currently, the Agency is working on estab-
lishing a test method to determine capture efficiency.
Examples of control devices used in the surface coating industry
are: carbon adsorbers, incinerators, and refrigeration systems.
Refrigeration systems may be used in conjunction with a carbon adsorber.
A carbon adsorber removes VOC from air streams by molecular
adsorption of the VOC onto the surface of a bed of activated carbon.
The VOC contaminated stream is forced through the carbon bed and the
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carbon adsorbs the organic materials. Periodically, the carbon bed must
be regenerated with steam or inert gas to purge the organics. Typically,
the organics are recovered with a condenser. If the carbon adsorber is
not regenerated, breakthrough will occur. Breakthrough means that the
carbon cannot adsorb any additional organic materials and therefore, the
organic materials pass through the device and are emitted to the atmo-
sphere.
Incinerators destroy VOC by oxidizing the organics in the stream
to carbon dioxide (C02) and water (H20). Two types of incinerators are
used by surface coaters to destroy VOC: thermal and catalytic. The tem-
perature in the combustion chamber of a thermal incinerator should be at
least 1,400 °F to destroy the VOCs. The temperature required to destroy
the VOCs is dependent upon the VOC content of the gas stream. A cat-
alytic incinerator uses a catalyst such as platinum to reduce the VOC
combustion temperature. As a result, catalytic incinerators require
about 600 to 700 °F combustion chamber temperature to combust the VOCs.
The lower temperature needed reduces the fuel consumption by the incin-
erator and therefore reduces operating costs. Other factors which
influence the incinerator's destruction efficiency are turbulence and
time. The combustion chamber must have sufficient turbulence to mix the
VOC-laden stream so that almost all organics are destroyed. Likewise,
the organics must remain in the combustion chamber for a sufficient time
period for complete combustion to occur. Residence times as low as 0.3
seconds to several seconds have been utilized in thermal incinerators
while almost negligible residence time is needed in catalytic incinera-
tors.
Refrigeration systems or condensers are used to remove organic
materials that could cause overloading or poisoning of the main pollu-
tion control device. A refrigeration system achieves this purpose by
cooling the VOC-laden gas stream to change the organic materials from
vapor to liquid. If the facility does not want the organic materials
and water to be mixed, it may choose a surface condenser. If mixing is
not of concern to the facility, it may choose a contact condenser. For
recordkeeping purposes, the most important item to record is the inlet
and outlet temperatures of the cooling fluid. If these temperatures are
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not significantly different, there may be a problem with the refrigera-
tion system that is allowing uncondensed VOC to be carried to the main
pollution control device which could cause malfunction.
Table 2-4 lists the types of control devices most often used by
various types of surface coating operations.
2.5 VOC MEASUREMENT METHODS
Two EPA reference test methods are generally used to quantify VOC
emissions from surface coating and graphic arts sources: Methods 24 and
25. Reference Method 24 is used to determine the volatile matter con-
tent, water content, density, volume solids (nonvolatile matter), and
weight solids of surface coatings. This method includes specific ASTM
procedures to obtain these coating parameters. In accordance with EPA
policy, however, the solids volume content of the coating is determined
by calculation using the manufacturer's coating formulation. Reference
Method 24 enables the facility and inspector to determine the VOC weight
fraction, water weight and volume fraction, density, and solids weight
fraction data for the coating.
For coatings containing water, Reference Method 24 includes an
additional procedure to subtract the water from the total volatile con-
tent. EPA has not formally accepted any analytical method for determin-
ing the amount of exempt solvents in a coating. EPA has issued guidance
that exempt solvents should be subtracted from the total volatile con-
tent just like water6. ASTM has adopted a method for determining the
concentration of methylene chloride and 1,1,1-trichloroethane in coat-
i ngs.
Though Reference Method 24 is found suitable for most surface
coatings, it may not be applicable to publication rotogravure printing
inks, which typically contain relatively high boiling solvents. A modi-
fied test procedure, referred to as Reference Method 24A is recommended
for the determination of volatile matter content and density of publica-
tion rotogravure printing inks and related coatings. There may be other
categories of coatings, such as radiation-cured coatings and inks, for
which Reference Method 24 is not appropriate. For these coatings, other
procedures may be substituted with EPA's approval.
2-15
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TABLE 2-4. CONTROL DEVICES USED BY SURFACE COATING OPERATIONS
Operation
Can coating
Paper coating
Fabric coating
Coil coating
Flatwood paneling
coating
Automotive and
light
duty truck
coating
Large appliance
coating
Metal furniture
coating
Magnetic tape
coating
Magnetic wire
coating
Miscellaneous
metal
parts and
products
coating
Control device
Carbon
adsorber
X
X
X
X
X
Incinerator
Thermal
X
X
X
X
X
X
X
X
X
X
X
Catalytic
X
X
X
X
X
X
X
X
X
X
Condensers
X
X
None
2-16
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TABLE 2-4. CONTROL DEVICES USED BY SURFACE COATING OPERATIONS
(Concluded)
Operation
Architectural
coating
Wood furniture
coating
Ship and boat
coating
Plastic parts for
business
machines coating
Adhesive coating
Flexible and
rigid disc
mfg. coating
Traffic paints
Control device
Carbon
adsorber
X
X
X
Incinerator
Thermal
X
X
X
Catalytic
X
X
X
Condensers
None
X
X
X
X
2-17
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Reference Method 25 is used to determine the total gaseous non-
methane organic (TGNMO) emissions as carbon. In certain specific cir-
cumstances, Reference Methods 18, 25A, and 25B can be used instead of
Method 25. Copies of the existing emission measurement methods, i.e.,
Reference Test Methods 24, 24A, and 25, are included in Appendix C.
EPA is in the process of developing and finalizing other measure-
ment methods. A procedure for determining the VOC emission rate from
automobile and light-duty truck topcoat operations is published?. It
provides measurement methods of transfer efficiency and bake oven
exhaust VOC content. EPA is also in the process of developing new pro-
cedures for determining the efficiency of a capture device, such as an
enclosed room, hood, "floor sweep" or other means of containing or col-
lecting VOC in order to direct it to a control device such as a carbon
adsorber or incinerator.
2-18
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2.6 REFERENCES FOR CHAPTER 2
1. Control of Volatile Organic Emissions from Existing Stationary
Sources Volume III: Surface Coating of Metal Furniture. EPA-
450/2-77-032, U.S Environmental Protection Agency, Research
Triangle Park, NC, December 1977.
2. May 25, 1988 Memorandum from Ozone/Carbon Monoxide Program
Branch, AQMD, OAQPS to Air and Hazardous Materials Divisions,
Regions I-X. Issues Relating to VOC Regulation - Cut Points,
Deficiencies, and Deviations. Clarification to Appendix D of
November 24, 1987 Federal Register.
3. July 22, 1980 Federal Register. Volume 45, No. 142
4. December 4, 1986 Federal Register Volume 51, No. 233, Page
43814, Notices
5. July 3, 1979 Memorandum from R.G. Rhoads, Director, Control
Programs Development Division to Air and Hazardous Materials
Divisions, Regions I-X. Appropriate Transfer Efficiency for
"Waterborne Equivalence"
6. June 29, 1983 Memorandum from G.T Helms, Chief, Control
Programs Operations Branch to Air Branch Chiefs. Exclusion of
Exempt Solvents from VOC Calculations.
7. Protocol for Determining the Daily Volatile Organic Compound
Emission Rate of Automobile and Light-Duty Truck Topcoat
Operation. EPA-450/3-88-018, U.S. Environmental Protection
Agency, Research Triangle Park, NC, December 1988.
2-19
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3. RECORDKEEPING PROCEDURES
The purpose of this chapter is to provide guidance to the minimum
data owners of surface coating operations must maintain. Such informa-
tion can be used by State agency and EPA enforcement officials, in addi-
tion to the source, to determine the compliance status of these sources.
The minimum data that must be maintained is specified in Section 3.1.
Standard forms that surface coating sources can use to maintain their
records are presented in Section 3.2.
3.1 RECORDKEEPING NEEDS AND REQUIREMENTS
In order to determine whether a surface coating operation is in
compliance with the VOC emission regulations applicable to it, records
of coatings used and other process data must be maintained. Some State
Implementation Plans (SIPs) contain general provisions requiring record-
keeping, but recordkeeping requirements contained in SIPs are seldom
detailed. The NSPS for surface coating operations contain recordkeeping
requirements. Many construction permits issued under New Source Review
have quite specific recordkeeping requirements as permit conditions.
The minimum recordkeeping data that must be maintained by a surface
coating operation includes the following:
• Coating formulation and analytical data
• Coating consumption data
' Capture and control equipment performance data
• Spray applicator transfer efficiency data
• Process information
These minimum data requirements are applicable to sources subject to SIP
regulations. Specific data requirements in each of these operations are
discussed in more detail below. Facilities are required to submit only
those data applicable to their specific operations. If, for example, a
source uses only compliant coatings to comply with the regulation, there
is no need to submit control equipment or transfer efficiency data.
3-1
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Sources subject to NSPS or special construction or operating permit con-
ditions may have other requirements specific to those regulatory pro-
grams .
3.2 STANDARD FORMS
Standard forms that can be used to maintain the minimum essential
data are shown in Figures 3-1 through 3-6. The General Information form
in Figure 3-1 should be included with each data submission. The pri-
mary purpose of this form is to identify the source of the data. The
Facility Contact should be the Plant Manager or an equivalent plant
official. Although it is not mandatory that sources use these forms,,
they do provide the minimum data required. If the source chooses to use
different forms, those forms must contain the same data. A facility is
required to complete only those forms which are applicable to its opera-
tions. For example, if a facility only uses compliant coatings, the
forms for Control Equipment and Transfer Efficiency would not be submit-
ted. A facility should submit new Control Equipment and Transfer
Efficiency Data only when new data become available such as new test
data. The General Information, Process Information, Coating
Formulation, and Coating Consumption forms should be submitted as
required on a recurring basis.
Figure 3-2 is the form to be used to provide process information
for each coating line or press for which recordkeeping data are pro-
vided. This form should be completed for the initial submission and
revised when changes are made to the coating line. Additional process
information is needed for some sources. For flatwood paneling coating,
the emission limit is expressed in terms of emissions per unit of pro-
duction such as pounds of VOC per 1,000 square feet of finished product.
Sources subject to such emission limitations must also maintain records
on production in a format compatible with the regulation and consistent
with the time frame for which coating consumption data are maintained.
Information on the method for determining compliance must also be main-
tained if the facility is subject to a bubble under EPA's Emission
Trading Policy. A plant subject to a bubble may have an emission limit
in terms of pounds per day that is applicable to a number of coating
lines or presses.
3-2
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GENERAL INFORMATION
Facility Name
Facility Address
Facility Contact
Title
Telephone Number
Figure 3-1. Recordkeeping Form for General Information
3-3
-------
PROCESS INFORMATION
Date of Report:
Coating Line:
Job ID:
Hours of Operation:
Method of Application:
Rol1er
Dip
Spray:
hrs/day,
days/wk,
wks/yr
Electrostatic (Gun Voltage
Air assisted/airless
Low Pressure High Volume (LPHV)
Hand-held
Automatic
Robotic
Number of Coats:
Primer
Top Coat
Clear Coat
Other
Drying Method:
Air Dry _
Oven Dry,
Bake,
Radiation
Substrate type:
Wood
Metal
Plastic _
Paper
Other
Min
Min
Substrate form:
Web fed
Sheet fed
Other
Figure 3-2. Recordkeeping Form for Process Information
3-4
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Date:
COATING DATA
CO
I
en
Data
Supplier Name
Name and Color of Coating
Type of Coating (primer, clearcoat, etc.)
Identification Number for Coating
Coating Density (Ibs/gal)
Total Volatiles Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
VOC Content (wt%)
Solids Content (vol%)
Diluent Properties:
Name
Identification Number
Diluent Solvent Density (Ibs/gal)
VOC Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
Diluent/Solvent Ratio (gal diluent
solvent/gal coating)
Coating
1
Coating
2
Coating
3
Coating
4
Note: If the solids content is not available from the manufacturer as a volume percent,
it should be calculated. A copy of this calculation must be provided.
Figure 3-3. Recordkeeping Form for Coating Data
-------
00
I
CTt
Coating Line:.
COATING CONSUMPTION DATA
Units:
To:
Date:
Coating
ID
Amount
Used
Di 1 uent
ID
Amount
Used
Date:
Coating
ID
Amount
Used
Diluent
ID
Amount
Used
Note: If the data are not on a daily basis, indicate the time frame.
Figure 3-4. Recordkeeping Form for Coating Consumption Data
-------
CONTROL EQUIPMENT DATA
COMPLETE FOR EACH CONTROL DEVICE:
Control Device ID No. Model
Manufacturer
Installation Date: Date of Report
Coating Line(s) Controlled:
Is the control equipment always in operation when the line(s) it
is serving is (are) in operation? (yes/no)
Control Device:
Type:
Carbon Adsorption Unit
Incinerator: Thermal Catalytic
Refrigeration/Condensation
Other
Destruction or Removal Efficiency (%):
When was it tested:
If a test was not conducted, how was the destruction or
removal efficiency determined
Figure 3-5. Recordkeeping Form for Control Equipment Data
3-7
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CONTROL EQUIPMENT DATA
For a Thermal Incinerator:
Combustion Temperature (°F)*:
For a Catalytic Incinerator:
Exhaust Gas Temperature (°F)*:
Change in Temperature across Catalyst Bed (AT)
Date of Last Change of Catalyst in Bed:
For a Condenser:
Inlet Temperature of Cooling Medium (°F):
Outlet Temperature of Cooling Medium (°F):
Emission Test Results:
Inlet VOC Concentration (ppm):
Outlet VOC Concentration (ppm):
How were inlet and outlet concentrations determined:
When were these concentrations determined:
* Continuous Monitoring Data. Must be available for inspection by
enforcement officials.
Figure 3-5. Recordkeeping Form for Control Equipment Data (Continued)
3-8
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CONTROL EQUIPMENT DATA
Capture Efficiency:
Type:
Hood
Floor Sweep
Enclosure
Other
Efficiency (%)
How was capture efficiency determined:
Is the capture equipment always in operation when the
line(s) it is serving is (are) in operation? (yes/no)
Figure 3-5. Recordkeeping Form for Control Equipment Data (Concluded)
3-9
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TRANSFER EFFICIENCY DATA
NOTE: Complete this form for each coating line to which a determination
of transfer efficiency is important for determining compliance
with the applicable emission limit. Complete a separate form for
each set of lines that have a different transfer efficiency. A
copy of all recent EPA Reference Method 24 tests for as applied
coatings should be appended to this form.
Date of Report
Coating Lines to Which the Transfer Efficiency Applies:
Baseline Transfer Efficiency (%):
Actual Transfer Efficiency
How was this actual transfer efficiency determined?
If a test was conducted, what is the date of the most recent test?
What is the split in VOC uncontrolled emissions between the application
area and the oven?
Application Area (%) Oven (%)
How was the application area/oven split determined:
Date of most recent test:
Figure 3-6. Recordkeeping Form for Transfer Efficiency Data
3-10
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Coating data, as shown in Figure 3-3, must be provided for each
coating used by the facility. The coating data will be "as supplied" or
"as applied". The "as applied" coatings differ from the "as supplied"
coatings when additional solvents or other diluents are added prior to
application to the substrate. If no diluents are added to the coatings
at the source, the "as applied" coatings are the same as the "as sup-
plied" ones. SIP regulations for VOC surface coating operations are
applicable to "as applied" coatings. The coating manufacturer normally
provides the "as supplied" coating data (coating formulation) to the
user of the coating. The user obtains the "as applied" coating data
using "as supplied" coating data and diluent data. (See Reference 1.)
Coating and diluent formulation data can be obtained from the VOC
Data Sheets1 or in some cases from Material Safety Data Sheets (MSDSs)
provided by the coating suppliers. The preferred source of coating for-
mulation data is from VOC Data Sheets completed as a result of a
source's tests of its "as applied" coatings. MSDSs are commonly avail-
able at surface coating operations because of the need to comply with
worker right-to-know regulations. They typically contain coating formu-
lation data that can at times be used to supplement information on the
EPA VOC Data Sheets. However, MSDSs do not always contain sufficiently
accurate or complete VOC data. Manufacturers' specification sheets may
provide more complete information on VOC content. However, production
variables may result in individual batches which have VOC contents
higher than those expected from using MSDSs or manufacturers' specifica-
tion data.
Coating suppliers can test their coatings using EPA Reference
Method 24 (RM-24)1 for determining the VOCs contained in specific coat-
ings. Reference Method 24A (RM-24A)2 must be used for publication
rotogravure inks. If EPA VOC Data Sheets are available, they must also
be maintained as part of the recordkeeping requirements. If diluents
are added to the coatings prior to application, the "as applied" coating
information can be calculated using the "as supplied" information for
the coating and diluent or from the results of RM-24 or RM-24A tests
conducted on the facility's "as applied" coatings.
The coating formulation data that must be submitted includes the
name of the supplier, the name of the coating, the color of the coating
3-11
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if the color is used as part of its name, an identification number for
the coating that can be used to relate consumption data for that coating
to its formulation data, the density of the coating, the total volatile
content of the coating by weight percent, the water content of the coat-
ing by weight percent, the percentage by weight of the coating that con-
sists of exempt solvents as identified in Table 2-2, the percent by
weight of the coating that consists of VOC (if available), the total
solids or nonvolatile content of the coating by volume percent. Because
the regulations require a determination of the "as applied" coating for-
mulation, the formulation of diluents and the quantity of diluents con-
sumed must be provided. Data must also be provided for any diluents and
solvents used for clean-up operations if such solvents are regulated by
the SIP as they are in Texas. For diluents or solvents used for clean-
up, the name of the solvent, its identification number which can be used
to relate its consumption data to its formulation data, its density, the
percent by weight of the diluent that consists of VOCs, i.e., excluding
water and exempt solvents, and the ratio of the diluent in gallons added
to a gallon of the coating must be provided.
