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                                      -2-




   Impact of Control Techniques Guideline  (CTG) dated  September 6,  1991.	




      This firm has demonstrated  that alcohol  can be completely eliminated




from the lithographic process and still  maintain the highest  of quality




standards in so doing. This firm produces  art  catalogs  for  many of  the leading




museums in Washington and New York along with  the most  difficult advertising




and commercial print projects. Since isopropyl alcohol  repryesints one  of  the




greatest culprits in the quest to reduce VOC's in the printing  industry,




emphasis should be given to the technical  and  educational aspects of  weaning




this industry completely away from its use.




      Operating a complete facility without alcohol is  not  an easily




accomplished task. For example, the rubber rollers used to  apply the  alcohol




substitute & water combination must be maintained in superior condition and




the durometer of the roller (its softness) is critical  to the success of




alcohol substitutes. This is an expensive process to constantly monitor roller




condition and durometer. Rollers must be changed out and replaced far more




frequently without alcohol than with alcohol.




      Roller settings are more critical when not using alcohol.  Alcohol tends




to cover many mechanical sins. These settings are time consuming and require




the attention of the top paid craftsmen  (not more lowly paid  helpers). These




settings must be checked and adjusted more frequently due to  the fact that




without alcohol one has a more limited tolerance range.




      If alcohol can be eliminated from  the process, it is not  logical that




the temperature must be continuously monitored by probes and  recorded for each




fountain unit.  Without alcohol the VOC reduction is of substantial proportions




in itself,  and  the substitutes are used in such small volume  that the total




VOC emission is not a significant  number. Also, the vast majority of dampening




systems in  operation today are refrigerated due to the need to  maintain




constant percentage of alcohol in  the fountain solutions.  Printers who do not

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                                       -3-




 maintain a constant percentage of alcohol will see unacceptable variations in




 the print quality.  Thus,  refrigeration was adapted to dampening fountains in




 attempts to control the evaporation rate of alcohol purely for quality




 reasons.   Should  one unit of refrigeration malfunction and the temperature




 thereby increase,  an operator is  forced to repair it to provide consistency of




 quality.  So the process itself of causing erratic quality ensures the repair



 and maintenance of  such equipment --  thereby making the need to install probes




 and recording  devices redundant and in our opinion not necessary.




       The experience and  learning curve to run high-quality work without




 alcohol is significant. The  experimental phase of testing alcohol substitutes




 in  one fountain on  a multi-color  press lasted  approximately two months.  Once




 alcohol substitutes are introduced  into the  entire press  we noted the real




 impact of the  learning curve:



       a)     Dampening changes  are more difficult  to  effect  using alcohol



             substitutes.




       b)     Roller  problems  are more  critical




       c)     Roller  replacements become major cost  item.




       d)     Build-up of by-products on ink rollers cause  inking irregularities




       e)     Dot gain is increased as  dampening  efficiency decreases due  to



             elimination of alcohol




       f)     Maintenance is more critical  in dampening  units and inking units.




       g)     Spoilage due  to  color being "out of tolerance"  is  more prevalent




             due to  difficulty  in  balancing water and ink. (Cost of reprinting



             entire  jobs can  be  extremely high.)




 (Suggestion) Monitor  fountain  solutions with testing for  VOC concentration and




 temperature  only on  those units using  alcohol. Refrigeration should not  be the




 issue here  -- but rather alcohol.   Testing refrigerated fountain solutions is




not going  to be program effective and will do practically nothing  toward the




goal of reducing VOC emissions. The lithographic printing process  itself will

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                                      -4-



"police" the industry in maintaining refrigerated units to correct




temperatures. However, testing those fountain units vhich use alcohol  --




whether refrigerated or not refrigerated -- would be program effective. But




since there is nothing to prohibit non-refrigerated fountains from using




isopropyl alcohol, these units should be addressed in the scheme of imposing




controls.



Sec. D-8, C 1-2 stipulates that on ". . . any press using refrigeration .  . .




shall install, maintain and operate a temperature probe . . .".No mention




made of non-refrigerated units. It should be more important to monitor the




non- refrigerated units,  especially if using isopropyl alcohol.




      The monitoring process itself is burdensome, especially to the small



operators. To install the monitors, educate those responsible, and detail a



person to record and maintain the records will be a very real cost, which in




my estimation will yield negligable results in reducing VOC emissions. In a




small shop -- such as the majority of printing establishments are -- this will




pose a detrimental burden on management which is already over worked and




frustrated by a myriad of regulations and paper work.  I know of not one small




shop which can afford the payroll of someone to monitor fountains every eight



hours.




      If monitoring is deemed necessary it  would be sufficient to monitor and




record the results on every separate batch  of fountain solution when mixed.




Regardless of what is being tested for,  it  will not materially change while in




the process of being used.  Here again the printer and process itself will




"police" the results because if that batch  of fountain solution does change,




it will show up as unacceptable quality and force the operator to shut down.




      Create the incentive  for the owner/operator to explore alternatives and




substitutes instead of imposing yet another layer of non-productive cost in an




industry facing competitive pressures from  over-seas.




      Cleaning solutions  are a unique problem and also a dilemma to printers.


                                   >". ~ "*
                                   1 -' V-

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                                       -5-




 A rag with solvent can easily be rubbed over an inked surface and the ink




 thereby removed.  (The key vork is "rubbed"). A multitude of solvents could




 pass this usage test easily,  regardless of VOC content. Few of the




 applications of cleaning solvents are this simple though.




       Consider the structure  of an inking unit on a printing press.  Current



 sheet-fed press equipment use approximately 20 -  22 rollers in each printing




 unit. The diagrams on pages 2-2 and 3-6 are over  simplifications of roller




 configurations for the average sheet-fed press. Your diagrams show 11 ink




 rollers,  whereas  the sheet-fed presses used today have 20  to 22 ink rollers.




