-New Source Performance Standards-
Automobile Surface Coating
Public
Participation
The promulgated
NSPS for automotive
surface coatings were
published in the
Federal Register (45
FR 85410) on Decem-
ber 24, 1980. The
promulgated standards
reflect changes made
as a result of comments received from industry
representatives, coatings manufacturers, trade
and professional associations, state air pol-
lution control agencies. The Background In-
formation Document (BID), "Automobile and
Light-Duty Truck Surface Coating Opera-
tions — Background Information for Promul-
gated Standards," (EPA-450/3-79-030b) dis-
cusses these comments in detail and is avail-
able from the EPA Library (MD-35), Research
Triangle Park, North Carolina 27711, tele-
phone (919) 541-2777. For further informa-
tion, contact Gene W. Smith, Chief, Standards
Preparation Section (MD-13), U.S. Environ-
mental Protection Agency, Research Triangle
Park, North Carolina 27711, telephone (919)
541-5421.
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United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
January 1981
New Source Performance Standards
oEPA
Automobile Surface Coatings
Final Regulation
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-New Source Performance Standards-
Automobile Surface Coating
Regulatory
Authority
The 1977 Clean Air Act Amendments call for
a comprehensive national program to reduce
air pollution and improve air quality. Section
111 of the Act requires the U.S. Environ-
mental Protection Agency (EPA) to establish
nationwide emission standards for selected
new, modified and reconstructed stationary
sources. These New Source Performance
Standards (NSPS) are intended to minimize
new air pollution problems. The NSPS for
automobile and light duty truck surface coat-
ing operations are discussed here.
Emission
Limits
On December 24,1980,
EPA published a final
regulation to reduce
emissions of volatile
organic compounds
(VOC) from automo-
bile surface coating
operations. VOC are
emitted when surface
coatings cure (dry) after application. VOC
react in the atmosphere to form photo-
chemical oxidants, pollutants that irritate the
respiratory system and damage plant tissue
and other materials. VOC are found in engine
exhausts, and in gasoline and surface coating
solvent vapors. The regulation establishes
performance standards for new, modified, and
reconstructed automobile and light-duty
truck surface coating operations within as-
sembly plants. Three major coating operations
in assembly plants—prime coat, guide coat,
and topcoat applications—will be covered by
the standards. The standards limit VOC emis-
sions in kilograms per liter of applied coating
solids as follows: 0.16 from prime coat op-
erations; 1.40 from guide coat operations; and
1.47 from topcoat operations.
Affected
Sources
NSPS for automotive surface coating opera-
tions were proposed on October 5, 1980.
Almost 15 percenter 135,000 metric tons of
VOC emissions from all industrial coating op-
erations nationwide came from automotive
surface coating operations in 1976.
The standards for surface coating operations
apply to all new, modified, and reconstructed
automobile and light-duty truck surface coat-
ing operations for which constructions began
after October 5, 1979. No existing plant
would be covered by the NSPS unless it under-
goes either a modifi-
cation that increases
VOC emissions or is
reconstructed. Opera-
tions for coating all-
metal bodies or metal
bodies with plastic
parts attached are cov-
ered by the standards.
However, operations for coating all plastic
bodies or body parts are not covered. Also
exempt from the standards are modifcations
required by annual model changeovers.
Control
Options
The intent of the stand-
ards is to require use
of the best demonstra-
ted system of contin-
uous emission reduc-
tion and control tech-
nology considering ec-
onomic, energy and
other impacts not di-
rectly related to air quality. VOC control
technology for automobile surface coating op-
erations include: (1) use of coatings contain-
ing relatively low quantities of VOC; (2) use
of improved painting methods such as electro-
static spray; or (3) use of incineration, carbon
adsorption or other similar emission con-
trol devices. Any one or a combination of
these may be used to achieve the standards.
For purposes of compliance, data calculated
by Reference Method 24 (Determination of
Volatile Matter Content, Water Content, Den-
sity, Volume Solids, and Weight Solids of Sur-
face Coatings) or manufacturers formulation
data will be used to determine the VOC con-
tent of coating materials. Reference Method
25 (Determination of Total Gaseous Nonme-
thane Organic Emissions as Carbon) will be
used to determine the percentage reduction of
VOC achieved by emission control devices.
To facilitate enforcement of the standards,
the owner or operator is required to conduct
monthly performance tests and to report non-
compliance by the tenth day of the following
month.
Impacts
Environmental: EPA estimates the standards
will reduce VOC emissions by 4800 metric
tons per year or 80 percent by 1983, com-
pared to emission levels currently allowed by
most states. This is based on estimates that
four new assembly-line surface coating opera-
tions will be constructed by 1983. Water pol-
lution and solid waste impacts will be neg-
ligible compared to the amounts of each that
are normally generated by existing plants.
Energy: Energy consumption at typical as-
sembly plants will increase about 25 percent—
the equivalent of 18,000 barrels of fuel oil per
year. This corresponds to a nationwide in-
crease of 72,000 barrels of fuel oil per year by
1983.
Economic: Capital
and annual costs of
automotive surface
coating operations will
increase as a result of
the standards. EPA
estimates the price of
an automobile or light-
duty truck will increase
by less than 0.1 percent, spread over the
entire production process. Control costs for
four new assembly lines planned by 1983 will
increase by about $19 million, or 0.2 percent
of the $10 billion planned for capital expen-
ditures.
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