In conjunction with the coating formulation data, coating consump-
tion data, as shown in Figure 3-4, are basic data needed to calculate
VOC emission rates. Coating consumption data are to be provided for
each coating line on a time-frame consistent with the SIP. The defini-
tion for "coating line" in the SIP must be used in reporting data by the
facility. The basic coating consumption data are the coatings used and
the quantities consumed. The identification of the coatings for which
consumption data are reported must be related to the identification of
the coatings in the coating formulation data. In addition, data must be
provided on the amounts of diluents and clean-up solvents consumed.
(Some states including Texas regulate clean-up solvents.) The diluent
solvent coating ratio must be calculated for the compliance period for
which the report is prepared.
In Chapter 2, there is a discussion of the add-on control devices
that have been typically used to control VOC emissions from surface
coating operations. Figure 3-5 is a form that can be used to provide
the minimum data required for control devices and their associated VOC
3-12
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capture systems. The two main types of control devices used in the sur-
face coating industry are incineration and carbon adsorption.
Refrigeration/condensation systems are occasionally used for controlling
VOC emissions from surface coating operations but are much less common
than incineration or carbon adsorption systems. When refrigera-
tion/condensation systems are used, they are often used in conjunction
with incinerators or carbon adsorption units. Incineration can be
either thermal or catalytic. For thermal incinerators, the owner or
operator must monitor and maintain records on the temperature in the
combustion chamber which can be used as an indicator that the incinera-
tor is operating properly. These continuous monitoring data must be
available for inspection by enforcement officials. For catalytic incin-
erators, data on the changes of the catalyst in the beds must be kept in
addition to the combustion temperature. Basic data maintained for
refrigeration/condensation systems include the inlet and outlet tempera-
tures of the cooling medium. The estimated destruction or removal effi-
ciency of the control device must be recorded. Inlet and outlet concen-
trations for incinerators, carbon adsorption units, or refrigera-
tion/condensation systems must be provided based upon the latest source
test results that are available. Detailed reports of the results of
source tests must be maintained as part of the facility's database.
Another major consideration in determining the compliance of sur-
face coating operations with control equipment installed is the effi-
ciency of the VOC capture system. The facility must provide the esti-
mated efficiency of its capture system and the method used to determine
that efficiency. If the facility maintains data on the lower explosive
limit (LEL) concentration in the ductwork of its VOC capture system,
such data must be available for inspection. Unless there is a change in
the control or capture system or new test data become available either
because the State or local agency has required retesting of the source
or because it has been tested for other reasons, data on efficiency of
the control equipment will normally only have to be supplied once.
For auto coating, surface coating of large appliances, and metal
furniture coating, the transfer efficiency (TE) of the coating applica-
tor system is an important consideration in determining the VOC emission
3-13
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rate and compliance with the emission limits. The CTG emission limita-
tions for these source categories were based upon typical or "baseline"
TEs applicable in these operations when the regulations were originally
adopted. As discussed in Chapter 2, EPA has defined "baseline" TEs for
these surface coating categories. Since then, advances in technology
have increased the TE that can be achieved. As a result, the emission
limitations can be achieved using a coating with a higher VOC content
than originally designated in the SIP. A source can take advantage of
the new, higher TE technology to comply only if the SJP applicable to it
includes the baseline TE upon which the emission limit is based. The
SIP must also indicate that enhancing TE is an acceptable control
option. The method used to determine the transfer efficiency must be
documented. If testing was used, the results of the test, the date of
test, and a detailed description of the test methodology used must be
available. Figure 3-6 is a form that can be used to provide transfer
efficiency data.
3.3 REFERENCES FOR CHAPTER 3
I- Procedures for Certifying Quantity of Volatile Organic
Compounds Emitted bv Paint. Ink, and Other Coatings EPA-450/3-
84-019, U.S. Environmental Protection Agency, Research Triangle
Park, NC , December 1984.
2. "Determination of Volatile Matter Content and Density of
Printing Inks and Related Coatings", 40 Code of Federal
Regulations. Part 60, Appendix A, Method 24A.
3-14
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4. DATA VERIFICATION PROCEDURES
This chapter provides guidance to State agency and EPA enforcement
officials who must verify data provided concerning a surface coating
operation. A major portion of the effort of determining the compliance
status of a surface coating operation is verification of the
owner/operator's data. Data verification activities may vary from a
routine check and comparison of the submitted data with other available
information for the facility to a thorough inspection of the facility.
After an on-site inspection, new data should be available as a result of
the inspection that can be used to verify the source's recordkeeping
data. Each of these phases of the data verification process are dis-
cussed in Sections 4.1 through 4.3.
4.1 PRELIMINARY DATA VERIFICATION ACTIVITIES
The purpose of this subsection is to provide guidance to the
enforcement official who must verify data provided concerning a surface
coating operation in order to determine its compliance status.
Enforcement officials are concerned with determining compliance primar-
ily for the purposes of verifying the source's compliance status or
developing a case for enforcement action against the source.
The minimum recordkeeping data that must be maintained by a surface
coating operation as discussed in Chapter 3 include the following:
• Coating formulation and analytical data
• Coating consumption data
• Capture and control equipment performance data
• Spray applicator transfer efficiency data
• Process information
The enforcement official should try to verify each of these types of
data. Because of the quantity of data that may be submitted, the
enforcement official will probably choose to spot-check the data.
Prior to reviewing data submitted concerning a VOC surface coating
operation to verify compliance, the enforcement official should gather
4-1
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and become familiar with any available background information on the
facility. The following are potential sources of such information:
• The applicable regulations for the facility and its individual
coating lines should be reviewed. The primary regulations that
are likely to be applicable are the State or local agency regula-
tions that are included in the SIP. The coating lines at the
facility may also be subject to NSPS. Federally enforceable per-
mit conditions should also be reviewed. The enforcement official
should verify each time that he reviews a source's data that new
sources have not been installed at the facility or that existing
sources have not been modified in such a way as to subject the
source to NSPS and new source review permitting.
• EPA databases such as the National Emissions Data System (NEDS)
and the Compliance Data System (CDS) may have information that
can be used as a starting point. For example, CDS would include
the date of the most recent inspection. Both NEDS and CDS may
contain general information on a source including emissions esti-
mates, operating data, and compliance status. However, data in
NEDS and CDS are likely to be dated in comparison with a source's
recent submission of recordkeeping data.
• The State or local agency's files will contain copies of the
agency's inspection reports and correspondence regarding the
source's compliance status between the agency and the source. In
addition, these files should contain any data that the source has
submitted to the agency.
• The source may have been asked to submit a Section 114 response.
Under Section 114 of the Clean Air Act, the EPA Administrator is
given broad authority to request information to use in determin-
ing a source's compliance with emission regulations in the SIP.
There are legal penalties if a source refuses to provide informa-
tion requested by EPA under Section 114 or provides false infor-
mation. Such a response might include considerable detail as to
the source's emissions and control technology.
The enforcement official should use all of the independent data avail-
able from these and other sources to verify the facility's recordkeeping
data.
If the source provides copies of VOC Data Sheets or Material Safety
Data Sheets, these can be used to check the coating formulation data.
4-2
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Coating formulation data from other similar sources may also be useful
in verifying the data. If diluents are added to the coatings, the coat-
ing formulation data and the consumption data should be consistent.
Many surface coating operations maintain purchasing and/or inven-
tory data on their coatings. These data are usually available on an
annual, quarterly, or monthly basis. The enforcement official should
request that the source submit the purchasing and/or inventory data
prior to verifying the recordkeeping data. By comparing these data with
the daily recordkeeping data, the enforcement official may be able to
verify the accuracy of the recordkeeping data. If there is a signifi-
cant difference between the two data sets, e.g., greater than a five
percent difference, the value of the recordkeeping data may be question-
able. Procedures that the plant uses for obtaining its recordkeeping
data may not be sufficient.
If a source has a control device, the reported control efficiency
should be verified by comparing the reported destruction and removal
efficiencies with those for similar devices used for similar sources.
The efficiency of the VOC capture system reported by the source should
also be within the range of efficiencies for similar sources. If source
tests or capture efficiency tests have been conducted, they should be
reviewed.
The initial review of the recordkeeping data may indicate that
there is a question as to the source's compliance status. It may be
decided that an on-site inspection is required to provide a more certain
verification of reported data or to develop a case for enforcement
action. In addition, the source may not have submitted all of the data
needed in order to determine compliance. If additional data are needed,
the enforcement official may at this time decide that a Section 114
letter should be sent to the source.
4.2 DATA VERIFICATION PROCEDURES DURING ON-SITE INSPECTIONS
If an on-site inspection is conducted, the inspector should make
observations and measurements which can assist in verifying the source's
recordkeeping data. The inspector should verify that data have been
provided to include all of the coatings used by the source.
4-3
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During the walk-through inspection stage of the inspector's visit,
the inspector may collect samples of the individual "as applied" coat-
ings being used at that time for EPA Reference Method 24 analysis.
Coatings should be selected for sampling based upon the enforcement
official's screening of the source's recordkeeping data to identify
those coatings which may not comply with the regulations. The enforce-
ment official may also select for sampling some coatings claimed to be
compliant coatings in order to verify the claim. The samples should be
handled in a consistent manner with a chain-of-custody, record. Duplicate
samples should be collected for analysis by an EPA laboratory or by a
consultant laboratory under contract to EPA and by the source. The
source may also choose to provide for an additional sampling of the
material in question for analysis by the coating supplier, who can func-
tion as another source of accurate analysis.
Coating equipment is generally cleaned using a VOC solvent. These
solvents and waste coatings are generally collected in 55-gallon drums
for off-site disposal at a hazardous waste disposal facility!. If waste
coatings are disposed of as hazardous waste and the source is claiming
the right to subtract significant amounts of VOCs contained in the waste
coatings from its emissions estimates, samples of the waste coatings
should be obtained for Reference Method 24 analysis. If waste coatings
are disposed of by shipping out as hazardous waste or by sending to
waste water treatment plants, data on the quantities of such waste coat-
ings disposed including their VOC content must be obtained to subtract
from the recordkeeping data. Any previous analyses of the waste coat-
ings disposed of as hazardous waste should also be obtained.
The accumulation of hazardous waste on-site, as well as off-site
transportation and disposal, are regulated under the Resource Con-
servation and Recovery Act (RCRA). The hazardous waste is generally
regulated also by the State Hazardous Waste Regulations which, for the
most part, coincide with the Federal RCRA Regulations. Under RCRA,
facilities are required to keep records of on-site accumulation and off-
site shipments1.
During the inspection, the methodology used by the source for
tracking coating consumption should be observed. A purely manual system
may have inaccuracies built into it. Estimates of coating consumption
4-4
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may vary from one individual to another as not all operators may be
keeping consumption data. Manual accounting methods may also include
calculation errors. Such observations in conjunction with a comparison
of the coating consumption data with the facility's purchasing and/or
inventory data can provide insight into the accuracy of the recordkeep-
ing data.
The operation of any control equipment should be observed during
the inspection. If the source monitors the operation of its control
equipment, records of such monitoring should be obtained. Previous test
results should be obtained and reviewed. Any unusual operation of con-
trol equipment should be observed and documented to form a basis for any
subsequent request for testing of the control device. For example, the
combustion temperature in an incinerator may differ substantially from
that when the unit was tested indicating that its destruction efficiency
may differ as well. The inspector should be particularly concerned with
the operation of the VOC capture system. By observation, he should be
able to determine qualitatively whether or not the system is operating
as claimed. Measurements with hand-held anemometers, chemical smoke, or
an Organic Vapor Analyzer (OVA) can be taken to provide a more quantita-
tive basis for determining if the capture system is operating properly.
For example, floor sweeps or hoods with a face velocity below 200 feet
per minute are unlikely to provide a high capture efficiency. High VOC
concentrations in the building as measured by an OVA are indicative of
poor capture efficiency. The control device and VOC capture system
should be operating at similar conditions as those observed during any
compliance test. Differences in operation of either during an inspec-
tion from those during the compliance test may indicate that there has
been a degradation in the overall control efficiency. If there is
reason to suspect that the capture system or the control device is not
operating properly, a new capture efficiency test and compliance test
may be warranted.
4.3 POST-INSPECTION DATA VERIFICATION PROCEDURES
After an on-site inspection or initial review of the recordkeeping
data has been completed, the enforcement official may find that addi-
tional data not submitted with the recordkeeping data or obtained during
4-5
-------
the on-site inspection may be needed. Such data could include the fol-
1owi ng:
• Additional data on coatings if the source has not submitted data
for all coatings or diluents used
• Destruction or removal efficiency test results if there is reason
to believe that the control equipment has deteriorated since the
most recent test
• Capture efficiency test results
• EPA Reference Method 24 results for "as applied" coatings and
formulation coatings if there is reason to believe that the
recordkeeping data submitted by the source are erroneous
Using these additional data, the recordkeeping data, and data from any
Section 114 response, the enforcement official should be able to judge
accuracy of the recordkeeping data and the source's compliance status.
If the recordkeeping data are inaccurate, the facility's recordkeeping
procedures may need to be changed.
4.4 REFERENCES FOR CHAPTER 4.
1. Glenn G. Draper Engineering. EPA Region 6 Air Compliance
Determination, Vol. I: Overview (draft). U.S Environmental
Protection Agency Region 6. Air Enforcement Division. EPA
Contract No. 68-02-4465, Work Assignment No. 008. September
1987.
4-6
-------
5. COMPLIANCE DETERMINATION
The primary purpose of recordkeeping as discussed in this guideline
is to obtain the data necessary to determine the compliance status of a
surface coating facility. Although the minimum data requirements out-
lined in Chapter 3 will provide the information to determine the compli-
ance status of surface coating operations, the specific calculations
using those data may differ from one operation or facility to the next.
In this chapter, the various methods that sources use to comply with the
surface coating regulations are identified. Examples of the calcula-
tions required to determine the compliance status of sources using those
methods are provided. Further examples of compliance calculations can
be found in EPA's surface coating calculations guideline1.
In general, the compliance methods can be divided into the follow-
ing three scenarios:
• Compliant coatings
• Add-on control equipment
• Alternative means, such as:
••Combination of compliant coatings and add-on controls
••Improvements in paint application methods, i.e., improved
transfer efficiency (TE)
••Bubbles
Within a given facility, each source (usually, each coating line) must
be in compliance with the regulations except where a bubble has been
obtained.
Because the CTG limitations primarily restrict the amount of sol-
vent that can be contained in a given volume of coating, compliance with
a CTG limit is based on a per coating or at least a per line basis.
When only compliant coatings are used, time averaging is never a consid-
eration in the compliance determination, and for all practical purposes,
compliance can be assumed to be continuous. The same assumptions can be
implied when an applicable CTG limit is adopted into a SIP. However,
5-1
-------
when alternative compliance options such as add-on control equipment,
bubbles, or enhanced transfer efficiencies are used, the compliance
determination must be based on equivalency calculations in terms of the
amount of VOC per unit volume of applied solids, i.e., Ib VOC/gal of
solids. This requirement is specified for the coating industries in a
March 9, 1984 EPA policy memorandum^. In such calculations, time aver-
aging of actual VOC emissions is necessary. For equivalency purposes,
some SIPs have specified averaging time periods, such as 24 hours. EPA
policy and guidance concerning VOC emission limitations for can coating
operations recommended that compliance be demonstrated on a 24-hour
basis^. Few SIPs currently mention specific time requirements.
However, most SIPs are being revised at the present time. As a result
of this revision process, specific time requirements are expected to be
included in them. The federal New Source Performance Standards (NSPSs)
require 30-day averaging.
5.1 COMPLIANT COATINGS
If the VOC content of all of the coatings used on an individual
surface coating line is less than or equal to the limit prescribed in
the regulation applicable to that line, the line is in compliance. The
compliance determination should be made daily on a coating-by-coating
basis or for the averaging time designated in the SIP and other applica-
ble regulations. Each line must comply with the emissions limit unless
the SIP allows averaging of emissions for more than one coating line at
a facility.
Coating formulation data alone are not sufficient to ensure that
the coating as applied is in compliance. Consideration must be made of
any diluents that are used with the coating and of solvents that are
used for washup or cleaning of the equipment if they are regulated by
the SIP. To determine compliance, the total VOC content of the coating
as applied must be determined including the diluents. For some surface
coating operations, the emission limit varies for different kinds of
coatings. For example, the CTG for coating of miscellaneous metal parts
and products has a separate emission limit for air or forced air dried-
items, clear coat, and powder coatings. If more than one emission limit
applies to the coatings used on a single line, a separate determination
5-2
-------
must be made for compliance with each emission limit. If any of the
solvents in the coating are exempt, they must be subtracted from the
percent volatiles along with the percent water. There also are differ-
ences in the way in which emission limits for different surface coating
operations are expressed. Many SIP regulations use limits of pounds of
VOC per gallon of applied coating less water and exempt solvents. NSPSs
use limits of pounds of VOC per gallon of solids. The CT6 for flatwood
panelling coating uses units of pounds of VOC per 1,000 square feet of
panelling. The compliance determination calculations must be consistent
with the applicable regulations.
To illustrate the computations necessary to establish the compli-
ance status of sources that rely upon the use of compliant coatings, the
following examples can be used:
• Example 5-1. A paper coater operates one paper coating line
which is subject to the CTG limit of 2.9 pounds of VOC per gallon
of coating minus water. It uses a water-based coating with VOC
solvent and solids. Coating formulation data for this line are
shown in Figure 5-1.