 Thus a six-color  press will have from 120 to 132  rollers which will require




 cleaning  at  least once per day --  possibly several times.  The surfaces of




 some of these rollers are not visible,  being surrounded by the outer rollers.



 The cleaning solutions of products with 30 percent or less VOC concentrations




 will not  dry properly and those inner rollers will not clean-up well.  It  is




 imperative that the cleaning  solutions  used on press rollers will:



       a)  clean properly,




       b)  dry reasonably quickly,




       c)  not leave a residual film.




 It  is impossible  to access  some of the  ink rollers to hand wipe the  residual




 solvent without a major disassembly of  the inking  system which would include a



 day-long  process.




      The percentage of VOC mandated for  cleaning  solvents should  be analyzed




 carefully and  researched  by technical experts thoroughly knowledgeable of




 press equipment and the unique  constraints various ink systems impose upon the




 printer.  To  do  otherwise,  the printer cannot  operate.  I  cannot believe the




 30 percent VOC  limit will yield an acceptable roller solvent.  The  Roller  wash




we currently use, which is giving  satisfactory results,  contains 84  percent




VOC's. It  is incomprehensible to me  that we could  find an  acceptable roller




wash containing only 30 percent VOC's. To  attempt  to use an unsatisfactory

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                                      -6-




product would cripple our operation.




      Ink VOC emissions are not as critical to the small/medium sheet-fed




lithographer as to the larger operators simply because  they use less




volume/poundage. However, such factors as drying, scuff resistance,




appearance, and handling on press are all important.  The recent introduction




of vegetable-based inks such as soy-bean is promising but the results do not




indicate that petroleum-based inks can be phased out any time in the




foreseeable future. There are problems contingent with  the vegetable-based




inks that small operators simply do not have the access to technology and




research to properly make that transition at this point in time.




                                    SUMMARY




      The monitoring requirements as set forth in Section D.8 (b) "Fountain




Solution VOC Concentration" definitely pose an onerous and costly imposition




upon the small/medium operators and should be amended to apply only if




isopropyl alcohol is used in the fountain, and then only applied on a "batch"




basis instead of every 8-hours. Once tested a "batch" will not change




significantly in VOC concentration.




      The Section D.8 (c) "Fountain Solution Temperature" should only be




imposed on those units using isopropyl alcohol.  This section targets




"refrigeration equipment" when it should target  alcohol. There should not be




the need to test any press which uses alcohol substitutes.




      Cleaning solutions should be researched by those intimately familiar




with printing press inking systems prior to  mandating a specific percentage of




VOC concentration.




                                    Respectfully submitted,








                                    C.  Vm.  Schneidereith,  Jr.




                                    President

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1.2  QUESTIONS AND COMMENTS FROM THE COMMITTEE
Question:   Why  is  industry not taking advantage of the large
            cost savings  due  to a  reduction in  alcohol?
Response:   The  industry  has  reduced alcohol for Occupational
            Safety  and  Health Administration (OSHA) regulations
            and  fire  insurance benefits.   However,  it is easier
            for  the operator  to use too much isopropyl alcohol
            (IPA) because it  makes the press easier to operate
            and  keep  within specifications.
Question:   Will ink  pigments poison the  catalyst in a catalytic
            incinerator and can the incinerator actually achieve
            95 percent  control?
Response:   It may  not  be ink pigments that poison the catalyst
            - other ingredients in the inks and in the fountain
            solution  may  poison the catalyst in many cases.
            Most vendors  work with the printers in choosing  the
            best catalyst for their operation.   Industry has
            successfully  used catalysts without poisoning.   As
            for  control,  current use in industry indicates that
            the  catalytic incinerator  can achieve 98 percent
            control.
Question:   Do the  16,700 facilities in non-attainment areas, as
            referred  to in the presentation, take into account
            the  newly revised non-attainment area boundaries?
Response:   Since the boundaries were  only revised about a week
            before  this meeting, there was no time to take into
            account the changes and redo  the numbers for this
            presentation.
Question:   How  are the very  small and large model plants
            differentiated?
Response:   The  size  of the plants are determined by the number
            of printing units.
Question:   Were the  operating costs of incinerators based on
            3000 operating hours per year, and  are the
            incinerators  shut down at  all other times?
Response:   Some incinerators may  shut down, while others may
            "idle"  during the off-hours,  making warm up
                               11

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            unnecessary.  Energy costs were  calculated  based  on
            3000 operating hours per year.
Comment:     The wording in the draft CTG  should be  clarified  to
            ensure that monitoring should take place  only when
            the unit is operational.
Question:    Would reformulation of the inks  to soybean  inks be a
            viable control option for the larger  facilities?
Response:    Soy inks are used in non-heatset processes, which
            have low emissions to begin with.  Requiring heatset
            processes to change to non-heatset was  not
            considered reasonable, and hence were beyond the
            scope of RACT.
Question:    The total percent reduction is plausible  based on
            what the control device sees, but given the amount
            of potential emissions, does  this really  correspond
            to what the control device actually sees?
Response:    We may have not made it very  clear that the
            efficiency values refer to the efficiency of the
            control device and not the percent of all VOC's
            applied to the substrate.  There is approximately 20
            percent retention of VOC's from  ink in  the  paper.
Question:    Do all the volatile organic compounds (VOC) from
            heatset inks go out from the  dryer?
Response:    Essentially, all the VOC's from  the inks  that are
            volatilized exit through the  dryer.
Question:    Do the control options for large sheet-fed  plants
            differ technically from other sheet-fed plants as to
            warrant the different control options?  What is the
            difference between these two  types of plants and  why
            can't control for one unit be the same  for  24 units?
Response:    The lower level of control for larger plants was  due
            to the fact that large plants could cope  with the
            costs better than smaller plants.
Question:    Since the alcohol content of  the fountain solution
            is falling with changes in the industry,  what year
            were the model plants emissions  based on?
                                12