Using these data, the emission rate corresponding to the CTG
emission limit can be calculated as follows:
The mass of VOC per volume of coating is
9.3 1b coating 0.1 Ib VOC* _ 0.93 1b VOC
gal coating Ib coating ~ gal coating
*(50 % total volatile content - 40 wt % water content)
The mass of water in the coating is
9.3 Ib coating 0.4 Ib water 3.7 Ib water
gal coating Ib coating ~ gal coating
The volume of water in the coating is
5-3
-------
Date:
COATING DATA
en
i
Data
Supplier Name
Name and Color of Coating
Type of Coating (primer, clearcoat, etc.)
Identification Number for Coating
Coating Density (Ibs/gal)
Total Volatiles Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
VOC Content (wt%)
Solids Content (vol%)
Diluent Properties:
Name
Identification Number
Diluent Solvent Density (Ibs/gal)
VOC Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
Diluent/Solvent Ratio (gal diluent
solvent/gal coating)
Coating
1
9.3
50
40
0
10
42
Coating
2
Coati ng
3
Coating
4
Figure 5-1. Example 5-1 Data
-------
3.7 15 water 1 0.44 gal water
Y = 2
gal coating 8.33 1b water gal coating
gal water
The mass of VOC emitted per volume of coating less water is
0.93 1b VOC
gal coating 1.66 1b VOC
1 gal coating - 0.44 gal water gal coating less water
gal coating
Since the emission rate is below the CTG emission limit, the
source is in compliance.
• Example 5-2. The facility described in Example 5-1 operates
another coating line that uses a coating with the same formula-
tion as that specified in Example 5-1 except that a diluent is
added to the coating. The density of the diluent is 7.21
Ibs/gal, and the diluent is 100 percent VOC. For each gallon of
coating, a gallon of diluent is added. The resulting VOC emis-
sion rate per gallon of coating as applied would be
0.93 1b VOC 7.21 1b VOC
gal coating + gal diluent 5.22 1b VOC
2 gals coating - 0.44 gals water ~ gal coating as applied less water
As a result of adding the diluent, the coating as applied does
not comply with the regulation.
These examples demonstrate the simple situation where only a few coat-
ings are used. These calculations, however, are basic to all compliance
determinations.
Table 5-1 illustrates a more complicated situation where a number
of coatings are used on a coating line during a day and the SIP allows
for daily averaging. In this table, individual coatings are above the
emission limit of 2.9 Ibs/gal, and a diluent is used with some of the
coatings. Yet, the line is in compliance on a daily basis.
5-5
-------
TABLE 5-1. COMPLIANCE DETERMINATION FOR A LINE USING MULTIPLE COATINGS3
en
cr>
Coating
ID
101
102
103
104
105
106
107
108
109
ZOO
(Diluent)
Amount
Used,
Gallons
53
12
34
78
101
23
54
11
25
22
Density,
Ib/gal
9.3
11.2
12.3
10.1
9.4
12.7
9.9
11.0
8.5
7.2
Total
Volatiles
Content, wt%
50
40
30
45
55
25
70
40
70
100
VOC
Content,
wt%
10
15
8
15
15
12
20
10
10
100
Water
Content,
wt%
40
25
22
35
40
13
50
30
60
0
Coati ng
Minus
Water,
Gallons
29. y
8.0
23.0
44.9
55.4
18.4
21.9
6.6
9.7
22.0
VOC
Content,
lb/galb
1.7d
2.5
1.5
2.6
2.6
1.9
4.9
1.8
2.2
7.2
VOC
Emissions,
IDS
49.8
20.0
34.5
116.7
144.0
35.0
107.3
11.9
21.3
158.4
Total
413
239.2
698.9
VOC Emission Rate
(Ibs/gal of coating minus water)
2.9
a) Values in the last three columns were calculated using data in the of the columns of the Table.
b) Ibs VOC/gal coating less water
c) Example calculation of coating minus water, gallons -
ter Content^
- wt% — xf l- 1
100 J Density of water
I Ibs/gal J
d)
/Amount oA
coating
used
V gallons /
( Amount of >
coating used
^ gallons
r (53X9.3X
v (°
Xl
0.40
8.33
= 29.3 gallons coating minus water
Example calculation of VOC content, Ib VOC/gal coating less water -
fVOC content^
I wt% I
(,_Am°U.n_t .°L] . ^ensity^ „ I 100 J
i . j i i—...-..^ v iot
coaqaTigonuss x ^lb/galJxrcoa*1n9m1nus *aten
^ 9 •> \ gallons J
53 X 9.3 X 0.10
29.3
= 1.7 Ibs VOC/gal coating less water
-------
As mentioned earlier, some of the emission limits for surface coat-
ing operations are expressed in units other than pounds per gallon of
coating as applied. If the applicable regulation is expressed in the
units of Ibs VOC per gal solids as are the NSPSs, a further calculation
beyond those illustrated in the previous examples is necessary. For
example, the NSPS for exterior base coatings used in can coating opera-
tions except clear base coating operation is 2.4 Ib/gal of coating
solids. A coating used at a particular facility had a formulation as
shown in Figure 5-2. The VOC content is the total volatiles content (53
percent) minus the water content (30 percent) or 23 percent by weight.
Emissions in terms of pounds per gallon of solids would be calculated as
follows:
Pounds of VOC per gallon coating =
0.23 Ib VQC 9.1 Ib coating _ 2.1 Ib VOC
Ib coating gal coating gal coating
Pounds of VOC per gallon solids =
2.1 Ib VOC gal coating _ 5.38 Ib VOC
gal coating 0.39 gal solids ~ gal solids
Emission limits for surface coating operations that are expressed
in terms of pounds per gallon of solids may also include the need to
determine the transfer efficiency of the application. An example of
calculating equivalent emission rates using the transfer efficiency is
given in Section 5.4.
For surface coating of flatwood paneling, the units of the CTG
emission limit are pounds of VOC per 1,000 square feet of paneling. For
this surface coating category, the production rate in terms of 1,000
square feet per unit time and the application rate of the coating in
terms of gallons per unit time must be known in addition to the coating
formulation data. The weight percent of volatiles minus the weight per-
cent of water, i.e., the weight percent of VOC, would then be multiplied
by the production rate and the application rate as follows:
5-7
-------
Date:
COATING DATA
en
00
Data
Supplier Name
Name and Color of Coating
Type of Coating (primer, clearcoat, etc.)
Identification Number for Coatina
Coating Density (Ibs/gal)
Total Volatiles Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
VOC Content (wt%)
Solids Content (vol%)
Diluent Properties:
Name
Identification Number
Diluent Solvent Density (Ibs/gal)
VOC Content (wt%)
Water Content (wt%)
Exempt Solvent Content (wt%)
Diluent/Solvent Ratio (gal diluent
solvent/gal coating)
Coati ng
1
9.1
53
30
0
23
39
Coati ng
2
Coati ng
3
Coating
4
Figure 5-2. Example Formulation Data for Calculating Ibs VOC/gals Solids
-------
Ibs VOC gal coating/hour
gal coating X 1000 sq ft/hour
5.2 ADD-ON CONTROL EQUIPMENT
If a source uses an add-on control device to comply with the regu-
lations, additional information on the device and the associated VOC
capture system must be used in making the compliance determination. The
overall control efficiency which is the product of the capture effi-
ciency and the destruction or removal efficiency of the control device
must be determined. The overall control efficiency must then be applied
to the uncontrolled emissions estimate. The uncontrolled emissions
estimate is based upon the VOC content of the coatings as applied. The
controlled emission rate must then be compared with the applicable emis-
sion limit which as discussed earlier is generally in terms of pounds of
VOC per gallon of coating less water. For surface coating operations,
this comparison must be made on the basis of the equivalent amount of
solids applied. In some cases, such as the CTG for printing operations,
the emission limit may specify a specific control efficiency that must
be achieved if compliant coatings are not used. For such a regulation,
it is necessary only to calculate the overall control efficiency in
order to determine compliance.
To illustrate calculation of VOC emission rates for lines using
add-on control devices, the previous Example 5-2 can be used. In that
example, the line was out of compliance because the emission rate of
5.22 Ib/gal of coating exceeded the standard. Assuming that the facil-
ity installed an incinerator with a destruction efficiency of 95 percent
and that the capture efficiency were 70 percent, the overall control
efficiency would be 66.5 percent (95% X 75%). To determine whether or
not this source is in compliance, it is necessary to calculate the over-
all control efficiency which would provide the same emission rate as a
compliant coating. The required emission reduction would be equal to
Uncontrolled Emission Rate Emission Limitation Rate
(Ibs VOC/gal solids) " (Ibs VOC/gal solids)
Uncontrolled Emission Rate (Ibs VOC/gal solids)
5-9
-------
The uncontrolled emission rate (expressed as Ibs VOC/gal solids) is
5.22 IDS VOC
gal coating _ 24.86 Ibs VOC
0.42 gal solids ~ gal solids
gal coating
2 gal coating
The solids content of the "as supplied coating", i.e., 0.42 gal
solids/gal coating (from Figure 5-1), must be divided by 2 gals in the
equation above because the as supplied coating is diluted with one gal-
lon of diluent per gallon of coating. The CTG assumes an average sol-
vent density of 7.36 Ibs VOC per gal VOC. Thus, the volume percent of
solids in the compliant coating is
2.9 Ibs VOC
gal coating 0.61 gal solids
" 7.36 Ibs VOC " gal coating
gal VOC
The emission limitation in terms of Ib VOC/gal solids is
2.9 Ibs VOC
gal coating _ 4.75 Ib VOC
0.61 gal solids ~ gal solids
gal coating
The required overall control efficiency will then be
24.86 Ibs VOC/gal solids - 4.75 Ibs VOC/gal solids nn n
'. n. ..—T^T,—: — ' = 80.9 percent
24.86 Ibs VOC/gal solids
Since the overall control efficiency of the system installed is only
66.5 percent, the line does not comply with the regulation.
5-10
-------
5.3 TRANSFER EFFICIENCY ENHANCEMENT
Spray booths in the automotive, large appliance, and metal furni-
ture coating industries may be brought into compliance with the regula-
tions by increasing their transfer efficiency (TE). For spray booth
operations in those industries, the equivalent emission limit must be
determined based upon the TE used as a baseline for the emission limita-
tion and the TE achieved by the plant. These equivalency calculations
are based upon the fact that a higher TE results in less coating having
to be applied in order to coat the substrate with the same amount of
solids. In order for enhanced TE to be used as a compliance method, two
conditions must be met. First, the SIP must include TE in the emission
limit. Second, the baseline TE must be defined. If a lower quantity of
coatings is used, the emissions will be lower.
The following example illustrates the calculations necessary to
determine the compliance status of surface coating operations that
entail equivalence calculations. A large appliance manufacturer has a
coating operation using electrostratic spray coating equipment. The
applicable emission standard is 2.8 pounds of VOC per gallon coating
less water and a baseline transfer efficiency of 60 percent. The
electrostatic spray equipment achieves a transfer efficiency of 70 per-
cent, based on on-site testing, using a coating with the formulation
data shown previously in Figure 5-2. The following calculations can be
used to determine the compliance status of this operation:
1. Calculations to determine if a compliant coating is being used:
9.1 1b coating 0.23 1b VOC 2.1 Ib VOC
gal coating Ib coating ~ gal coating
9.1 Ib coating 0.30 Ib water 2.7 Ib water
gal coating Ib coating ~ gal coating
2.7 Ib water 1 0.33 gal water
gal coating 8.33 Ib water " gal coating
gal water
5-11
-------
2.1 Ib VOC
gal coating 3.1 1b VOC
0.33 gal water gal coating less water
1 gal coating - ,——
gal coating
Based upon these calculations, the coating does not comply with the reg-
ulations. As a result, it is necessary to determine whether the source
will be in compliance if TE is considered.
2. Calculations based on coatings in use:
2.1 1b VOC gal coating 5.4 Ib VOC
gal coating supplied 0.39 gal solids supplied ~ gal solids supplied
3. Calculations based on the compliant coating:
2.8 Ibs VOC gal solvent _ 0.38 gal solvent
gal coating 7.36 Ib VOC " gal coating
0.38 gal solvent 0.62 gal solids
gal coating " gal coating
2.8 Ibs VOC gal coating _ 4.5 Ib VOC
gal coating 0.62 gal solids ~ gal solids supplied
4.5 Ib VOC gal solids supplied _ 7.5 Ib VOC
gal solids supplied 0.6 gal solids applied ~ gal solids applied
4. Calculation of the transfer efficiency required to comply with the
regulation:
5.4 Ib VOC
gal solids supplied 0.72 gal solids supplied
7.5 Ib VOC ~ gal solids applied
gal solids applied
Based upon these calculations, this particular source would not be in
compliance with the emission regulation. In order to comply by using
5-12
-------
the indicated coating, the operation's transfer efficiency would have to
be at least 72 percent.
5.4 BUBBLES
A bubble supplants the emission limits for individual coating lines
by allowing trade-offs of emissions for various coating lines. Bubbles
sometimes take the form of facility-wide emission limits. However, in
some cases a bubble may apply to only some of the lines at a facility.
In such cases, the compliance of the lines not included in the bubble
must be determined separately on a line-by-line basis. A facility may
use a combination of compliant coatings, noncompliant coatings, and add-
on control devices. To determine compliance with the bubble, the emis-
sions from each line must be calculated. The emissions for each line in
the facility subject to the bubble are then added together and compared
with the bubble emission limit or compared to the revised emission limi-
tations for each line. To be approved, a bubble must include a method-
ology for determining compliance. Since each bubble is a source-spe-
cific SIP revision or issued pursuant to a SIP approval generic rule,
the provisions of the bubbles must be reviewed carefully prior to
attempting to determine compliance.
An example of the type of calculations necessary to determine a
facility's compliance with a particular bubble is as follows. Overall
emission reductions must be 65 percent. The plant complies by using a
catalytic incinerator on two of the presses, i.e., Presses 13 and 14.
The incinerator's efficiency is 97 percent. The efficiency of the VOC
capture system is 100 percent because all of the air in the pressroom
where the controlled presses are located is exhausted through the incin-
erator (total enclosure). Table 5-2 summarizes the data for three days
of operation. Coating usage data and emissions estimates are in terms
of pounds per day. Coating formulation data have been averaged to sim-
plify the illustration. Because the total overall control is greater
than 65 percent, the facility is in compliance for this time period.
5-13
-------
TABLE 5-2. DAILY VOC EMISSIONS FROM A PLANT WITH A BUBBLE
(Pounds per Day)
Press
Press
Press
Press
Ink/
ID Coating
Type
#1 Ink
Solvent
Extender
Lacquer
and
Primer
Waterbased
#2 Ink
Solvent
Extender
Lacquer
and
Primer
Waterbased
#3 Ink
Solvent
Extender
Lacquer
and
Primer
Waterbased
VOC
Content %
67.5
100.0
67.5
67.5
10.0
67.5
100.0
67.5
67.5
10.0
67.5
100.0
67.5
67.5
10.0
Coating Usage
Day 1
15
8
3
0
0
542
552
96
0
648
1,073
42
203
19
Day 2
168
128
6
0
207
355
364
44
13
779
1,088
80
71
0
Day 3
23
12
1
0
12
250
363
84
18
755
1,170
97
76
0
VOC
Day 1
10
8
2
0
0
366
552
65
0
438
1,073
29
137
2
Emissions
Day 2
113
128
4
0
21
240
364
30
9
526
1,088
54
48
0
Day 3
15
12
1
0
1
169
363
56
12
509
1,170
65
51
0
5-14
-------
TABLE 5-2. DAILY VOC EMISSIONS FROM A PLANT WITH A BUBBLE
(Concluded)
(Pounds per Day)
Press ID
Press #4
Lamina-
Ink/
Coating
Type
Ink
Solvent
Extender
Lacquer
and
Primer
Waterbased
Solvent
VOC
Content %
67.5
100.0
67.5
67.5
10.0
100.0
Coating Usage
Day 1
875
1,973
98
196
0
468
Day 2
600
1,588
61
304
130
441
Day 3
673
1,867
102
230
0
575
VOC Emissions
Day 1
591
1,973
66
133
0
468
Day 2
405
1,588
41
205
13
441
Day 3
454
1,867
69
155
0
575
tor
Wash-up Solvent
25.0
200 179 176
50 45
44
Uncontrolled Emissions from Presses #1
and #2, the Laminator, and Wash-up
Uncontrolled Emissions from Presses #3
and 14
Total Uncontrolled Emissions
Percent Control for Presses #3 and #4
Total Controlled Emissions3
Percent Total Control
1,531 1,412 1,259
4,441 3,969 4,341
5,972 5,381 5,600
97
97 97
1,664 1,531 1,389
72 72
75
NOTE: This facility is in compliance because overall control efficiency
is better than 65 percent.
a) Uncontrolled emissions from Presses #1 and #2 and actual
emissions after control from Presses #3 and #4, i.e., for Day 1,
1,531 + (1 - 0.97) X 4,441 = 1,664 Ibs/day
5-15
-------
5.5 REFERENCES FOR CHAPTER 5
1. A Guideline for Surface Coating Calculations. EPA-340/1-86-016,
U.S. Environmental Protection Agency, Washington,DC, July 1986.
2. Memorandum from Darryl D. Tyler, Director, Control Programs
Development Division, "VOC Equivalency Calculations -
Clarification of Requirements", March 9, 1984.
3. Federal Register. December 1980.
5-16
-------
6. RECORDKEEPING PROCEDURES FOR
THE GRAPHIC ARTS INDUSTRY
As discussed previously in Chapter 1, the recordkeeping procedures
outlined in this document for surface coating operations apply as well
to the graphic arts industry. There are certain differences in regula-
tions between the graphic arts industry and surface coating operations
which may affect recordkeeping procedures for the two types of sources.
The purpose of this Chapter is to provide an overview of processes in
the graphic arts industry, the applicable regulations, and recordkeeping
and data verification procedures.
6.1 GRAPHIC ARTS PROCESSES
There are five basic processes of the printing industry included in
the term "graphic arts": offset lithography, letterpress, rotogravure,
flexography, and screen printing. Screen printing is usually reserved
for small applications such as posters. The substrate may be fed to the
printing presses in the form of a web or as sheets.
The substrate printed may be coated or uncoated paper, plastics
such as vinyl, or other surfaces. Printing and paper coating, which is
regulated as a surface coating operation, both involve the application
of a relatively high solvent content material to the surface of a moving
web or film, solvent evaporation by movement of heated air across the
wet surface, and exhaust of solvent laden air from the system. They
differ in that printing always involves the application of ink by a
printing press.
Inks used in the graphic arts industry consist of pigments, binders
which are solid components that lock the pigments to the substrate, and
solvents which disperse the pigments and binders. The binders usually
are composed of organic resins and polymers or oils and rosins.
Solvents are usually organic compounds.
Of the various types of processes, rotogravure and flexography as
applied to publication and packaging printing are the only two for which
a Control Technique Guideline1 (CTG) has been issued. State and local
6-1
-------
air pollution control agencies, however, may regulate other printing
processes. Such regulations may be included in the State Implementation
Plan (SIP). In addition, there is a New Source Performance Standard
(NSPS) for publication rotogravure. Rotogravure and flexography are
described in more detail below. AP-422 contains a description of
printing processes.
The image in rotogravure printing is engraved or "intaglio" rela-
tive to the surface of the image carrier. The image carrier is a copper
plated steel cylinder that may also be chrome plated to resist wear.
This cylinder rotates in an ink trough or fountain. The engraved area
picks up the ink. A steel "doctor blade" scrapes off the ink from the
nonimage area. The image is then transferred directly to the web when
it is pressed against the cylinder by a rubber covered impression roll.
The web must be dried after application of each color
Illustrations with excellent color control can be produced with
rotogravure. The two major uses of rotogravure are in publication
printing such as newspaper supplements, magazines, and mail-order
magazines and printing of flexible packaging materials. It is also used
in the printing of specialty products such as wall and floor coverings,
decorated household paper products, and vinyl upholstery.
Inks used in rotogravure printing contain from 55 to 95 volume per-
cent low boiling solvent. They must have low viscosities. Typical sol-
vents include alcohols, aliphatic naphthas, aromatic hydrocarbons,
esters, glycol ethers, ketones, and nitroparaffins. Waterbased inks
containing small amounts of alcohol are being developed.
In flexography, the image area is raised, and the ink is trans-
ferred directly to the substrate from the image surface. The distin-
guishing feature of flexography from other types of printing, especially
letterpress, is that the image carrier is made of rubber or other elas-
tomeric materials. A feed cylinder rotates in a trough of ink (called
an ink fountain), and delivers ink to the plate (image) cylinder through
a distribution roll. Flexographic presses are usually web fed.
Flexography can be used to print medium or long multicolor runs on
a variety of substrates, including heavy paper, fiberboard, and metal
and plastic foil. The major categories of the flexographic market are
flexible packaging and laminates, multiwall bags, milk cartons, gift
6-2
-------
wrap, folding cartons, corrugated paperboard (which is sheet fed), paper
cups and plates, labels, tapes, and envelopes. Almost all milk cartons
and half of all flexible packaging are printed by flexography.
Very fluid inks of about 75 volume percent organic solvent are used
in flexography. The solvents must be compatible with rubber. Usually,
the solvents are alcohol or an alcohol mixed with an aliphatic hydrocar-
bon or ester. Typical solvents also include glycols, ketones, and
ethers. The inks dry by solvent absorption into the web and by evapora-
tion in high velocity steam drum or hot air dryers at temperatures below
250°F. Waterbased inks are also used.
6.2 VOC EMISSION LIMITATIONS
As mentioned previously, a CTG has been promulgated for rotogravure
and flexography. The emission limitations for the graphic arts industry
differ in kind from those for the surface coating operations. There are
four types of emission limitations for the graphic arts industry recom-
mended by the CTG as follows:
• Compliant inks are defined as those whose volatile portion con-
sists of 75 volume percent or more water and 25 volume percent or
less organic solvent.
• If a source chooses to comply by using add-on control devices, an
overall control efficiency, i.e., capture efficiency and control
device destruction or removal efficiency, must be achieved.
These efficiency requirements differ depending upon the type of
process as follows:
•• 75 percent for publication rotogravure presses
•• 65 percent for packaging rotogravure presses
•• 60 percent for flexographic presses
• The CTG recommended that inks which contain 60 percent or more
non-volatile material be exempt in order to encourage the devel-
opment of high solids inks.
• Another method of compliance suggested in the CTG is to replace
high-coverage solvent-borne inks with water-borne ones such that
a 70 volume percent overall reduction in solvent usage is
achieved as compared to all solvent-borne ink usage. This con-
trol option relies upon the fact that many printing jobs consist
6-3
-------
of printing a heavy coverage color or one in which large areas
are of the same color and several light coverage colors. An
example of a light coverage is a thin strip of a given color.
In addition, EPA has defined an alternative emission limit of 0.5 Ibs of
VOC per Ib of solids in ink as the equivalent to reasonably available
control technology (RACT) for flexographic and packaging rotogravure
presses^.
There is a NSPS for publication rotogravure. This NSPS limits the
VOC emissions to no more than 16 percent of the total mass of VOC sol-
vents and water used at the facility during any one performance averag-
ing period. Only the water contained in the waterborne raw inks and
related coatings and the water added for dilution with waterborne ink
systems are included in the determination of the water used.
6.3 ADD-ON CONTROL SYSTEMS
Add-on controls for printing presses are similar to those for sur-
face coating operations, i.e., carbon adsorption and thermal and cat-
alytic incineration. Carbon adsorption is the predominant control sys-
tem used in the publication rotogravure industry. Packaging rotogravure
and flexographic presses are usually controlled by thermal or catalytic
incinerators if add-on controls are used to comply with the regulations.
VOC capture systems for the graphic arts industry are similar to those
used for surface coating operations. Because the emission limits for
the graphic arts industry are in terms of an overall control efficiency
when using add-on control systems, the capture efficiency is a very
important consideration.
6.4 RECORDKEEPING AND DATA VERIFICATION PROCEDURES
The recordkeeping procedures outlined in Chapter 3 are applicable
to the graphic arts industry. In particular, graphic arts facilities
should maintain the data indicated for coating formulation, coating con-
sumption, and add-on control devices. In addition, graphics arts
sources should maintain data on the density of solvents in the inks if
compliant coatings are used. Because transfer efficiency is not an
issue in the graphic arts industry, the data requirements for transfer
6-4
-------
efficiency are not applicable. In using the forms provided in Chapter
3, the graphic arts facility should interpret the term "coating" to
include inks and the term "coating line" co include printing presses.
In spite the previous discussion in this Chapter on only rotogravure and
flexography, the recordkeeping procedures in Chapter 3 would apply to
any graphic arts source regulated by the applicable SIP.
The data verification procedures described in Chapter 4 are also
applicable to the graphic arts industry.
6.5 COMPLIANCE DETERMINATIONS
Because of the differences in the regulations for surface coating
operations and the graphic arts industry, there are differences in the
calculations needed to determine compliance. For example, the CTG for
graphic arts specifies an overall control efficiency when add-on con-
trols are used. There is no need to calculate an efficiency requirement
based upon the solids content of the compliant coating. The possibility
of substituting low-solvent inks for high-solvent ones in the high cov-
erage jobs requires that the actual emissions prior to substitution of
low-solvent inks be established. An EPA Guideline^ for calculating
compliance for the graphic arts industry is being developed.
6.6 REFERENCES FOR CHAPTER 6
1. Control of Volatile Organic Emissions from Existing Stationary
Sources - Volume VIII; Graphic Arts - Rotogravure and
Flexoaraphv (EPA-450/2-78-033), U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711, December
1978.
2. Compilation of Air Pollutant Emission Factors (EPA Publication
AP-42), U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina 27711, October 1986.
3. September 9, 1987 Memorandum from D. Tyler, Director, Control
Programs Development Division, Office of Air Quality Planning
and Standards, OAQPS to Air Divisions, Regions I-IX, "An
Alternative Emission Limit for Flexographic and Packaging
Rotogravure Printing Facilities".
6-5
-------
4. PEI Associates, Inc. "A Guideline for Graphic Arts Cal-
culations" (Draft). U.S. Environmental Protection Agency.
Contract Number 68-02-3963, 1988.
6-6
-------
APPENDIX A. ALLOWABLE VOC LIMITS FOR SURFACE
COATING OPERATIONS
(The State and local air pollution control agency limits shown in this
Appendix may not reflect recent changes that have been made to surface
coating regulations.)
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
Operation
Pounds VOC per gal coating
minus water3
1. CAN COATING
CTG Limits
a) Sheet basecoat (exterior and
interior) and over varnish;
two piece can exterior base
coat and over varnish
b) Two and three piece can
interior body spray, two
piece can exterior end
(spray and roll coat)
c) Three piece can side-seam
spray
d) End sealing compound
CTG Reference:
EPA 450/2-77-008, Vol. II,
May 1977
NSPS Limits
From two piece beverage can
surface coating operations:
Each exterior base coating
except clear base coating
operation
Each over varnish coating
andeach clear base coating
operation
2.8
Established based on 25 volume
percent solids and 80:20 volume mix
of water and VOC
4.2
Establish based on 18 volume percent
solids and 70:30 mix of water and
VOC
5.5
3.7
2.4 Ib/gal of coating solids
3.8 Ib/gal of coating solids
A-l
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water9
Each inside spray coating
operation
NSPS Reference:
40 CFR 60 WW; 1983
NSPS BID:
EPA 450/3-80-036a & b
California Limits
Sheet base coat (exterior and
interior) and over varnish
Two piece can exterior base
coat and over varnish
2. PAPER COATING
CTG Limits
Coating line (consists of the
coatings put on paper, pressure
sensitive tapes regardless of
substrate (including paper,
fabric, or plastic film) and
related web coating processes
on plastic film such as type-
writer ribbons, photographic
film and magnetic tape.
Also included in paper coating
category are decorative
coatings on metal foil such as
gift wrap and packaging.
CTG Reference:
Item 1
The same as for
7.4 Ib/gal of coating solids
(1.9)
(2.1)
2.9 (1.0 California)
A-2
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus watera
NSPS Limits
NSPS only applicable to the
coating of Pressure sensitive
tapes and labels (PSTL)
NSPS Reference:
40 CFR 60 RR; 1983
NSPS BID: 450/3-80-003a&b
3. FABRIC COATING
CTG Limits
a) Fabric Coating Line
"Fabric Coating" includes
all types of coatings
appliedto fabric, a large
portion of which is rubber
used for rainwear, tents,
industrial purposes such as
gaskets and diaphragms.
b) Vinyl Coating Line
"Vinyl Coating" refers to
any printing,decorating or
protective topcoat applied
over vinyl coated fabric or
vinyl sheets. It does not
include the application of
vinyl plastisol to the
fabric (emission from the
application of plastisol are
near zero.)
0.20 Ib/lb of coating solids
applied
2.9 (1.0 California limit)
Established based on the use of a
control device resulting in 81
percent overall emissions
reduction or the use of organic-and
borne coatings of 60 volume
percent solids
3.8; Established based on an 81
percent overall reduction
CTG Reference:
Item 1.
The same as for
A-3
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
NSPS Limits
A NSPS is being developed
for polymeric coatings of sup-
porting webs. It will restrict
emissions from new fabric coat-
ing but not fabric printing
operations.
NSPS BID: 450/3-81-016a&b
4. COIL COATING INDUSTRY
Prime and top coat or single
coat operation
CTG Reference: The same as for
Item 1.
NSPS Limits
a) For a facility with no
emission control device
b) For a facility with emission
control device
c) For a facility with an in-
termittently used emission
control device
NSPS Reference:
40 CFR 50 TT; 1982
NSPS BID: 450/3-80-035a&b
2.6 (1.7 California limit)
Established based on incineration at
90 percent capture and 90 percent
destruction of emissions from an
organic-borne coating which contains
25 volume percent solids.
2.3 Ib/gal of coating solids
1.2 Ib/gal of coating solids or
90 percent emission reduction
A value between 1.2 and 2.3 Ib/gal
of coating solids applied
A-4
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus watera
5. SURFACE COATING OF
FLATWOOD PANELING
CTG Limits
a) Printed hardwood plywood and
particle board
b) Natural finish plywood
c) Class II finishes for hard-
wood paneling
Exemptions: Exterior siding,
tile board or particle board
used in furniture component
CTG Reference: 450/2-78-032
NSPS Limits
California Limits
Coatings and adhesives
Inks
6. AUTOMOTIVE AND LIGHT DUTY
TRUCK ASSEMBLY PLANTS
CTG Limits
6.0 lb/1,000 ft2 of surface
covered (2.7 Ib VOC/gal coating
minus water, NJ limit)
12.0 lb/1,000 ft2 of surface
covered (3.3 Ib VOC/gal coating
minus water, NJ limit)
10.0 lb/1,000 ft2 of surface
covered (3.6 Ib VOC/gal coating
minus water, NJ limit)
None
(2.1)
(4.2)
A-5
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
a) Prime application, flashoff
area, and oven
Prime coat (15.1 Ib/gal
solids applied—later
guidance)
Guide coat (15.1 Ib/gal
solids applied—later
guidance)
b) Topcoat application,
flashoff area, and oven
c) Final repair application,
flashoff area, and oven
CT6 Reference: The same as for
Item 1
NSPS Limits
Prime coat
Guide coat
Top coat
A requirement of the NSPS is
that the operator must conduct
a performance test each calen-
dar month and report the
results to EPA within 10 days.
The calculation of the volume
weighted average mass of VOC
per volume of applied coating
1.9 (1.2 Delaware limit)
1.2
2.8 at baseline TE = 30 percent,
Established based on the use of
water-borne coatings
2.8 At baseline TE = 30 percent,
Established based on the use of
water-borne coatings
4.8
1.3 Ib/gal solids applied
11.7 Ib/gal solids applied at
baseline TE = 39 percent
12.2 Ib/gal solids applied at
baseline TE = 37 percent
A-6
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
solids during each month con-
stitutes a performance test.
While RM 24 is the reference
method for use in this perfor-
mance test to determine data
used in the calculation of the
volatile content of coatings,
provisions have been made to
allow the use of coatings manu-
facturers' formulation data to
determine the volume fraction
of solids. If an incinerator
is used, owner must submit a
quarterly report on incinerator
performance.
NSPS Reference:
40 CFR 60 MM; 1980
NSPS BID: 450/3-79-030a&b
California Limits
SCAQMD Rule 1115
a) Prime application, flashoff
area and oven:
for electrophoretic primer
for primer surfacer
for spray primer
b) Topcoat application, flash-
off area, and oven
Massachusetts has separate
limits for primer application
(1.2 at baseline TE
(2.8 at baseline TE
(2.3 at baseline TE
(2.3)
95 percent)
95 percent)
95 percent)
A-7
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus watera
and primer surfacer application
It also has a requirement to
base emission limits on daily
arithmetic average
Exemptions in Kentucky:
a) If prime coating line uses
electrophoretic deposition
and coating 1.2 Ib/gal of
coating excluding water or
50 percent TE and 55 percent
solids coating on first
applicators; and uses <2.8
Ib/gal of coating excluding
water or 65 percent TE and
55 percent solids coating on
surfacer;
b) If top coating line uses
<2.8 Ib gal of coating
excluding water or 55 per-
cent solids coating and
65 percent TE;
c) If repair coating line uses
4.8 Ib/gal of coating
excluding water and 65 per-
cent TE;
d) If arithmetic average of all
coatings on a coating line
meets the exemption then all
coatings are considered to
meet the exemption.
A-8
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus watera
Exemptions in Virginia: Wheel
enamels, anti-rust coatings and
sealers not associated with
prime or top coat application
to the vehicle body.
Exemption in Delaware: Coating
lines emitting less than 40
IDS/ day per facility
7. SURFACE COATING OF URGE
APPLIANCES
CTG Limits
CTG Reference: Vol V
NSPS Limits
NSPS Reference:
40 CFR SS, 1982
NSPS BID: 450/3-80-007a&b
California Limits
Air dried or forced air dried
coatings
Baked coatings
Industrial machinery:
Extreme performance coatings
If dried at >90°C
2.8 at baseline TE = 60 percent
7.5 Ibs/gal of applied coating
solids
Established based on 62 volume
percent solids applied at a TE
of 60 percent
(2.8)
(2.3)
(2.8)
(2.3)
A-9
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
Extreme high-gloss
Metallic
Baked
Air-dried
Exemptions: Quick drying lac-
quers for repairs of scratches
and nicks, provided that the
volume not exceed 1 qt per 8
hour period.
8. SURFACE COATING OF METAL
FURNITURE
CTG Limits
Metal furniture coating line
CTG Reference:
EPA-450/2-77-02 Vol III
NSPS Limits
NSPS Reference: EE 1982
Revision 4/30/85 50 FR 18247
9. MAGNETIC TAPE COATING
CTG Limits
The CTG for paper coating cover
magnetic tape and other plastic
film coating
NSPS Limits
(3.5)
(2.3)
(2.8)
3.0 at baseline TE = 60 percent.
Established based on converting
to low solvent coatings
7.5 Ib/gal of coating solids
the use of a coating with 62
volume percent solids and a 60
percent TE
A-10
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
An NSPS currently being written
was proposed on 1-22-86.