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Response:    The use of fountain solution in the model plant was
             based on a report of a survey performed for a
             meeting held in 1989;  the meeting notes were
             published in 1990.
Question:    Is  there a point in which the performance of the
             fountain solution decreased a great deal due to a
             reduction in alcohol?
Response:    There is no perfect linear relationship between
             alcohol content and performance;  with a management
             commitment to quality, a reduction in alcohol should
             not be a problem.
Question:    What are alcohol substitutes made of?
Response:    They are made up of cellulose derivatives, propylene
             glycol, and glycol ethers.   Material safety data
             sheets (MSDS) do not indicate what makes up the VOC
             content or what the hazardous air pollutant (HAP)
             content is, and, since many vendors feel that the
             fountain solution ingredients are proprietary, it is
             difficult to identify  all the ingredients of
             fountain solution additives.
Comment:     Inks should be considered differently than coatings
             and the structure of the model rule should be
             changed to indicate this difference.
Comment:     There were some reservations that requiring lower
             VOC cleaning solution  (<30 percent VOC) would reduce
             the number of different cleaning products available
             and would thereby impede the cleaning process, since
             one cleaning solution  typically cannot be used for
             every application.   Some printers use 100 percent
             VOC cleaning solution  and maintain that there is no
             viable substitute.
Response:    Users of the lower VOC cleaning solution exist and
             say that they are able to use these cleaners
             successfully.  The EPA is trying to obtain more
             complete data on this  issue and will address it in
             the future.
                                13

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                     2.0  DISCUSSION SECTION

2.1 AGI ROSOS, PRESIDENT, ROSOS RESEARCH LABORATORIES, INC.
2.1.1   Presentation
    Ms. Agi Rosos of Rosos Research Laboratories, Inc. gave a
presentation on alcohol substitutes.   Rosos Research Laboratories
has been a manufacturer of alcohol replacements for over 21
years.   Ms. Rosos read from a prepared speech that is enclosed.
                                14

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2.1.2   Questions and Comments
Question:     Glycol  ethers  were  mentioned as a component of the
             fountain solution.   Since glycol ethers are HAP's,
             are  VOC's being replaced by an equally harmful
             chemistry?
Response:     Ms.  Rosos responded that while the first few
             formulations did indeed contain HAP's, Rosos has
             completely  reformulated the product and are
             currently testing the  new HAP-free formulation.
Question:     Where does  OSHA stand  on alcohol replacements?
Response:     The  response was that  these substitutes are well
             within  the  limits set  by OSHA.   However, the
             17 percent  alcohol  level probably would not be
             allowed by  most states,  but printers that stay below
             10 percent  alcohol  would generally not have any
             problems with  OSHA.
Question:     What are the differences between large sheet-fed and
             other sheet-fed plants,  and is a control distinction
             necessary for  the two  categories?
Response:     Ms.  Rosos answered  that a distinction is not
             necessary but  she does encourage refrigeration on
             all  fountain solutions.
Question:     Why  isn't it possible  to measure the VOC content in
             the  fountain solution  by taking samples from the
             trays and tanks, and why should samples be taken
             from freshly mixed  solution?
Response:     The  response was that  the tanks and trays contain
             recirculated solution  with residual contaminants due
             to contact  with other  parts of the press.  The
             samples should be taken near the tap of the alcohol
             proportioner,  as alcohol is mixed with water.
                                15

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2.2  PAUL MARTIN,  C.A. ENTERPRISES, LTD.
2.2.1  Presentation
    Mr. Paul Martin of C.A. Enterprises, LTD. gave a
presentation regarding the use of magnets in reducing the surface
tension of water in the fountain solution.  C.A. Enterprises has
been primarily a manufacturer of magnets for the treatment of
water used for heating and cooling in residential and commercial
buildings uses for the last 20 years.  The magnets help control
lime, scale and corrosion in equipment that contacts water.
Mr. Martin read from a prepared speech that is enclosed.
                                16

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2.2.2  Questions and Comments
Question:    If  the  magnets  can  do  what you have said they will,
             then why  aren't they used by all  printers?
Response:    Mr. Martin  responded that the use of magnets for
             this industry is a  completely new technology.
             Currently,  there are approximately 1,000 units in
             operation.   The technology was introduced to the
             industry  in April 1990.
Question:    How expensive are these  magnets as compared to the
             cost of a press?
Response:    The response was that  magnets cost about $3000 per
             press,  with a life  approximately  egual  to that of a
             press.  The cost of a  press is approximately $1.6 to
             2 million dollars.
Question:    What types  of modifications to the presses are
             necessary for retrofitting the magnets  to the press?
Response:    Mr. Martin  responded that it took about 10 minutes
             to  add  magnets  to one  press.   After the
             modification, press operators may need  to make
             adjustments to  the  process.  The  most significant
             adjustment  would be the  speed of  the water roller.
Question:    Is  there  anything in the draft CTG that would
             preclude  the use of these magnets?
Response:    There is  nothing in the  draft CTG indicating that
             the magnets are not an option of  control.  In fact,
             the quality of  the  process would  increase as a
             result  of using the magnets.   In  addition, alcohol
             substitutes would become more effective since water
             is  more soluble with the magnets.  Some users run
             the presses with magnets and an alcohol-free
             fountain  solution.
                                17

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2.3  WILSON CUNNINGHAM,  VICE PRESIDENT TECHNICAL RESEARCH,
     AMERICAN NEWSPAPER PUBLISHERS ASSOCIATION
2.3.1  Presentation Summary
    Mr. Wilson Cunningham for the American Newspaper Publishers
Association (ANPA)  gave a presentation to discuss ANPA's comments
on the draft CTG.   The ANPA is a trade association that
represents publishers of approximately 1350 newspapers.
Mr. Cunningham read from a prepared speech that is enclosed.
                               18

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2.3.2  Questions and Comments
Question:   What  is  the  content  of  ink pigments?
Response:   Mr. Cunningham  responded that black ink is mainly
            carbon black, and  all color newspaper pigments are
            complex  organic compounds.
Question:   In  reference to the  chart in the presentation
            showing  the  recommended ranges for fountain solution
            and cleaning solution usage,  as compared to those
            shown in the draft CTG,  the new calculated medians
            seem  to  fall within  the ranges reported in the draft
            CTG,  so  why  would  it be necessary to recalculate  the
            usage rates?
Response:   Mr. Cunningham  responded that while the medians fell
            within the ranges  given in the draft CTG,  the upper
            limits of those ranges  were too high.   In addition
            the ANPA would  prefer to be regulated based on real
            data  as  opposed to projected data.
Question:   Since there  is  such  a wide variation in the volatile
            percent  of inks, could  the volatile content be
            regulated to 10 percent or less?
Response:   The response was that inks are formulated to satisfy
            the consumer as well as regulations.   As rule of
            thumb, as the VOC  content increases,  the amount of
            rub off  decreases, so it is important to find a
            middle ground to allow  the least amount of rub off
            without  significantly increasing VOC content.  In
            general,  VOC content would not go down very much.
Comment:    The rule recommended by the draft CTG is not
            intended to  be  used  for the purpose of emission
            inventories.  Although  credit for waste ink and
            solvent  ink  used to  determine NSPS rules,  it is not
            pertinent to the draft  CTG.
                                19

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2.4  JAMES RENSON, COORDINATOR ENVIRONMENTAL AFFAIRS,  NATIONAL
     ASSOCIATION OF PRINTING INK MANUFACTURERS
2.4.1  Presentation Summary
    Mr. James Renson, of the National Association of Printing
Ink Manufacturers (NAPIM),  gave a presentation on printing inks
as related to the draft CTG.  NAPIM is a national trade
association representing small, medium and large printing ink
manufacturers in the United States.  There are 80 members in this
association accounting for approximately 90 percent of the total
U.S. sales of printing ink.  Mr. Renson read from a prepared
speech that is enclosed.
                                20

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2.4.2  Questions and Comments
Question:    Where  are  no-rub inks  used?
Response:    The  oils in  inks are absorbed leaving carbon black
             on the top of  the substrate.   A no-rub ink has more
             resin,  but also  has higher VOC content.   Some
             examples of  printers using no-rub ink are Time and
             Newsweek magazines.
Question:    Is "Method 30" an EPA  method?
Response:    Mr.  Renson said  that "Method  30" is  a California Bay
             Area Air Quality Management District (BAAQMD)  test
             method.  There is an ATSM  method for EPA Method 24,
             and  there  will soon be an  ATSM Method for BAAQMD
             Method  30.
                               21

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2.5  ENVIRONMENTAL CONSERVATION BOARD (ECB) OF THE GRAPHIC
     COMMUNICATIONS INDUSTRIES
2.5.1  Gerald Bender, Vice President Environmental Affairs,
       R.R. Donnelley & Sons Company; Web Segment
    2.5.1.1  Presentation Summary.  Mr. Bender began his
presentation with a discussion on the sources of VOC's.  The
three sources of VOC are:  ink oil solvents, fountain solution
additives, and cleaning solvents.  Ink oil solvents were not
originally considered VOC's, but when the definition of VOC was
changed, the ink oils fell into the category of VOC's.  These
oils can be compared to No. 2 fuel oil.  The need for fountain
solution as well as the amount depends on the equipment.
Cleaning solutions include blanket wash, auto blanket wash,
roller wash, and other miscellaneous cleaning, such as equipment
cleaners, plate cleaners, etc.
    To explain the concept of blanket-to-blanket printing, a
schematic of the unit was presented (see attachment).  Ink and
fountain solution are applied to a large cylinder called a print
plate.  The image is formed on the print plate and transferred to
the blanket cylinder, and then the final image is printed on the
substrate.  The system shown in the schematic is called a
blanket-to-blanket unit because it prints both sides of the
substrate at the same time.
    There are many types of applicators for fountain solutions,
each one requiring a different need for alcohol or alcohol
substitutes.  The first type of applicator is the continuous
dampening system.  Fountain solution is contained in a shallow
pan and, as shown on the schematic for the continuous dampening
system, there are rollers that pick up the solution and carry it
to the rest of the unit.  In some cases, brushes or spray nozzles
are used in place of rollers to transfer solution to the plate
cylinder.  In this case, alcohol substitutes may be used in
concentrations of about 0.5 to 1 percent, but only to keep the
blanket cylinder free from debris, not for high quality printing.
    This schematic shows a blanket-to-blanket web offset press.
For a four-color press, there would be four sequential units
                                22