NSPS Reference: FR 2996
10. MAGNET WIRE COATING
CTG Limits
Wire coating oven
CTG Reference:
450/2-77-033 Vol IV
NSPS Limits
None
11. MISCELLANEOUS METAL
PARTS AND PRODUCTS
CTG Limits
a) Air or forced air dried
itemb
b) Clear coat
c) No or infrequent color
change or small number of
colors applied
1. Powder coatings
2. Other
1.7 Established based on use of an
incinerator
3.5
4.3
0.4
3.0
A-ll
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
d) Outdoor harsh exposure or
extreme performance charac-
teristics
e) Frequent color change, large
number of colors applied or
first coat on untreated
ferrous substrate
Air or forced air dried items:
Coatings dried at or
below 194° F
Coatings dried above 194°F
CTG Reference:
450/2-78-015 Vol VI
NSPS Limits
Delaware exemption: refin-
ishing transportation equip-
ment, low volume specialty
coatings (5 percent of total
annual coating line, <20 Ib/day
operations, and customized
coatings of <20 vehicles per
day)
12. ARCHITECTURAL COATINQC
CTG Limits
NSPS Limits
3.5
3.0
3.5 (2.8 California limit)
4.3 (2.3 California limit)
None
Overall VOC reduction
efficiency >=80 percent
None
None
A-12
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
California Limits
Flat coatings
Non-flat coatings
Coating Category
Varnish
Lacquer
Semi-Transparent
Opaque Stains
Semi-Transparent and clear
wood preservatives
General primers, sealers
and undercoaters
Industrial maintenance
primers and topcoats
Dry fog coatings:
Flat
Non-flats
Quick dry enamels
Specialty flats
Waterproof sealers
Concrete curing compounds
Roof coatings
Water proofing mastic
coatings
Enamel undercoaters
Traffic paints for public
streets and highways for
other surfaces
Black traffic coatings
13. COATING OF AIRCRAFT INDUSTRY
(2.1)
(2.1)
(2.9)
(5.7)
(2.9)
(2.9)
(2.9)
(2.9)
(3.5)
(3.5)
(3.3)
(3.3)
(3.3)
(3.3)
(2.9)
(2.5)
(2.5)
(2.9)
(2.1)
(2.1)
A-13
-------
TABLE A-l. ALLOWABLE YOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
CTG Limits
NSPS Limits
California Limits
The most stringent of rules of
South Coast, San Diego, and Bay
Area
a) Primer
b) Top coat
c) Pretreatment
d) Adhesive bonding primer
e) Flight test
f) Fuel tank
g) Maskant
h) Electromagnetic
i) Temporary protective
Tennessee Limit
Stripper operation
Ok!ahoma Limits
a) Alkyl primer
b) Vinyls
c) NC Lacquers
d) Acrylics
e) Epoxies
f) Maintenance finishes
g) Custom product finishes
(The CTG for miscellaneous metal
parts covers coating of aircraft
parts and components with the
exclusion of fully assembled
aircraft.)
None
(2.9)
(2.9)
(6.5)
(5.1)
(7.0)
(5.4)
(5.0)
(6.7)
(2.1)
(3.3)
(4.8)
(6.0)
(6.4)
(6.0)
(4.8)
(4.8)
(6.5)
A-14
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
Exemption = 90 percent inci-
neration or 85 percent
absorption
14. SURFACE COATING OF WOOD
FURNITURE
CTG Limits
NSPS Limits
Emissions are currently limited
by a few State regulations.
California's model rule focuses
on improved TE of the spray
operation.
California Limits
The following are baseline VOC
contents - not VOC standards -
established in California for
use in calculating an equiva-
lent emission reduction plan:
a) Clear topcoats
b) Sealer
c) Washcoat
d) Pigmented coating
e) Semi-transparent stain
f) Opaque stain
15. SURFACE COATINGS IN THE
SHIP AND BOAT INDUSTRY
CTG Limits
None
None
(5.8)
(5.7)
(6.2)
(5.0)
(6.7)
(4.8)
None
A-15
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
NSPS Limits
16. COATINGS OF PLASTIC PARTS
FOR BUSINESS MACHINES
CTG Limits
NSPS Limits
For exterior coatings prime
coat, color coat and fog coat
Texture coat and touch-up
NSPS Reference: January 86;TTT
NSPS BID: 450/3-85-0192
California Limits
BAAQMD regulation for exterior
coating
17. ADHESIVE
The CTG and NSPS have been set
for pressure sensitive tape and
label surface coating opera-
tions. The CTG is also appli-
cable to adhesive coatings
applied to all webfed
substrates.
CTG Limit
CTG Reference:
EPA 450/2-77-008, Vol II,
May 1977
None
None
12.52 Ib/gal solids applied
19.2 Ib/gal solids applied
(2.8)
2.9
A-16
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
NSPS Limits
Affected facility
NSPS Reference:
40 CFR 60 RR, 1983
California Limits
California emission limits for
Plastic Parts, Rubber, Glass,
and Adhesive - the most strin-
gent of the South Coast and Bay
Area limits
General Coatings:
One component
Two component
Flexible Parts:
Primer
Color topcoat
Basecoat or clear coat
Rubber coating
Glass coating
Metallic Coatings
Camouf1 age
Conductive
Touch-up
Extreme performance
Military Specifications:
One component
Two component
Multi-colored
0.20 Ib VOC/lb of coating solids
applied as calculated on a weighted
average basis for one calendar month
or a 90 percent overall VOC emission
reduction.
(2.3)
(2.8)
(4.1)
(3.8)
(4.5)
(2.3)
(2.3)
(Exempt)
(3.5)
(Exempt)
(Exempt)
(Exempt)
(2.8)
(3.5)
(4.0)
A-17
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
Mold Seal
Vacuum Metalizing
Mirror Backing:
Curtain coated
Roll coated
Elastomeric Adhesives
Plastic cements
Adhesive
Adhesives applied to rubber
EMI/RFI
Optical
Electric dissipating and
shock-free
Materials for surface
preparation:
Clean-up and Stripping
Disposal of cloth and
paper
Clear (transparent)
Automotive:
General
Metallic
Stencil
Reflective on highway cones
Mask Coatings
18. FLEXIBLE AND RIGID DISC MFG.
CTG Limits
NSPS Limits
California Limits
(6.3)
(6.7)
(4.2)
(3.6)
(Exempt)
(Exempt)
(2.1)
(3.5)
(Exempt)
(6.7)
(6.7)
(1.67)
(Closed containers)
(Exempt)
(4.3)
(5.0)
(Exempt)
(Exempt)
(Exempt)
None
None
Emission control systems which
demonstrate overall collecction
and control of at least 85 percent
A-18
-------
TABLE A-l. ALLOWABLE VOC LIMITS FOR SURFACE COATING OPERATIONS
(Continued)
Operation
Pounds VOC per gal coating
minus water3
19. TRAFFIC PAINTS
Waterborne traffic paints,
whichcan reduce VOC emissions
by 80 percent, have been
developed and used in a number
of states.
Traffic paint is included as a
category in the architectural
coating rule adopted in several
districts in California
a CTG and NSPS regulated limits are listed as applicable. More stringent State
regulated limits are listed in parentheses. All limits are given in Ib VOC/gal of
coating minus water and exempt solvents except where noted.
0 Parts too large or too heavy for practical size ovens and/or sensitive heat
requirements. Parts to which heat sensitive materials are attached. Equipment
assembled prior to top coating for specific performance or quality standards
c Several State regulations, including California's, have a separate limit of 6.25
Ib VOC/gal of coating minus water for high performance coatings.
A-19
-------
APPENDIX B. SUGGESTED SURFACE COATING TERMS
-------
DEFINITIONS
Aerospace Component - The fabricated part, assembly of parts, or com-
pleted unit of any aircraft, helicopter, missile or space vehicle.
Air Sorav Coating - A type of application method where the coating is
atomized by mixing it with compressed air.
Airless Sprav Coating - A type of application method where the coating
is atomized by forcing it through a small opening at high pressure. The
liquid coating is not mixed with air before exiting the nozzle.
As Applied - The condition of a coating after dilution by the user just
prior to application to the substrate.
As Supplied - The condition of a coating before dilution, as sold and
delivered by the coating manufacturer to the user.
Alternative Method - Any method of sampling and analyzing for an air
pollutant which is not a reference or equivalent method but which has
been demonstrated to the Administrator's satisfaction to, in specific
cases, produce results adequate for compliance determination.
Applied Solids - Solids which remain on the substrate being coated or
painted.
Architectural Coating - Stock type or shelf coatings which are formu-
lated for service under environmental conditions, and for general appli-
cation on new and existing residential, commercial, institutional, and
industrial structures. These are distributed through wholesale/retail
channels and purchased by the general public, painters, building con-
tractors and others.
Attainment Area - An area which is considered to have air quality as
good as or better than the national ambient air quality standards, as
defined by Section 107 of the Clean Air Act. An area may be an attain-
ment area for one pollutant and a nonattainment area for others.
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Automobile or Light-Duty Truck Manufacturing Plant - A facility where
parts are manufactured or finished for eventual inclusion into a fin-
ished automobile or light-duty truck ready for sale to vehicle dealers,
but not including customizers, body shops, and other repainters.
Bubble Concept - An alternative emission plan whereby a facility with
multiple sources of a given pollutant may achieve a required total emis-
sion by a different mix of controls from that mandated by regulation.
Some sources may be assigned more restrictive limits, while others would
meet less restrictive one^s, provided the resulting total emissions are
equivalent. Such a concept may permit a more expeditious cost effective
compliance plan.
Can Coating - The application of a coating material to a single walled
container that is manufactured from metal sheets thinner than 29 gauge
(0.0141 in.).
Capture Device - A hood, enclosed room, floor sweep or other means of
collecting solvent or other pollutants into a duct. The pollutant can
then be directed to a pollution control device such as an incinerator or
carbon adsorber.
Carbon Adsorber - An add-on control device which uses activated carbon
to absorb volatile organic compounds from a gas stream. The VOC's are
later recovered from the carbon, usually by steam stripping.
Catalytic Incinerator - A control device which oxidizes VOC by using a
catalyst to promote the combustion process. The catalyst allows the
combustion process to proceed at a lower temperature (usually around
600°F to SOOT) than a conventional thermal incinerator would require
(1,100 to 1,400°F), resulting in fuel savings and lower cost incinera-
tion.
Clean Air Act - The Clean Air Act, as amended, provides the foundation
for EPA's efforts to improve air quality. The Clean Air Act, building
on earlier legislation, was passed in 1970, and was amended in 1977.
Clear Coat - A transparent coating usually applied over a colored opaque
coating to give improved gloss and protection to the color coat below.
In some cases, a clear coat simply refers to any transparent coating
without regard to substrate.
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Coating - A protective or decorative film applied in a thin layer to a
surface. This term often applies to paints such as lacquers or enamels,
but also is used to refer to films applied to paper, plastics, or foil.
Coatino Applicator - Equipment used to apply a surface coating.
Coating Line - An operation where a surface coating is applied to a
material and subsequently the coating is dried and/or cured.
Coil Coating - A metal coating operation in which sheet metal is unwound
from a coil, roller coated and rewound. The metal may then be formed
into products such as aluminum siding, automobile parts or a variety of
other items.
Compliant Coating - A coating whose volatile organic compound content
does not exceed that allowed by regulation. Compliance coatings may be
water borne, low solvent (high solids), or powder.
Condensation - A method of solvent recovery in which the vaporized sol-
vent is liquified generally by cooling.
Control Technique Guidelines (CTG) - A series of documents prepared by
EPA to assist States in defining reasonable available control technology
(RACT) for major sources of volatile organic compounds (VOC). The docu-
ment provide information on the economic and technological feasibility
of available techniques; and, in some cases, suggest limits on VOC emis-
sions.
Daily Weighted Average - The amount of volatile organic compounds emit-
ted on a given day, considering actual production, VOC content of coat-
ing used, and the degree of control achieved by any abatement equipment
on the coating line(s) included in the submitted plan.
Dip Coating - A method of applying a coating in which the substrate is
dipped into a tank of coating and then withdrawn.
Doctor Blade - Method of applying a coating in which a flat metal strip
or blade is mounted such that it scrapes off excess coating from a roll
or rotogravure coater before the coater contacts the paper or other sub-
strate being coated.
Electrodeposition - A dip coating method in which an electrical field is
used to promote the deposition of the coating material onto the part.
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The part being painted acts as an electrode which is oppositely charged
from the particles of paint in the dip tank.
Emission Reduction - The decrease in VOC emitted when (1) a low solvent
coating is used in place of a higher solvent coating or (2) an add-on
control device (such as carbon adsorber or incinerator) is used on a
process. Emission reduction is often expressed as a percentage.
Equivalent Method - Any method of sampling and analyzing for an air pol-
lutant which has been demonstrated to the Administrator's satisfaction
to have a consistent and quantitatively known relationship to the refer-
ence method, under specific conditions.
Exempt Solvent - Specified organic compounds that are not subject to the
requirements of a regulation. Such solvents have been deemed of negli-
gible photochemical reactivity by EPA.
Exterior Base Coat - A coating applied to the exterior of a beverage can
to provide both corrosion resistance and a background for lithography or
printing.
Exterior End Coat - A coating applied by rollers or spraying to the
exterior end of can.
Fabric Coating - A process which applies a uniform layer of polymeric
resin on a supporting fabric substrate. Typical coatings are rubbers,
urethanes, vinyls, and acrylics.
Film Coating - Any coating applied in a web coating process on any film
substrate other than paper or fabric, including, but not limited to
typewriter ribbons, photographic film, magnetic tape, metal foil, and
gift wrap.
Flashoff Zone - The area within a plant where solvents evaporate from a
coating during the interval between coats or before the painted object
enters a bake oven.
Flatwood Paneling Coating - The coating of plywood, particle board, and
hardwood.
Flow Coat - A method of applying coating to an object in which the coat-
ing is poured on the substrate.
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Fluidized Bed Coating - A type of application method where air is blown
through a powder coating and a heated object is lowered into the tank
and coated.
High Performance Architectural Coating - A coating used to protect
architectural subsections and which satisfies the requirements of the
Architectural Aluminum Manufacturers' Association's Publication No. AAMA
605.2-1985.
High Solids Coating - Paints containing considerably higher solids than
has been conventional in the past. Usually paints with greater than 60
percent solids by volume are considered high solids coatings although
the term is often applied to any coating which meets any of EPA's
Control Technique Guidelines. Formerly, under California's Rule 66, a
high solids paint was one containing not less than 80 percent solids by
volume.
Hood - A partial enclosure or canopy for capturing and exhausting, by
means by of a draft, the organic vapors or other fumes rising from a
coating process or other source.
Incinerator - An engineered apparatus capable of withstanding heat and
designed to efficiently reduce solid, semisolid, liquid, or gaseous
waste at specified rates and from which the residue contains little or
no combustible material. "Tepee" burners, "conical" burners, and "jug"
burners are not considered as incinerators.
Interior Base Coating - A coating applied to the interior of a can to
provide a protective lining between the product and the can.
Interior Body Sorav - A coating sprayed on the interior of the can body
to provide a protective film between the product and the can.
Large Appliance Coating - The application of a coating material to the
component metal parts (including but not limited to doors, cases, lids,
panels, and interior support parts) of residential and commercial
washers, dryers, ranges,refrigerators, freezers, water heaters, dish-
washers, trash compactors, air conditioners, and other similar products.
Low Solvent Coating - A coating which contains a lower amount of
volatile organic compound (VOC) than conventional organic solvent borne
coatings. Low solvent coatings usually fall into the three major groups
of high solids, waterborne, or powder coatings.
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Maonet Wire Coating - The coating of wire used in equipment such as
electrical motors, generators, and transformers. Magnet wire is coated
with an electrically insulating varnish or enamel.
Make-up Solvent - The portion of solvent required to compensate for the
amount lost, normally via evaporation, during a manufacturing process.
Manufacturer's Formulation - A list of substances or component parts of
coatings as described by the maker of the coatings. This may be used, in
many cases, to calculate the volatile organic compound content of a
coating.
Material Balance - A calculation based on conservation of mass, i.e.,
the amount of material going into a process is equal to the amount which
leaves the process. This relationship is often used to estimate solvent
losses from coating operations.
Metal Furniture Coating - The application of a coating material to any
furniture piece made of metal or any metal part which is or will be
assembled with other metal, wood fabric, plastic, or glass parts to form
a furniture piece including, but not limited to, tables, chairs, waste-
baskets, beds, desks, lockers, benches, shelving, file cabinets, lamps,
and room dividers. This definition shall not apply to any coating line
coating metal parts or products that is identified under the Standard
Industrial Classification Code for Major Groups 33, 34, 35, 36, 37, 38,
39, 40, or 41.
Method 24 - An EPA reference method to determine density, water content
and total volatile content (water and VOC) of coatings (40 CFR Part 60
Appendix A).
Method 25 - An EPA reference method to determine the VOC concentration
of a gas stream (40 CFR Part 60 Appendix A).
Miscellaneous Metal Parts and Products Coating - The coating of metal
parts not covered by other regulated surface coating operations.
Nonvolatiles - Parts of a coating which form the solid material that
coats the substrate and remains after the coating is dried or cured.
NSPS - New source performance standards, i.e., standards for emission of
air pollutants from new, modified, or reconstructed stationary emission
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sources which reflect the degree of emission limitation achievable
through the application of the best system of emission reduction which
(taking into account the cost of achieving such reduction) the
Administrator determines has been adequately demonstrated. The Clean
Air Act usually refers to these as standards of performance for new sta-
tionary sources.
Organic Vapor - Gaseous phase of an organic material or a mixture of
organic materials present in the atmosphere.