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followed by a dryer.  Drying does not occur between colors as
with rotogravure printing.
    A continuous dampening system requires at least 3 to
4 percent alcohol in the fountain solution for good quality.  The
ECB is asking that the level of alcohol allowed be increased to
5 percent to allow a margin for error.  Small printers cannot
afford to not use alcohol.  They need a little more latitude to
add alcohol or alcohol substitutes to make the chemistry work.
    Mr. Bender remarked that since the document deals with
existing operations, printers cannot afford to redesign their
presses to operate with less alcohol.  Alcohol not only cleans
the print plate, but it also changes the rheology properties of
the water (i.e. lowers the surface tension of the water).  Small
variations in the amount of alcohol alter the viscosity of the
water, and therefore change the rate at which the solution is
transferred to the plate.  Older presses cannot speed up their
fountain rollers to accommodate the reduction in alcohol.
    Mr. Bender addressed the control options next.  The three
types of controls are condenser filters, condenser filters with
activated carbon, and incinerators (both catalytic and thermal).
A recommended control level in terms of percent reduction for
condenser filters does not make sense because condenser filters
operate best when the loading is very high.  The ECB suggested
that a concentration limit should be set on the exhaust stream
instead of a percent reduction.
    Condenser filters with carbon work very well in removing the
condensed oils from the dryer exhaust, but the oils are almost
impossible to remove from the carbon.  According to Mr. Bender,
hot air and low pressure steam will not remove the condensed
oils.  Since most facilities do not have high pressure steam at
their convenience, this is not a viable option.  It was suggested
that this type of control was a misapplication of activated
carbon.
    The ECB reviewed the costs for the different control options
and found capital and annual cost to be slightly lower than
expected.   Not included in the cost analysis were costs for
                                23

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safety purges of the incinerator and replacement of the filter
material in the condenser filter.
    The next issue addressed by Mr. Bender was the model  rule in
Appendix D of the draft CTG.  The first topic was the
applicability section (section D.2) of the model rule.  The ECB
would like some guidance to the States as to the definition of a
major source; also, the States need information on how to apply
RACT to the industry.
      The ECB then suggested that the control level  (for  the
emissions standards section (D.4) of the draft CTG) should be 90
percent instead of 95 percent to give the printer some leniency
in operation.
    Mr. Bender suggested changes in the equipment standards
section of the draft CTG (section D.5).  The changes mainly
concerned raising the levels of the alcohol permitted in the
fountain solution.  Also, the States have required the exclusive
use of EPA Test Method 25 to test heatset dryer emissions.  This
test, however, is not repeatable and therefore not a reliable
test method for this industry.
    The rest of the suggested changes for the draft CTG concern
rhetoric and are attached following this summary.
2.5.2  William Schaeffer, Consultant to Graphics Arts Technical
       Foundation (GATF), Chairman of the Technical Committee
    2.5.2.1  Presentation.  Mr. Schaeffer read from a prepared
speech that is enclosed.
2.5.3  C. Wm. Schneidereith, Jr., President, Schneidereith
       & Sons, Inc.; Sheet-fed Industry Segment
    2.5.3.1 Presentation.  Schneidereith & Sons, Inc. is  a
commercial printing facility that operates 20 printing units in
its sheet-fed, offset lithographic facility.  Mr. Schneidereith
read from a prepared speech that is enclosed.
                                24

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2.5.4  Questions and Comments
Question:   An  alternative  concentration requirement may work
            with  incinerators,  but would it work with condenser
            filters?   Couldn't  the air flow from the dryers be
            increased  to  dilute the exhaust and, hence,  lower
            the concentration of VOC's measures, without any
            real  decrease in emissions?
Response:   There is a high concentration of VOC's in the dryer.
            Increasing the  air  flow is not a good idea,  since
            the air leaving should be at the saturation  level or
            dew point.  This option will be researched further.
Question:   Were  there any  numbers to support the claim  that as
            VOC concentration decreases, solid waste increases?
Response:   Waste is generated  during changeover and runs.
            There are  no  numbers at this time concerning the
            trade-off  between VOC's and solid waste.  Data is
            available  on  waste  incurred during various run
            parameters.   Less effective cleaners increase waste
            and decrease  safety.
Question:   During the three presentations, each speaker
            recommended a different limit on the percent alcohol
            allowed in the  fountain solution.  What are  the
            reasons for this discrepancy?
Response:   The different levels refer to different segments of
            the industry.
Question:   Is  taking  samples of batches of solution common for
            small or for  large  facilities?
Response:   Large shops have central fountain solution
            circulators,  smaller shops make 10 gallons at a
            time. Once the batch is made, it won't change.
Question:   Have  cleaning solutions of 30 percent VOC have been
            tried? Have  they been examined for quality?
Response:   These cleaners  have been tried and they do not work.
            The lower  the VOC content, the longer the drying
            time  and the  volume necessary for good cleaning is
            increased.  The press is also shut down during this

-------
            time, so  it would  shut  down  longer when cleaning
            with these lower VOC  cleaners.
Question:    Six tons  per year  of  cleaning solution emits
            5.13 tons of VOC,  corresponding to approximately
            84 percent VOC.  Is the residual VOC-free?  If so,
            what happens to the remaining 16 percent?   Are all
            the volatile materials  emitted?
Response:    Some of the remaining cleaning solution leaves the
            shop in the cleaning  rags, and the rest goes into
            the waste solution.
Question:    The model plants showed that the fountain solution
            for non-heatset web facilities emits  the largest
            amount of VOC's; another speaker indicated  that this
            was too large.  Is this true?
Response:    The emissions were indeed too high.
Question:    Do inks volatilize?
Response:    The inks  do not volatilize during the normal process
            until, in the case of heatset inks, they reach the
            dryer, where 80 percent is volatilized in the dryer.
Question:    Have you  had any experience  with the  magnet as a
            form of water conditioning?
Response:    GATF submitted surface  tension data comparing water
            with and  without magnets.  No difference was noted
            in the lab studies.
                                26

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nooirn
                   NATIONAL ASSOCIATION OF PRINTING INK MANUFACTURERS, INC.
                   47 Halstead Avenue, Harrison, New York 10528 / Phone: 914-835-5650
                                                  Fax:914-835-5988

                   JAMES H. SUTPHIN, Executive Director

                                   November  11, 1991

Mr. Bruce C. Jordan
Chair, National Air Pollution Control Techniques Advisory
Committee
Director, Emissions Standards Division  (MD-13) Office of Air
Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC  27711


Dear Mr. Jordan,

The purpose of this letter is to present comments on the draft
CTG for offset lithographic printing prepared for EPA by the
Radian Corp.  These comments are presented by the National
Association of Printing Ink Manufacturers, Inc. (NAPIM) on behalf
of the printing ink industry -

NAPIM

NAPIM is a national trade association representing small, medium
and large printing ink manufacturers in the U.S.  Its eighty
members account for nearly ninety percent of the total U.S. sales
of printing ink.  The printing ink industry is composed of 224
companies operating a total of 504 manufacturing facilities
according to the U.S. Census of Manufactures for the year 1987.
Total shipments of printing ink in the U.S. were over $2.7
billion in 1990.

NAPIM has been vitally concerned with the need to clarify the
definition of VOC which currently varies widely from state to
state.  We are also vitally concerned that the definition of VOC,
and the application of this definition to various types of
printing inks, be reasonable and fair to the printing and
converting industries in the U.S.

DEFINITION OF VOC

NAPIM is especially concerned with the proposed definition of VOC
emission from inks which are applied without the addition of heat
(so called no-heat inks).  These inks encompass newsink and other
no-heat web offset inks; forms inks for commercial business
forms, and sheet-fed ink normally used for high quality color
printing.  While NAPIM acknowledges that the use of the Method 24
oven test condition of 110 degrees C for one hour is appropriate
for determining VOC content of heatset inks which are dried
through the application of heat, we submit that the use of Method
24 is not appropriate to define the VOC content of lithographic
ink which is applied without heat as proposed in the draft CTG.

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We have attached a copy of a report prepared by a task force of
the National Printing Ink Research Institute (a subsidiary of
NAPIM) prepared for Radian Corp. to provide background on
measurement of VOC's for no-heat ink.  The data and information
given in this report show clearly that press temperatures for no-
heat inks do not exceed 40 degrees C and that these inks are
normally on the press for less than 20 minutes.  Therefore,
although the draft CTG applies a retention factor of 95 percent
for no-heat inks, the conditions specified for Method 24 are
fundamentally much too severe for inks which are applied without
heat.

In the draft CTG, Radian Corp. has quite properly proposed a
retention factor of 95 percent for no-heat ink.  In other words,
Radian has acknowledged that at least 95 percent of the VOC in
the applied ink remain in the ink on the substrate or are
absorbed into the substrate.  While this may appear to make
allowance for the excessively rigorous Method 24 procedure, NAPIM
believes that the proposed retention factor is readily subject to
change by the states in the preparation of their SIP's whereas
the method to determine VOC will be fixed by the CTG.

ALTERNATIVE METHOD FOR DETERMINING VOC

NAPIM would like to call attention to an oven test method
proposed by the California Air Resources Board for the Bay Area
Air Quality Management District to determine the VOC content of
no-heat ink.  This is known as Method 30 and will shortly_be
confirmed as an approved test method by ASTM.  Method 30 is
conducted at 40 degrees C for one hour and since press
temperatures do not exceed 40 degrees C, and since ink residence
time on press is less than 20 minutes, Method 30 will predict VOC
for no-heat ink with a comfortable margin of safety.  We urge the
NAPCTA Committee to recommend that EPA adopt Method 30 to measure
VOC content of no-heat lithographic inks.

TYPICAL VOC CONTENT

Under section 2.5.1 on page 2-8 an estimated VOC content for non-
heat set web inks is given as 30 percent.  NAPIM submits that this
reflects a "worse case" scenario since in actual practise ink oil
content in these types of ink is much lower.  Based upon
production figures and VOC determinations for the various types
of non-heatset web inks (black and colored newsinks, regular
offset newsinks, no-rub offset newsinks, forms inks, etc.) the
weighted average VOC is estimated at 10 percent.  In order to
reflect the true average VOC content for these inks, it is urged
that the average be changed from 30 percent to 10 percent.

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SUMMARY -

We ask that the foregoing comments be considered in the
Committee's evaluation of the draft CTG and urge that the
suggested change in the method used to determine VOC's in no-heat
ink be adopted.

We appreciate this opportunity to comment on the draft CTG and
would be pleased to answer any question which the Committee may
have.
                                       a H. Sutphin
                                   Executive Director
/dem
Jordan.jhs
cc: NAPCTA Committee
    NPIRI VOC Task Force

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     REPORT TO RADIAN CORPORATION ON VOC'S FOR NON-HEAT INKS

              FROM NAPIM/NPIRI  TASK FORCE ON VOC'S

                          MAY 29,  1991

                          INTRODUCTION
     The graphic arts industry and, in particular, the printing
ink industry (whom we represent)  are concerned about test methods
being used to control VOC emissions for lithographic inks that
are applied at ambient temperatures without heat.  Because of
this concern, NAPIM under its research affiliate NPIRI, formed an
industry Task Force on VOC so that its dialogue with the EPA and
other regulatory bodies would be based upon an industry consensus
and not on a company by company basis.

     Specifically, the Task Force is concerned about the use of
totally unrealistic conditions such as EPA Reference Method 24
(one hour at 110 degrees C) to determine the VOC emission for
inks such as newsinks, forms inks, and sheetfed inks that are not
heated during application.

     Newsinks, forms inks and sheetfed inks contain light
distillate oils that have minimum initial boiling points of 480
to 540 degrees F, and which are essentially non-volatile under
ambient conditions.  Based upon VOC emissions measured at
production newspaper presses and temperature measurements made
for these same news presses and sheetfed presses, the Task Force
submits that an oven test such as Method 30 (one hour at 40
degrees C) more than adequately measures the emissions that may
be expected from these inks.