Overall Control - The product of the capture efficiency and the control
device efficiency gives an overall control efficiency for the process.
Over Varnish - Coating applied over the ink on the outside of beverage
cans to provide gloss and protect the can from corrosion and abrasion.
Ozone - An oxygen molecule composed of three oxygen atoms. It is a com-
ponent of photochemical smog and its concentration in the air is regu-
lated by pollution control laws. It is a criteria pollutant under
Section 109 of the Clean Air Act for which a State Implementation Plan
is required by Section 110 of the Act.
Paper Coating - As used in the Environmental Protection Agency's Control
Technique Guidelines, is the coating of paper, plastic, film or metallic
foil usually with a roll, knife, or rotogravure coater.
Photochemical Oxidant - Ozone and smaller amounts of other irritating
chemicals such as peroxyacetyl nitrate which are products of atmospheric
reactions of volatile organic compounds, oxides of nitrogen, and sun-
light. Photochemical oxidants are a major portion of the air pollution
commonly known as "smog".
Powder Coating - A coating applied as a dry powder which, when baked at
sufficiently high temperature, flows out to form a continuous film.
Prime Coat - The first film of coating material applied in a multiple
coat operation.
Prime Surfacer Coat - A film of coating material that touches up areas
on the surface not adequately covered by the prime coat before applica-
tion of the top coat.
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- Any stationary emission source other than a fuel combustion
emission source or an incinerator.
Recovered Solvent - Solvent which is extracted from a process or exhaust
stream usually by adsorption or condensation.
Reducing Solvent - A solvent added to dilute a coating usually for the
purpose of lowering the coating's viscosity.
Reverse Roll Coater - A roll type coater for paper, film, foil and metal
coil which applies coating to the web by a roll which turns in a reverse
direction to the direction of travel of the web. This procedure is said
to reduce striations in the coating.
Roll Coating - Method of applying coating to a flat sheet or strip in
which the coating is transferred by a roller or series of rollers.
Sheet Basecoat. - A coating applied to metal when the metal is in sheet
form to serve as either the exterior or interior of a can for either
two-piece or three-piece cans.
SIR - State Implementation Plans are required by Section 110 of the
Clean Air Act, as Amended. Each State is to submit a plan to the EPA
Administrator which provides for implementation, maintenance, and
enforcement of the national ambient air quality standards.
Solvent - A liquid used in a paint or coating to dissolve or disperse
film-forming constituents and to adjust viscosity. It evaporates during
drying and does not become a part of the dried film.
Solvent Borne Coating - Coating which contains only organic solvents.
If water is present, it is only in trace quantities.
Solvent Density - The weight per unit volume of a solvent or solvent
mixture. This number is often used in calculating the VOC emissions
from coatings. Densities of common organic solvents range from 6.6
Ib/gal to 9.5 Ib/gal. The EPA has chosen 7.36 Ib/gal as an average den-
sity of a coating solvent mixture to use in some calculations.
Substrate - The surface to which a coating is applied.
Thermal Incinerator - A device for oxidizing waste material via flame
and heat. This contrasts with a catalytic incinerator which incorpo-
rates a catalyst to aid the combustion.
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Thinner - A liquid used to reduce the viscosity of a coating and which
will evaporate before or during the cure of a film.
Three-Piece Can Side-Seam Sprav - A coating sprayed on the exterior and
interior of a welded, cemented, or soldered seam to protect the exposed
metal.
TOD Coat - The last coat applied in a coating system.
Traffic Paint - Any coating used for traffic control such as to paint
center lines on highways and also for parking lot and curb markings.
Transfer Efficiency - The ratio of the amount of coating solids
deposited onto the surface of the coated part to the total amount of
coating solids used multiplied by 100 to equal a percentage.
Three-Piece Can - A can made of three different pieces, a body, a top,
and a bottom.
Two Component Paint - A coating which is manufactured in two components
which must be maintained separate until shortly before use. When mixed,
the two liquids crosslink to form a solid composition.
Two-Piece Can Exterior End Coating - A coating applied to the exterior
end of a can to provide protection to the metal.
Volatile Organic Compound (VOC) - Any organic compound which partici-
pates in atmospheric photochemical reactions. This includes any organic
compound other than the following compounds: methane, ethane, methyl
chloroform (1,1,1-trichloroethane), CFC-113 (trichlorotrifluoroethane),
methylene chloride, CFC-11 (trichlorofluoromethane), CFC-12 (dichlorodi-
fluoromethane), CFC-22 (chlorodifluoromethane), FC-23 (trifluorome-
thane), CFC-114 (dichlorotetrafluoroethane), CFC-115 (chloropentafluoro-
ethane). These compounds have been determined to have negligible photo-
chemical reactivity. For purposes of determining compliance with emis-
sion limits, VOC will be measured by the approved test methods. Where
such a method also inadvertently measures compounds with negligible pho-
tochemical reactivity, an owner or operator may exclude these negligibly
reactive compounds when determining compliance with an emissions
standard.
Volatiles - Parts of a coating which may contribute to VOC emissions.
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Waterborne Coating - A coating which contains more than five weight per-
cent water in its volatile fraction.
Weight Percent Solids - The portion of a coating which remains as part
of the cured film expressed as percent by weight. This contrasts to
another convention of expressing content by volume percent.
Wood Furniture Coating - The coating of wood furniture products or parts
such as chair, tables, and bookshelves.
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SOURCES OF DEFINITIONS
1. April 17, 1987 Memorandum from G.T Helms, Chief, Control Programs
Operations Branch to Air Branch Chiefs. Definition of VOC.
2. Bay Area Air Quality Management District Regulation 8, December 19,
1984.
3. California Air Resources Board, Consideration of Model Rule for the
Control of Volatile Organic Compound Emissions from Can and Coil
Coating Operations, July 1978.
4. Glossary for Air Pollution Control of Industrial Coating
Operations. Second Edition. EPA-450/3-83-013R. December 1983.
5. Puget Sound Air Pollution Control Authority, Regulation II, March
13, 1980.
6. State of Illinois Air Pollution Control Regulations, Part I:
General Provisions, February 1982.
7. May 25, 1988 Memorandum from Ozone/Carbon Monoxide Program Branch,
AQMD, OAQPS to Air and Hazardous Materials Divisions, Regions I-X.
Issues Relating to VOC Regulation - Cut Points, Deficiencies, and
Deviations. Clarification to Appendix D of November 24, 1987
Federal Reaister.
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APPENDIX C. REFERENCE TEST
METHODS 24, 24A, AND 25
(Excerpt from 40 CFR, Part 60, Appendix A)
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Environmental Protection Agency
wrrHOD 24— DETERMINATION or VOLATILE
MATTER CONTENT, WATER CONTENT. DENSI-
,-y VOLUME SOLIDS, AND WEIGHT SOLIDS OF
COATINGS
and Principle
1.1 Applicability. This method applies to
the determination of volatile matter con-
twit. water content, density, volume solids.
jnd weight solids of paint, varnish, lacquer,
or related surface coatings.
1.2 Principle. Standard methods are used
to determine the volatile matter content.
v»ter content, density, volume solids, and
weight solids of the paint, varnish, lacquer,
or related surface coatings.
1 Applicable Standard Methods
Ose the apparatus, reagents, and proce-
dures specified in the standard methods
below:
2.1 ASTM D1475-80 (Reapproved 1980),
Sundard Test Method for Density of Paint,
Varnish. Lacquer, and Related Products (in-
corporated by reference — see 5 60.17).
22 ASTM D2369-81. Standard Test
Method for Volatile Content of Coatings
(Incorporated by reference— see ! 60.17).
J.3 ASTM D3792-79. Standard Test
Method for Water Content of Water-Reduc-
ible Paints by Direct Injection into a Oas
Chromatograph (incorporated by refer-
ence—see § 60.17).
J.4 ASTM D4017-81, Standard Test
Method for Water in Paints and Paint Ma-
terials by the Karl Fischer Titration
Method (incorporated by reference— see
160.17).
J. Procedure.
3.1 Volatile Matter Content. Use the pro-
cedure in ASTM D2369-81 (incorporated by
reference— see 5 60.17) to determine the
Tolatile matter content (may include water)
of the coating. Record the following infor-
mation:
W, = Weight of dish and sample before heat-
ing, g.
W,= Weight of dish and sample after heat-
ing, g.
W,= Sample weight, g.
Run analyses in pairs (duplicate sets) for
e»ch coating until the criterion in section
4-3 is met. Calculate the weight fraction of
the volatile matter (W.) for each analysis as
follows:
W, =
W,-W.
W,
(Eq. 24-1)
Pt. 60, App. A, Meth. 24
3.2 Water Content. For waterbome
(water reducible) coatings only, determine
the weight fraction of water (w> using either
"Standard Content Method Test for Water
of Water-Reducible Paints by Direct Injec-
tion into a Gas Chromatograph" or "Stand-
ard Test Method for Water in Paint and
Paint Materials by Karl Fischer Method."
(These two methods are incorporated by
reference—see i 60.17.) A waterbome coat-
ing is any coating which contains more than
5 percent water by weight in its volatile
fraction. Run duplicate sets of determina-
tions until the criterion in section 4.3 is met.
Record the arithmetic average (Ww).
3.3 Coating Density. Determine the den-
sity (Dc, kg/liter) of the surface coating
using the procedure in ASTM D1475-60
(Reapproved 1980) (incorporated by refer-
ence—see 5 60.17).
Run duplicate sets of determinations for
each coating until the criterion in section
4.3 is met. Record the arithmetic average
(D.).
3.4 Solids Content. Determine the
volume fraction (V.) solids of the coating by
calculation using the manufacturer's formu-
lation.
4. Data Validation Procedure
4.1 Summary. The variety of coatings
that may be subject to analysis makes it
necessary to verify the ability of the analyst
and the analytical procedures to obtain re-
producible results for the coatings tested.
This is done by running duplicate analyses
on each sample tested and comparing re-
sults with the within-laboratory precision
statements for each parameter. Because of
the inherent increased imprecision in the
determination of the VOC content of water-
borne coatings as the weight percent water
increases, measured parameters for water-
borne coatings are modified by the appro-
priate confidence limits based on between-
laboratory precision statements.
4.2 Analytical Precision Statements. The
within-laboratory and between-laboratory
precision statements are given below:
Volatile manor content. W,
Water content. W, .. ..
Density, D, . .
Within-
laboratoiy
1 5 pet W, ... .
2 9 pet W. ...
0001 kg/liter.
Between-
laooratory
4 7 pet W.
7 5 pet W.
0 002 kg/liter
Record the arithmetic average (W,).
4.3 Sample Analysis Criteria. For W. and
Ww. run duplicate analyses until the differ-
ence between the two values in a set is less
than or equal to the within-laboratory pre-
cision statement for that parameter. For D,
run duplicate analyses until each value in a
set deviates from the mean of the set by no
more than the within-laboratory precision
statement. If after several attempts it is
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Pt. 60, App. A, Meth. 24A
concluded that the ASTM procedures
cannot be used for the specific coating with
the established within-laboratory precision.
the Administrator will assume responsibility
for providing the necessary procedures for
revising the method or precision statements
upon written request to: Director, Emission
Standards and Engineering Division, (MD-
13) Office of Air Quality Planning and
Standards, U.S. Environmental Protection
Agency, Research Triangle Park. North
Carolina 27711.
4.4 Confidence Limit Calculations for
Waterbome Coatings. Based on the be-
tween-laboratory precision statements, cal-
culate the confidence limits for waterborne
coatings as follows:
To calculate the lower confidence limit.
subtract the appropriate between-laborato-
ry precision value from the measured mean
value for that parameter. To calculate the
upper confidence limit, add the appropirate
between-laboratory precision value to the
measured mean value for that parameter.
For W, and Dc, use the lower confidence
limits, and for Ww, use the upper confidence
limit Because V. is calculated, there Is no
adjustment for the parameter.
5. Calculations
5.1 Nonaqueous Volatile Matter.
5.1.1 Solvent-borne Coatings.
W. = W, Eq. 24-2
Where:
W.=Weight fraction nonaqueous volatile
matter, g/g.
5.1.2 Waterborne Coatings.
W.=W,-W. Eq. 24-3
5.2 Weight fraction solids.
W.= 1-W, Eq. 24-4
Where:
W.=Weight solids, g/g.
METHOD 24A—DETERMINATION or VOLATILE
MATTER CONTENT AND DENSITY or PRINT-
ING INKS AND RELATED COATINGS
1. Applicability and Principle.
1.1 Applicability. This method applies to
the determination of the volatile organic
compound (VOC) content and density of sol-
vent-borne (solvent reducible) printing inks
or related coatings.
1.2 Principle. Separate procedures are
used to determine the VOC weight fraction
and density of the coating and the density
of the solvent in the coating. The VOC
weight fraction is determined by measuring
the weight loss of a known sample quantity
which has been heated for a specified
length of time at a specified temperature.
The density of both the coating and solvent
are measured by a standard procedure.
From this information, the VOC volume
fraction is calculated.
40 CFR Ch. I (7-1-85 Edition)
2. Procedure.
2.1 Weight Fraction VOC.
2.1.1 Apparatus.
2.1.1.1 Weighing Dishes. Aluminum foil.
58 mm in diameter by 18 mm high, with a
flat bottom. There must be at least three
weighing dishes per sample.
2.1.1.2 Disposable syringe, 5 ml.
2.1.1.3 Analytical Balance. To measure to
within 0.1 mg.
2.1.1.4 Oven. Vacuum oven capable of
maintaining a temperature of 120±2'C and
an absolute pressure of 510 ±51 mm Hg for
4 hours. Alternatively, a forced draft oven
capable of maintaining a temperature of 120
±2'C for 24 hours.
2.1.1.5 Analysis. Shake or mix the sample
thoroughly to assure that all the solids are
completely suspended. Label and weigh to
the nearest 0.1 mg a weighing dish and
record this weight (M,,).
Using a 5-ml syringe without a needle
remove a sample of the coating. Weigh the
syringe and sample to the nearest 0.1 mg
and record this weight (M^). Transfer 1 to
3 g of the sample to the tared weighing
dish. Reweigh the syringe and sample to the
nearest 0.1 mg and record this weight (M
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Environmental Protection Agency
Pt. 60, App. A, Meth. 25
3.1 Weight Fraction VOC. Calculate the
weight fraction volatile organic content W0
using the following equation:
M,, 4- Mcv i-
(Eq. 24A-1)
Report the weight fraction VOC W0 as the
arithmetic average of the three determina-
tions.
3.2 Volume Fraction VOC. Calculate the
volume fraction volatile organic content V0
using the following equation:
Eq. 24A-2
4. Bibliography.
4.1 Standard Test Method for Density of
Paint, Varnish, Lacquer, and Related Prod-
ucts. ASTM Designation D 1475-60 (Heap-
proved 1980).
4.2 Teleconversation. Wright, Chuck,
Inmont Corporation with Reich, R. A..
Radian Corporation. September 25, 1979.
Gravure Ink Analysis.
4.3 Teleconversation. Oppenheimer.
Robert, Gravure Research Institute with
Burt. Rick. Radian Corporation, November
5, 1979. Gravure Ink Analysis.
METHOD 25—DETERMINATION OF TOTAL GASE-
OUS NONMETHANZ ORGANIC EMISSIONS AS
CARBON
1. Applicability and Principle
1.1 Applicability. This method applies to
the measurement of volatile organic com-
pounds (VOC) as total gaseous •nonmethane
organics (TGNMO) as carbon in source
emissions. Organic paniculate matter will
interfere with the analysis and therefore, in
some cases, an in-stack paniculate filter is
required. This method is not the only
method that applies to the measurement of
TGNMO. Costs, logistics, and other practi-
calities of source testing may make other
te?- methods more desirable for measuring
VOC of certain effluent streams. Proper
judgment is required in determining the
most applicable VOC test method. For ex-
ample, depending upon the molecular
weight of the organics in the effluent
stream, a totally automated semi-continu-
ous nonmethane organic (NMO) analyzer
interfaced directly to the source may yield
accurate results. This approach has the ad-
vantage of providing emission data semi-
continuously over an extended tune period.
Direct measurement of an effluent with a
flame ionization detector (FID) analyzer
may be appropriate with prior characteriza-
tion of the gas stream and knowledge that
the detector responds predictably to the or-
ganic compounds in the stream. If present,
methane will, of course, also be measured.
In practice, the FID can be applied to the
determination of the-mass concentration of
the total molecular structure of the organic
emissions under the following limited condi-
tions: (1) Where only one compound is
known to exist; (2) when the organic com-
pounds consist of only hydrogen and
carbon; (3) where the relative percentage of
the compounds is known or can be deter-
mined, and the FID response to the com-
pounds is known: (4) where a consistent
mixture of compounds exists before and
after emission control and only the relative
concentrations are to be assessed: or (5)
where the FID can be calibrated against
mass standards of the compounds emitted
(solvent emissions, for example).
Another example of the use of a direct
FID is as a screening method. If there is
enough information available to provide a
rough estimate of the analyzer accuracy.
the FID analyzer can be used to determine
the VOC content of an uncharacterized gas
stream. With a sufficient buffer to account
for possible inaccuracies, the direct FID can
be a useful tool to obtain the desired results
without costly exact determination.
In situations where a qualitative/quanti-
tative analysis of an effluent stream is de-
sired or required, a gas chromatographic
FID system may apply. However, for
sources emitting numerous organics, the
time and expense of this approach will be
formidable.
1.2 Principle. An emission sample is with-
drawn from the stack at a constant rate
through a chilled condensate trap by means
of an evacuated sample tank. TGNMO are
determined by combining the analytical re-
suits obtained from independent analyses of
the condensate trap and sample tank frac-
tions. After sampling is completed, the or-
ganic contents of the condensate trap are
oxidized to carbon dioxide (CO,) which is
quantitatively collected in an evacuated
vessel; then a portion of the CO, is reduced
to methane (CH.) and measured by a FID.