                        PRESS  TEMPERATURES

     Newspaper Presses - The American Newspaper Publishers
Associations (ANPA) Reston, VA measured temperatures of newspaper
presses at four operating newspapers in the greater Washington
B.C. area (see Table I).  There was virtually no difference in
temperatures taken in the summer and winter time at the same
presses.  Maximum temperatures varied between 30 and 43 degrees C
for continuous operation.  The maximum temperature of 43 degrees
C was achieved for a Mark II Letterpress which is not used for
lithographic ink.  The average maximum for all presses was 36
degrees C.  It seems clear that an oven emissions test of 40
degrees C for one hour more than adequately covers emissions from
newspaper presses since ink residence time on the press roller
train is estimated as less than 20 minutes.

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                              - 2 -
     Sheetfed Presses  - The NAPIM Task Force determined the
temperatures of five production sheetfed presses covering rates
of 4,000 to 9,000 Impressions Per Hour (IPH).  Data are shown in
Table II.  Maximum temperatures of 100 degrees F or 38 degrees C
occurred at the form roller and the delivery location.  In one
instance, a temperature of 110 degrees F (43 degrees C) was
recorded for a press having an Infra-Red heater at the delivery
point.  As is the case for newspaper presses, an oven emissions
test conducted at 40 degrees C for one hour will measure sheetfed
press emissions more than adequately.  Ink residence time in a
sheetfed 'press is also estimated at less than 20 minutes.

                            TGA TESTS

     In an effort to obtain more precise and more meaningful VOC
data, the NPIRI Task Force contracted with the John Brown
Laboratories, Stirling, N.J., to conduct Thermogravimetric
Analyzer (TGA) tests for magenta quick-set sheetfed ink, and a
black no-rub news (black) ink.  These inks were selected because
they contain the highest concentrations of light distillate oils
of all non-heat lithographic inks.

     The tests were conducted with thin films of ink on aluminum
substrates.  Tests using paper as a substrate showed interference
from water vapor which could not be accurately accounted for.
However, an impervious substrate such as aluminum can be expected
to give higher results because of the lack of absorption forces
that can be expected to be present with paper.

     TGA data for the sheetfed ink are shown in Figures 1, 2, and
3 attached.  The three curves represent heating rates of 0.25,
1.0 and 5.0 degrees C per minute respectively-  Note in each case
that there is no weight loss until a temperature of about 50
degrees C is reached, a temperature which exceeds maximum
temperatures measured for a sheetfed press.

     TGA data for the no rub newsink are shown in Figure 4.  VOC
weight loss at 41 degrees C (which exceeds the maximum average
press temperature by 5 degrees C)  is only 0.5%.

TGA/Oven Data A comparison of TGA and oven test data are shown
below:

                                      VOC, % Loss

                         TGA at 40
Ink                      Degrees C     Method 30    Method 24

Sheetfed                     0            1.8          14.8

No-Rub News                0.5            1.7          24.3

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                              - 3 -
     The above results show good agreement between TGA results, a
precise measuring instrument, and Method 30 oven data.  Method 24
data are considerably higher because of its unrealistically
higher temperature (110 degrees C).


                          EMISSION TESTS

     In addition to determining press temperatures, the ANPA also
measured VOC emissions around these same four newspaper presses
during actual production runs.  Data are shown in Table III.  The
maximum concentration determined was 68.3 mg/M .  Inspection of
the GC trace revealed a high concentration of Cg and C-j^
hydrocarbons which undoubtedly came from wash solvent used on the
press.  When inks obtained from the various press runs were
analyzed using an OHSA approved device to collect VOC's, the high
proportion of Cg and C-^ compounds were no longer observed.

     To study emissions under more carefully controlled
conditions, ANPA conducted tests at its press facilities using
inks supplied by NPIRI Task Force members having three different
VOC contents.  Emissions data are shown in Table IV.  Emissions
during the controlled runs were about one-tenth of those measured
during production runs.  During the controlled runs a concerted
effort was made to minimize the effect of wash solvents, which
contributed to the lower emissions observed.  Since emission were
all low, it was difficult to find significant differences among
the various inks.  The low rub and no rub inks, which would be
expected to have higher emissions, did have slightly higher
emissions as a class, than the regular black ink.  However, all
inks were very low in emissions generated.
/dem
radian.jtd

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                                              TABLI5  I
                                                                             Winter

                                                                                     Blanket Cylinde
Circulation     Press Type      Min  Max  High      Min  Max  High     Min Max High        M.JIL

Press Type
i
Urbanite
Metro
TKS
Mark II*
Summer
Form Roller Blanket Cylinder Form Nolle
Min Max High Min Max High Min Max Hl<
24 31 36 n/a n/a n/a 25 30 30
28 34 39 37 36 42 28 34 42
28 32 38 29 36 40 25 36 36
32 43 43 n/a n/a n/a 33 38 44
 37,000         Urbanite        24   31   36        n/a n/a n/a      25  30  30         n/a n/a  n/a

375,000         Metro           28   34   39        37   36  42        28  34  42        ' 29  37   4J

717,000         TKS             28   32   38        29   36  40        25  36  36         28  40   40

717,000         Mark  II*        32   43   43        n/a n/a n/a      33  38  44         n/a n/a  n/a


Min = Minimum Observed  Running  Temperature
Max s Maximum Observed  Running  Temperatuare
High = Highest  Temperature  Observed After  pressn Was Stopped
* Letterpress

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                             TABLE JI                                    -Inly. I Ort!.


                    sTPign PRESS TEMPISHATURKS


RRESS                 MIEIIM:, <1C    MIEIII.E, 4C    MlElll.lt. 4C    HARRIS. 6C   KOMORI 6C
                         16"          31"          .||"          25"          .,n" '