The organic content of the sample fraction
collected in the sampling tank is measured
by injecting a portion into a gas chromato-
graphic (GO column to achieve separation
of the nonmethane organics from carbon
monoxide (CO), CO, and CH.; the nonmeth-
ane organics (NMO) are oxidized to CO,, re-
duced to CH., and measured by a FID. In
C-3
-------
Pt. 60, App. A, Meth. 25
this manner, the variable response of the
FID associated with different types of or-
ganics is eliminated.
2. Apparatus
The sampling system consists of a conden-
sate trap, flow control system, and sample
tank (Figure 1). The analytical system con-
sists of two major sub-systems: an oxidation
system for the recovery and conditioning of
the condensate trap contents and a NMO
analyzer. The NMO analyzer is a GC with
backflush capability for NMO analysis and
is equipped with an oxidation catalyst, re-
duction catalyst, and FID. (Figures 2 and 3
are schematics of a typical NMO analyzer.)
The system for the recovery and condition-
ing of the organics captured in the conden-
sate trap consists of a heat source, oxidation
catalyst, nondispersive infrared (NDIR) an-
alyzer and an intermediate collection vessel
(Figure 4 is a schematic of a typical system.)
TGNMO sampling equipment can be con-
structed from commercially available com-
ponents and components fabricated in a ma-
chine shop. NMO analyzers are available
commercially or can be constructed from
available components by a qualified instru-
ment laboratory.
2.1 Sampling. The following equipment is
required:
2.1.1 Probe. 3.2-mm OD
-------
Environmental Protection Agency
mg CO, CO,, and CH. from NMO com-
pounds as demonstrated according to the
procedures established in this method (sec-
tion 5.2.5). Addendum I of this method lists
a column found to be acceptable.
2.2.2.4 Sample Injection System. A GC
sample injection valve fitted with a sample
loop properly sized to interface with the
NMO analyzer (1 cc loop recommended).
2.2.2.5 FID. A FID meeting the following
specifications is required.
2.2.2.5.1 Linearity. A linear response (±
5%) over the operating range as demonstrat-
ed by the procedures established in section
5.2.2.
2.2.2.5.2 Range. Signal attenuators shall
be available to produce a minimum signal
response of 10 percent of full scale for a full
scale range of 10 to 50000 ppm CH..
2.2.2.6 Data Recording System. Analog
strip chart recorder or digital intergration
system compatible with the FID for perma-
nently recording the analytical results.
2.2.3 Barometer. Mercury, aneroid, or
other barometer capable of measuring at-
mospheric pressure to within 1 mm Hg.
2.2.4 Thermometer. Capable of measur-
ing the laboratory temperature within 1'C.
2.2.5 Vacuum Pump. Capable of evacuat-
ing to an absolute pressure of 10 mm Hg.
2.2.6 Syringe (2). 10 /il and 100 jil liquid
injection syringes.
2.2.7 Liquid Sample Injection Unit. 316
SS U-tube fittea with a Teflon injection
septum, see Figure 6.
3. Reagents
3.1 Sampling. Crushed dry ice is required
during sampling.
3.2 Analysis.
3.2.1 NMO Analyzer. The following gases
are needed:
3.2.1.1 Carrier Gas. Zero grade gas con-
taining less than 1 ppm C. Addendum I of
this method lists a carrier gas found to be
acceptable.
3.2.1.2 Fuel Gas. Pure hydrogen, contain-
ing less than 1 ppm C.
3.2.1.3 Combustion Gas. Zero grade air or
oxygen as required by the detector.
3.2.2 Condensate Recovery and Condi-
tioning Apparatus.
3.2.2.1 Carrier Gas. Five percent O. in N,,
containing less than 1 ppm C.
3.2.2.2 Auxiliary Oxygen. Zero grade
oxygen containing less than 1 ppm C.
3.2.2.3 Hexane. ACS grade, for liquid in-
jection.
3.2.2.4 Toluene. ACS grade, for liquid in-
jection.
3.3 Calibration. For all calibration gases,
the manufacturer must recommend a maxi-
mum shelf life for each cylinder (i.e., the
length of time the gas concentration is not
expected to change more than ± 5 percent
from its certified value). The date of gas cyl-
inder preparation, certified organic concen-
Pt. 60, App. A, Meth. 25
tration and recommended maximum shelf
life must be affixed to each cylinder before
shipment from the gas manufacturer to the
buyer. The following calibration gases are
required.
3.3.1 Oxidation Catalyst Efficiency
Check Calibration Gas. Gas mixture stand-
ard with nominal concentration of 1 percent
methane in air.
3.3.2 Flame lonization Detector Linearity
and Nonmethane Organic Calibration Gases
(3). Gas mixture standards with nominal
propane concentrations of 20 ppm. 200 ppm.
and 3000 ppm, in air.
3.3.3 Carbon Dioxide Calibration Gases
(3). Gas mixture standards with nominal
CO, concentrations of 50 ppm, 500 ppm. and
1 percent, in air.
NOTI: total NMO less than 1 ppm required
for 1 percent mixture.
3.3.4 NMO Analyzer System Check Cali-
bration Gases (4).
3.3.4.1 Propane Mixture. Gas mixture
standard containing (nominal) 50 ppm CO,
50 ppm CH.. 2 percent CO,, and 20 ppm
C>H.. prepared in air.
3.3.4.2 Hexane. Gas mixture standard
containing (nominal) 50 ppm hexane in air.
3.3.4.3 Toluene. Gas mixture standard
containing (nominal) 20 ppm toluene in air.
3.3.4.4 Methanol. Gas mixture standard
containing (nominal) 100 ppm methanol in
air.
4. Procedure
4.1 Sampling.
4.1.1 Sample Tank Evacuation and Leak
Check. Either in the laboratory or in the
field, evacuate the sample tank to 10 mm
Hg absolute pressure or less (measured by a
mercury U-tube manometer) then leak
check the sample tank by isolating the tank
from the vacuum pump and allowing the
tank to sit for 10 minutes. The tank is ac-
ceptable if no change in tank vacuum is
noted.
4.1.2 Sample Train Assembly. Just prior
to assembly, measure the tank vaccuum
using a mercury U-tube manometer. Record
this vaccum (Pu), the ambient temperature
(Tu>, and the barometric pressure (PM) at
this time. Assuring that the flow shut-off
valve is in the closed position, assemble the
sampling system as shown in Figure 1. Im-
merse the condensate trap body in dry ice to
within 2.5 or 5 cm of the point where the
inlet tube joins the trap body.
4.1.3. Pretest Leak Check. A pretest leak
check is required. After the sampling train
is assembled, record the tank vacuum as in-
dicated by the vaccum gauge. Wait a mini-
mum period of 10 minutes and recheck the
indicated vacuum. If the vacuum has not
changed, the portion of the sampling train
behind the shut-off valve does not leak and
is considered acceptable. To check the front
C-5
-------
Pt. 60, App. A, Meth. 25
portion of the sampling train, assure that
the probe tip is tightly plugged and then
open the sample train flow shut-off valve.
Allow the sample tram to sit for a minimum
period of 10 minutes. The leak check is ac-
ceptable If no visible change in the tank
vacuum gauge occurs. Record the pretest
leak rate (cm/Hg per 10 minutes). At the
completion of the leak check period, close
the sample flow shut-off valve.
4.1.4. Sample Train Operation. Place the
probe into the stack such that the probe is
perpendicular to the direction of stack gas
flow: locate the probe tip at a single prese-
lected point. If a probe extension which will
not be analyzed as pan of the condensate
trap is being used, assure that at least a 15
cm section of the probe which will be ana-
lyzed with the trap is in the stack effluent.
For stacks having a negative static pressure,
assure that the sample port is sufficiently
sealed to prevent air in-leakage around the
probe. Check the dry Ice level and add ice if
necessary. Record the clock time and
sample tank gauge vacuum. To begin sam-
pling, open the flow shut-off valve and
adjust (if applicable) the control valve of
the flow control system used in the sample
train: maintain a constant flow rate (±10
percent) throughout the duration of the
sampling period. Record the gauge vacuum
and flowmeter setting (if applicable) at 5-
mlnute intervals. Select a total sample time
greater than or equal to the minimum sam-
pling time specified in the applicable sub-
part of the regulation: end the sampling
when this time period Is reached or when a
constant flow rate can no longer be main-
tained due to reduced sample tank vacuum.
When the sampling is completed, close the
flow shut-off valve and record the final
sample time and guage vacuum readings.
Norr. If the sampling had to be stopped
before obtaining the minimum sampling
time (specified In the applicable subpart)
because a constant flow rate could not be
maintained, proceed as follows: After re-
moving the probe from the stack, remove
the used sample tank from the sampling
train (without disconnecting other portions
of the sampling train) and connect another
sample tank to the sampling train. Prior to
attaching the new tank to the sampling
train, assure that the tank vacuum (meas-
ured on-slte by the U-tube manometer) has
been recorded on the data form and that
the tank has been leak-checked (on-slte).
After the new tank Is attached to the
sample train, proceed with the sampling
until the required minimum sampling time
has been exceeded.
4.1.5 Post Test Leak Check. A leak check
is mandatory at the conclusion of each test
run. After sampling is completed, remove
the probe from the stack and plug the probe
tip. Open the sample train flow shut-off
40 CFR Ch. I (7-1-85 Edition)
valve and monitor the sample tank vacuum
gauge for a period of 10 minutes. The leak
check is acceptable if no visible change tn
the tank vacuum gauge occurs. Record the
post test leak rate (cm Hg per 10 minutes)
If the sampling train does not pass the post
leak check, invalidate the run or use a pro-
cedure acceptable to the Administrator to
adjust the data.
4.2 Sample Recovery. After the post test
leak check is completed, disconnect the con-
densate trap at the flow metering system
and tightly seal both ends of the condensate
trap. Keep the trap packed in dry ice until
the samples are returned to the laboratory
for analysis. Remove the flow metering
system from the sample tank. Attach the U-
tube manometer to the tank (keep length of
connecting line to a minimum) and record
the final tank vacuum (P,); record the tank
temperature (T,) and barometric pressure at
this time. Disconnect the manometer from
the tank. Assure that the test run number is
properly Identified on the condensate trap
and the sample tanlc(s).
4.3 Condensate Recovery and Condition-
ing. Prepare the condensate recovery and
conditioning apparatus by setting the carri-
er gas flow rate and heating the catalyst to
its operating temperature. Prior to Initial
use of the condensate recovery and condi-
tioning apparatus, a system performance
test must be conducted according to the pro-
cedures established in section 5.1 of this
method. After successful completion of the
initial performance test, the system is rou-
tinely used for sample conditioning accord-
ing to the following procedures:
4.3.1 System Blank and Catalyst Effi-
ciency Check. Prior to and Immediately fol-
lowing the conditioning of each set of
sample traps, or on a daily basis (whichever
occurs first) conduct the carrier gas blank
test and catalyst efficiency test as specified
in sections 5.1.1 and 5.1.2 of this method.
Record the carrier gas initial and final
blank values, B,, and B* respectively. If the
criteria of the tests cannot be met, make the
necessary repairs to the system before pro-
ceeding.
4.3.2 Condensate Trap Carbon Dioxide
Purge and Sample Tank Pressurization. The
first step in analysis is to purge the conden-
sate trap of any CO, which it may contain
and to simultaneously pressurize the sample
tank. This Is accomplished as follows:
Obtain both the sample tank and conden-
sate trap from the test run to be analyzed.
Set up the condensate recovery and condi-
tioning apparatus so that the carrier flow
bypasses the condensate trap hook-up ter-
minals, bypasses the oxidation catalyst, and
is vented to the atmosphere. Next, attach
the condensate trap to the apparatus and
pack the trap in dry ice. Assure that the
valves isolating the collection vessel corvnec-
C-6
-------
Environmental Protection Agency
Pt. 60, App. A, Meth. 25
tion from the atmospheric vent and the
vacuum pump are closed and then attach
the sample tank to the system as if it were
the intermediate collection vessel. Record
the tank vacuum on the laboratory data
form. Assure that the NDIR analyzer indi-
cates a zero output level and then switch
the carrier flow through the condensate
trap; immediately switch the carrier flow
from vent to collect. The condensate trap
recovery and conditioning apparatus should
now be set up as indicated in Figure 8. Mon-
itor the NDIR; when CO, is no longer being
passed through the system, switch the carri-
er flow so that it once again bypasses the
condensate trap. Continue in this manner
until the gas sample tank is pressurized to a
nominal gauge pressure of 800 mm Hg. At
this time, isolate the tank, vent the carrier
now, and record the sample tank pressure
(Ptt), barometric pressure (P*), and ambient
temperature (Ta). Remove the sample tank
from the system.
4.3.3 Recovery of Condensate Trap
Sample. Oxidation and collection of the
sample in the condensate trap is now ready
to begin. From the step just completed In
section 4.3.1.2 above, the system should be
set up so that the carrier flow bypasses the
condensate trap, bypasses the oxidation cat-
alyst, and is vented to the atmosphere.
Attach an evacuated intermediate collection
vessel to the system and then switch the
carrier so that it flows through the oxida-
tion catalyst. Switch the carrier from vent
to collect and open the valve to the collec-
tion vessel; remove the dry ice from the trap
and then switch the carrier flow through
the trap. The system should now be set up
to operate as indicated in Figure 9. During
oxidation of the condensate trap sample,
monitor the NDIR to determine when all
the sample has been removed and oxidized
(indicated by return to baseline of NDIR an-
alyzer output). Begin heating the conden-
sate trap and probe with a propane torch.
The trap should be heated to a temperature
at which the trap glows a "dull red" (ap-
proximately 500'C). During the early part
of the trap "bum out." adjust the carrier
and auxiliary oxygen flow rates so that an
excess of oxygen is being fed to the catalyst
system. Gradually increase the flow of carri-
er gas through the trap. After the NDIR in-
dicates that most of the organic matter has
been purged, place the trap in a muffle fur-
nance (500'C). Continue to heat the probe
with a torch or some other procedure (e.g.,
electrical resistance heater). Continue this
procedure for at least 5 minutes after the
NDIR has returned to baseline. Remove the
heat from the trap but continue the earner
flow until the intermediate collection vessel
is pressurized to a gauge pressure of 800 mm
Hg (nominal). When the vessel is pressur-
ized, vent the carrier: measure and record
the final intermediate collection vessel pres-
sure (Pf) as well as the barometric pressure
(P».), ambient temperature (T,), and collec-
tion vessel volume (V,).
4.4 Analysis. Prior to putting the NMO
analyzer into routine operation, an initial
performance test must be conducted. Start
the analyzer and perform all the necessary
functions in order to put the analyzer in
proper working order, then conduct the per-
formance test according to the procedures
established in section 5.2. Once the perform-
ance test has been successfully completed
and the CO, and NMO calibration response
factors determined, proceed with sample
analysis as follows:
4.4.1 Daily operations and calibration
checks. Prior to and immediately following
the analysis of each set of samples or on a
daily basis (whichever occurs first) conduct
a calibration test according to the proce-
dures established in section 5.3. If the crite-
ria of the daily calibration test cannot be
met. repeat the NMO analyzer performance
test (section 5.2) before proceeding.
4.4.2 Analysis of Recovered Condensate
Sample. Purge the sample loop with sample
and then inject a preliminary sample In
order to determine the appropriate FID at-
tenuation. Inject triplicate samples from
the intermediate collection vessel and
record the values obtained for the condens-
ible organics as CO. (C<«).
4.4.3 Analysis of Sample Tank. Purge the
sample loop with sample and inject a pre-
liminary sample in order to determine the
appropriate FID attenuation for monitoring
the back/lushed non-methane organics.
Inject triplicate samples from the sample
tank and record the values obtained for the
nonmethane organics (C,»).
5. Calibration and Operational Checks
Maintain a record of performance of each
item.
5.1 Initial Performance Check of Con-
densate Recovery and Conditioning Appara-
tus.
5.1.1 Carrier Gas and Auxiliary Oxygen
Blank. Set equal flow rates for both the ear-
ner gas and auxiliary oxygen. With the trap
switching valves in the bypass position and
the catalyst in-line, fill an evacuated inter-
mediate collection vessel with earner gas.
Analyze the collection vessel for CO,: the
earner blank is acceptable if the CO, con-
centration is less than 10 ppm.
5.1.2 Catalyst Efficiency Check. Set up
the condensate trap recovery system so that
the carrier flow bypasses the trap inlet and
is vented to the atmosphere at the system
outlet. Assure that the valves isolating the
collection system from the atmospheric vent
and vacuum pump are closed and then
attach an evacuated intermediate collection
vessel to the system. Connect the methane
standard gas cyclinder (section 3.3.1) to the
C-7
-------
Pt. 60, App. A, M.th. 25
system's condensate trap connector (probe
end. Figure 4). Adjust the system valvuig so
that the standard gas cylinder acts as the
earner gas and adjust the flow rate to the
rate normally used during trap sample re-
covery. Switch off the auxiliary oxygen flow
and then switch from vent to collect in
order to begin collecting a sample. Continue
collecting a sample in a normal manner
until the intermediate vessel is filled to a
nominal gauge pressure of 300 mm Hg.
Remove the intermediate vessel from the
system and vent the carrier flow to the at-
mosphere. Switch the valving to return the
system to its normal carrier gas and normal
operating conditions. Analyze the collection
vessel for CO,; the catalyst efficiency is ac-
ceptable if the COt concentration is within
±5 percent of the expected value.
5.1.3 System Performance Check. Con-
struct a liquid sample injection unit similar
in design to the unit shown in Figure 6.
Insert this unit into the condensate recov-
ery and conditioning system in place of a
condensate trap and set the carrier gas and
auxiliary oxygen flow rates to normal oper-
ating levels. Attach an evacuated intermedi-
ate collection vessel to the system and
switch from system vent to collect. With the
carrier gas routed through the injection
unit and the oxidation catalyst, inject a
liquid sample (see. 5.1.3.1 to 5.1.3.4) via the
injection septum. Heat the injection unit
with a torch while monitoring the oxidation
reaction on the NDIR. Continue the purge
until the reaction is complete. Measure the
final collection vessel pressure and then
analyze the vessel to determine the CO, con-
centration. For each injection, calculate the
percent recovery using the equation in sec-
tion 6.6.
The performance test Is acceptable if the
average percent recovery Is 100 ± 10 percent
with a relative standard deviation (section
6.7) of less than 5 percent for each set of
triplicate injections as follows:
5.1.3.1 100 fJ hexane.
5.1.3.2 10 >U hexane.
5.1.3.3 100 pi toluene.
5.1.3.4 10 IA! toluene.
5.2 Initial NMO Analyzer Performance
Test.
5.2.1 Oxidation Catalyst Efficiency
Check. Turn off or bypass the NMO analyz-
er reduction catalyst. Make triplicate Injec-
tions of the high level methane standard
(section 3.3.1). The oxidation catalyst oper-
ation is acceptable If no FID response is
noted.
5.2.2 Analyzer Linearity Check and NMO
Calibration. Operating both the oxidation
and reduction catalysts, conduct a linearity
check of the analyzer using the propane
standards specified in section 3.3. make trip-
licate injections of each calibration gas and
then calculate the average response factor
(area/ppm C) for each gas. as well as the
40 CFR Ch. I (7-1-85 Editio.)
overall mean of the response factor values.
The instrument linearity is acceptable if the
average response factor of each calibration
gas is within ± 5 percent of the overall mean
value and if the relative standard deviation
(section 6.7) for each set of triplicate injec-
tions is less than ±5 percent. Record the
overall mean of the propane response factor
values as the NMO calibration response
factor (RFmio)-
5.2.3 Reduction Catalyst Efficiency
Check and CO. Calibration. An exact deter-
mination of the reduction catalyst efficien-
cy is not required. Instead, proper catalyst
operation is indirectly checked and continu-
ously monitored by establishing a CO, re-
sponse factor and comparing it to the NMO
response factor. Operating both the oxida-
tion and reduction catalysts make triplicate
injections of each of the CO, calibration
gases (section 3.3.3). Calculate the average
response factor (area/ppm) for each calibra-
tion gas, as well as the overall mean of the
response factor values. The reduction cata-
lyst operation is acceptable if the average
response factor of each calibration gas is
within ± 5 percent of the overall mean value
and if the relative standard deviation (sec-
tion 6.7) for each set of triplicate injections
is less than ±5 percent. Additionally, the
CO, overall mean response factor must be
within ± 10 percent of the NMO calibration
response factor calculat-
ed during the Initial performance test (sec-
tion 5.2.2). Use the dally response factor
(DRF_,) for analyzer calibration and the
calculation of measured CO, concentrations
in the collection vessel samples. In addition.
record the NMO blank value (B.); this value
should be less than 10 ppm.
C-8
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Environmental Protection Agency
5.3.2 NMO Calibration. Inject triplicate
samples of the mixed propane calibration
cylinder (section 3.3.4.1) and calculate the
average NMO response factor. The system
operation is adequate if the calculated re-
sponse factor is within a: 10 percent of the
BF«io calculated during the initial perform-
ance test (section 5.2.1). Use the daily re-
sponse factor (DRFKMo) for analyzer calibra-
tion and calculation of NMO concentrations
In the sample tanks.
5.4 Sample Tank. The volume of the gas
sampling tanks used must be determined.
Prior to putting each tank in service, deter-
mine the tank volume by weighing the
tanks empty and then filled with deionized
Pt. 60, App. A, Meth. 25
distilled water; weigh to the nearest 5 gm
and record the results. Alternatively, meas-
ure the volume of water used to fill the
tanks to the nearest 5 ml.
5.5 Intermediate Collection Vessel. The
volume of the intermediate collection ves-
sels used to collect Cd during the analysis
of the condensate traps must be determined.
Prior to putting each vessel into service, de-
termine the volume by weighing the vessel
empty and then filled with deionized dis-
tilled water; weigh to the nearest 5 gm and
record the results. Alternatively, measure
the volume of water used to fill the tanks to
the nearest 5 ml.
C-9
-------
Pt. 60, App. A, Meth. 25 40 CFR Ch. I (7-1-85 Edition)
6. Calculations
Note: All equations are written using absolute pressure;
absolute pressures are determined by adding the measured barometric
pressure to the measured gauge pressure.
6.1 Sample Volume. For each test run. calculate the gas
volume sampled:
Ys - 0.386 V
6.2 Noncondenslble Organlcs. For each sample tank, determine
the concentration of nonmethane organlcs (ppm C):
ptf
1*
^r~ •
Tt TtT
^ r
F J-l CtBJ " *a
__
6.3 Condenslble Organlcs. For each compensate trap determine
the concentration of organlcs (ppm C):
V P,
Cc • 0.386 ^-^-
i !
" n-i
~^am
s-8*
C-10
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Environmental Protection Agency Pt. 60, App. A, Meth. 25
6.4 Total Gaseous Nonmethane Organics (TGNMO). To determine
the TGNMO concentration for each test run. use the following
equation:
' ct * Cc
6.5 Total Gaseous Nonmethane Organlcs (TGNMO) Mass
Concentration. To determine the TGNMO mass concentration as
carbon for each test run, use the following equation:
Mr - Q.49S C
6.6 Percent Recovery. To calculate the percent recovery for
the liquid Injections to the condensat» recovery and conditioning
system use the following equation:
M v
percent recovery » T.6 r- ~-
L p
6.7 Relative Standard Deviation.
RSO •
T
C-ll
-------
Pt. 60, App. A, Meth. 25
Where:
B. = Measured NMO blank value for NMO
analyzer, ppm C.
B, = Measured CO, blank value for conden-
sate recovery and conditioning system
earner gas. ppm CO,
C=total gaseous nonmethane organic
(TGNMO) concentration of the efflu-
ent, ppm C equivalent.
C«=Calculated condensible organic (conden-
sate trap) concentration of the effluent,
ppm C equivalent.
Co. = Measured concentration (NMO analyz-
er) for the condensate trap (intermedi-
ate collection vessel), ppm CO,
C,=Calculated noncondensible organic con-
centration (sample tank) of the effluent,
ppm C equivalent.
Co, = Measured concentration (NMO analyz-
er) for the sample tank, ppm NMO.
L=Volume of liquid injected, microliters.
M=Molecular weight of the liquid injected,
g/g-mole.
M«=total gaseous non-methane organic
(TGNMO) mass concentration of the ef-
fluent, mg C/dscm.
N=Carbon number of the liquid compound
injected (N=7 for toluene, N=6 for
hexane).
P,=Final pressure of the Intermediate col-
lection vessel, mm Hg absolute.
Pu=Gas sample tank pressure prior to sam-
pling, mm Hg absolute.
P,=Gas sample tank pressure after sam-
pling, but prior to pressurizing, mm Hg
absolute.
Pu=Final gas sample tank pressure after
pressurizing, mm Hg absolute.
T,= Final temperature of intermediate col-
lection vessel, 'K.
Tu=Sample tank temperature prior to sam-
pling. -K.
T,=Sample tank temperature at completion
of sampling, *K.
Tu=Sample tank temperature after pressur-
izing *K.
V=Sample tank volume, cm.
V, = Intermediate collection vessel volume,
cm.
V.=Gas volume sampled, dscm.
n=Number of data points.
q=Total number of analyzer injections of
intermediate collection vessel during
analysis (where k=injection number, 1
. . . q).
r=Total number of analyzer Injections of
sample tank during analysis (where
j=injection number. 1. . . r).
x,=Individual measurements.
X=Mean value.
p=Density of liquid injected, g/cc.
7. Bibliography
7.1 Sale, Albert E.. Samuel Witz. and
Robert D. MacPhee. Determination of Sol-
vent Vapor Concentrations by Total Com-
40 CFR Ch. I (7-1-85 Edition)
bustion Analysis: A Comparison of Infrared
with Flame lonization Detectors. Paper No
75-33.2 (Presented at the 68th Annual Meet-
ing of the Air Pollution Control Associatioa
Boston. MA. June 15-20. 1975.) 14 p.
7.2 Salo. Albert E.. William L. Oaks, and
Robert D. MacPhee. Measuring the Organic
Carbon Content of Source Emissions for Air
Pollution Control. Paper No. 74-190. (Pre-
sented at the 67th Annual Meeting of the
Air Pollution Control Association. Denver
CO. June 9-13, 1974.) 25 p.
METHOD 25—ADDENDUM I. SYSTEM
COMPONENTS
In test Method 25 several important
system components are not specified; in-
stead minimum performance specifications
are provided. The method is written in this
manner to permit Individual preference in
choosing components, as well as to encour-
age development and use of unproved com-
ponents. This addendum is added to the
method in order to provide users with some
specific information regarding components
which have been found satisfactory for use
with the method. This listing is given only
for the purpose of providing information
and does not constitute an endorsement of
any product by the Environmental Protec-
tion Agency. This list is not meant to imply
that other components not listed are not ac-
ceptable.
1. Condensate Recovery and Conditioning
System Oxidation Catalyst. H" ODxl4" In-
conel tubing packed with 8 inches of hopca-
lite* oxidizing catalyst and operated at
800'C in a tube furnace.
NOTE: At this temperature, this catalyst
must be purged with carrier gas at all times
to prevent catalyst damage.
2. NMO Analyzer Oxidation Catalyst, v,"
ODxl4" Inconel tubing packed with 6
inches of hopcalite oxidizing catalyst and
operated at 800'C in a tube furnace. (See
note above.)
3. NMO Analyzer Reduction Catalyst. Re-
duction Catalyst Module; Byron Instru-
ments. Raleigh, N.C.
4. Gas Chromatographic Separation
Column. V> inch OD stainless steel packed
with 3 feet of 10 percent methyl silicone, Sp
2100 (or equivalent) on Supelcoport (or
equivalent). 80/100 mesh, followed by 1.5
feet Porapak Q (or equivalent) 60/80 mesh.
The inlet side is to the silicone. Condition
the column for 24 hours at 200'C with 20
cc/min N, purge.
During analysis for the nonmethane or-
ganics the separation column is operated as
follows: First, operate the column at -78'C
(dry ice bath) to elute CO and CH«. After
•MSA registered trademark.
C-12
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Environmental Protection Agency Pt. 60, App. A, Meth. 25
the CH. peak operate the column at O'C to NOTE: Elthane and ethylene may or may
elute COi. When the CO« is completely not be measured using this column: whether
eluted. switch the carrier How to backilush or not ethane and ethylene are quantified
the column and simultaneously raise the will depend on the CO, concentration in the
column temperature to 100'C in order to gas sample. When high levels of CO, are
elute all nonmethane organics (exact Urn- present, ethane and ethylene will elute
ings for column operation are determined under the tall of the CO, peak.
from the calibration standard). 5 carrier Gas. Zero grade nitrogen or
NOTE: The dry ice operating condition helium or zero air.
may be deleted if separation of CO and CH,
Is unimportant.
C-13
-------
•r\
PROBE
EXTENSION
(IF REQUIRED)
VACUUM
GAUGE
FLOW
RATE
CONTROLLER
1
PROBE
STACK
WALL
o
JL ON/OFF
Ox FLOW
^^ VALVE
CONNECTOR
3
s
•0
TB
r
M
Ul
QUICK r-i
CONNECTO
A
I I
CONDENSATE
TRAP
EVACUATED -
SAMPLE *3
TANK L
Figure 1. Sampling apparatus.
cn
m
a.
y
5'
-------
Environmental Protection Agency
It. 60, App. A, Meth. 25
CARRIER GAS
CALIBRATION STANDARDS
SAMPLE TANK
INTERMEDIATE
COLLECTION
VESSEL
(CONDITIONED TRAP SAMPLE)
NON-METHANE
ORGANICS
HYDROGEN
COMBUSTION
AIR
Figure 2. Simplified schematic of non-methane organic (NMO) analyzer.
C-15
-------
I
(—>
cr>
SAMPLE / CALIIRATION
TANK / CYLINDERS
T>
•o
Figure 3. Nonmethane organic (NMO) analyzer.
O
k
m
a
3.*
-------
Environmental Protection Agency
Pt. 60, App. A, M*th. 25
VALVE
INTERMEDIATE
COLLECTION
VESSEL
'FOR EVACUATING COLLECTION
VESSELS AND SAMPLE TANKS
IOPTIONAL)
Figure 4. Condensate recovery and conditioning apparatus.
C-17
-------
Pi. 60, App. A, Meth. 25
40 CFR Ch. I (7-J-45 Edition)
PROBE, 3mm (1/8 in) 0.0.
INLET TUBE, 6mm ('/. in) 0.0
CONNECTOR
I A A
EXIT TUBE, 6mm (It in) 0 0
CRIMPED AND WELDED GAS-TIGHT SEAL
vBARREL 19mm I* m) O.D. X 140mm I5-V4 in) LONG,
1.5mm 11/16 in) WALL
NO. 40 HOLE
(THRU BOTH WALLS)
WELDED JOINTS
^ BARREL PACKING. 316 SS WOOL PACKED TIGHTLY
AT BOTTOM, LOOSELY AT TOP
HEAT SINK (NUT. PRESS FIT TO BARREL)
WELDED PLUG
MATERIAL TYPE 316 STAINLESS STEEL
Figure 5 Condensate trap?
C-18
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Environmental Protection Agency
Pt. 60, App. A, Meth. 25
INJECTION
SEPTUM
CONNECTING T
FROM
CARRIER
APPROX.
15 cm (6 in)
CONNECTING
ELBOW
TO
CATALYST
V
6 mm (1/4 in)
316 SS TUBING
Figure 6. Liquid sample injection unit.
C-19
-------
Pt. 60, App. A, Math. 25
40 CFR Ch. I (7-1-85
VOLATILE ORGANIC CARBON
FACILITY_
LOCATION.
DATE
SAMPLE LOCATION.
OPERATOR
RUNNUMIER.
TANK NUMBER.
_TRAP NUMBER.
LEAK RATE
em H| / 10 i
SAMPLE ID NUMB£H_
TANK VACUUM,
i>m H| cm H|
PRETEST IMANOMETERI
POST TEST [MANOMETER)
IG1UGEI
ir.llir.Fl
BAROMETRIC
PRESSURE
mm H|
AMBIENT
TEMPERATURE
•c
TIME
CLOCKySAMPLE
GAUGE VACUUM
cm H|
FLOWMETER SETTING
COMMENTS
Figure 7. Example Field Data Form
C-20
-------
Environmental Protection Agency
Pi. 60, App. A, Meth. 25
(CLOSED)
f METERS ~^\ TBA'
-j r-jj/ -rn iwa
i r "" K0w r^T 1 1
" N .CONTROL J
^ ii
-------
Pt. 60, App. A, Meth. 25
40 CFR Ch. I(7-1-85
J5
(CLOSED)
£
VAC
PL
HOW
/" *ETERS^\
1 f~ 1 1 / "x
1
T v~\^ FI°* \rrf
U .CONTROL U
i ini 3£ VALVES vf, Hi
j ( L tyi^V -T>^1 1
(CLOSED) (OPEN)
/
T
— {x*\j [ PURIFIER
3L
[
|
(OPEN)
A A
CARRIER
02 6 ptrcMit
07/1*2
VEN
^
(OPEN) )f-f) REGULATING V-
6A VALVE O
(OPEN) 1
QUICK r£]
)
MP MERCURY INTERMEDIATE
MANOMETER COLLECTION
TRAP
BYPASS
SWITCHING
-J-j VALVES r-L-v,- j^
CONNECTORS^ J c
4/ ^1 =
T 7 1
A PRO« C
/ ^-ENO C
y*
//< HEAT
SAMPLE
CONOENSATE
TRAP
r HEAT
, NOIR
I
]
J HEAT
: TKACE
">/~M
f-
CATALYST
IVPAB
VENT
^
-WAY \>J
ALVES-'T
1
OXIDATION
CATALYST
HEATED
CHAMIER
1- — __
• FOR MONITORING PROGRESS
OF COMBUSTION ONLY
"FOR EVACUATING COLLECTION
VESSELS AND SAMPLE TANKS
(OPTIONAL)
1
1 1
\/
HjO
TRAP
Figure 9 Condensate ncovery and conditioning apparatus, collection of trap organic*.
C-22
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA 340/1-88-003
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Recordkeeping Guidance Document for Surface Coating
Operations and the Graphic Arts Industry
5. REPORT DATE
July 1989
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Recordkeeping requirements are described for surface coating operations and
for sources in the graphic arts industry. The surface coating operations are
described and the types of application methods, solvents/diluents, and control
devices used by surface coating operations are summarized. Sample forms that can
be used by surface coating operations and the graphic arts industry for record-
keeping are provided with instructions for their completion. Suggestions are
given for procedures that can be used by enforcement officials to verify the data
submitted by a source. Example calculations to determine compliance using record-
keeping data are shown. Graphic arts industry sources are described separately.
Differences between recordkeeping for the graphics arts industry and that for
surface coating operations are detailed. Emission limits applicable to individual
surface coating operations are summarized.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Volatile Organic Compounds
Surface Coating Operations
Graphic Arts
Printing
Recordkeeping
8. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report I
Unclassified
21. NO. OF PAGES
146
20. SECURITY CLASS (This page I
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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