SPEED, IPH

ROOM TEMPERATURE. "F

INK FOUNTAIN, °F

WATER FOUNTAIN, °F

INK TRAIN ROLLERS, °F

FORM ROLLER, "F

PRINTING PLATE, °F

DELIVERY




IRUN1T                    NO         vns         vns          MO          Yns


RAYTGK RAYNGER IK I'lSTOI. TIII-RMOMI-TI-R. M.ulcl «U-380 - ..su.l lo ol.lain ..hovc ,|.,|.,.
>MOO
70 (26°C)
8f) (31°C)
M
90 (32'C)
100 (38°c)
HII
90
7800
90
90
50
90
90
H8
100
5300
88
90
50
90
100
90
90
•II MX)
711
80
55
90
SO
.SI)
75
9IXV)
70
100
_.
98
9H
85
110

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                          TABLE III
            VOLATILE EMISSIONS FOR FOUR NEWSPAPERS
                 DURING PRODUCTION OPERATIONS
Circulation

37,000

37,000

375,000

717,000

717,000

717,000

717,000

*Letterpress
                        Press Type

                       Goss Urbanite



                        Goss Metro
                                           Emission,
                        TKS

                        Goss,  Mark II*

                       Primarily  Cg - C

                           TABLE IV

VOLATILE EMISSIONS DURING CONTROLLED PRODUCTION RUN-^- (mq/M^)
                                           52.6

                                           43.0

                                           68.3

                                           42.8

                                           40.5

                                           19.8

                                           25.8

                                         hydrocarbons
Sample
Location
Right Ink
Form Roller
Left Ink
Form Roller
Pipe Roller
Regular
Black
3.1

3.7
0.6
Ink Type
Low Rub
Black
5.0

5.2
5.7
No Rub
Black
2.6

3.2
1.1
'
  Limited wash solvent

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                             TABLE V
                      VAPOR PRESSURE, mm Eg
                         Rule 66        L.D.O.
Temp.  F ( C)            Min. Sp.       540 IBP

  68 (20)                  5.6           0.01
 100 (38)                 12.5           0.03
 150 (66)                 37.0           0.18
 250 (121)                 200           3.0
 350 (177)                 740           26.0
Distillation
Range  F

    IBP                    320           538
    50%                    350           554
    FBP                    380           599

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                                                  .gure  1
                                     TGA Test Quick Set  Sheet Fed Ink
   2.5-
   2.3-
    2.1-
O>
6
•H
(U
*   1.9-
    1.7H
     1.5-
                        50
100             150
 Jemperature  (°C)
200
250

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                                                  Figure 2


                                     TGA Test Quick  Set Sheet  Fed  Ink
    3.B-
    3.6H
en
en
•i-t
QJ
    3.2H
    2.BH
    2.6H
    2.4
                                                    )
                        r
                       50
                                       100


                                       :, Temperature  (°C)
150
                        **?
                                2UO

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                                            Figure  3


                                TGA Test  Quick  Set  Sheet Fed Ink
    2.On
o»
e
r.
01
rH
cu
    l.BH
    1.2-f-
 r
50
100

^Temperature
                                                          T -

                                                        150
                                                 200
                                                      (°C)
                                                                                         250

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    1.2-
    1.0-
    O.B-
01

E
r\


OJ
    0.6-
     0.4-
     0.2
                  I •
                    .'25
r /
I- /
                                               Figure  4



                                       TGA Test No  Rub News Ink
                            -, I A rrrv < v^
                            -    '
                                                                      j c /o   
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                        WOOD FURNITURE COATING CTG
                      STATUS REPORT TO THE COMMITTEE
                        ON REGULATORY DEVELOPMENT
      Seven presentations were made to the Committee concerning the wood furniture coating
CTG: one by EPA, four by coating and equipment  manufacturers, and  two by  industry
representatives.   The key points  of each presentation and the discussions that followed are
summarized below, accompanied by the handouts prepared by the presenters.

1.    EPA PRESENTATION

      The EPA presentation was made by:

                                Ms. Mary-Jo Caldwell
                              Midwest Research Institute

      Ms. Caldwell summarized the status of the wood furniture coating CTG project. A copy
of the presentation is attached.

      A total of eight SIC codes, covering five industry segments,  were considered in the
analysis.    The  five  industry segments   considered  included  residential wood  furniture
manufacturers, cabinet manufacturers, office furniture manufacturers, institutional furniture
manufacturers, and store fixture manufacturers. These  five industry segments are referred to
as "the wood  furniture industry".

      Based on Census of Manufacturers' data, approximately 11,000 facilities fall into the five
industry segments just mentioned.  The majority of the industry is  made  up  of  residential
furniture and cabinet manufacturers, each of which constitute  about 35 percent of the industry.
More than 90 percent of the 11,000 facilities are considered small, that is, have less than 100
employees.
      It is interesting to note, however, that although large facilities, (i.e., those with more
than 250 employees), constitute  only  three percent of the total number  of facilities, they
contribute  about one-third  of  the total VOC  emissions.   The wood furniture industry VOC
emissions are distributed approximately equally among the three sizes of facilities.  The wood
furniture industry is one of the largest uncontrolled stationary VOC sources.

      Residential furniture manufacturers generally assemble their pieces and then finish them.
-------
The remainder of the industry also does some prefinishing of unassembled pieces. Coatings are
usually spray applied. The residential furniture manufacturing industry generally uses manual
spraying, whereas the rest of the industry uses both manual and automatic spraying.  Flatline
coating methods such as curtain coating and rollcoating are not presently used extensively by this
industry.

      The finishing process may be a single or multi-step operation.   The coating  may be
manually or automatically spray applied in the spray booth. The piece then leaves the booth,
and may be wiped  before  entering  the flash area, where the faster  solvents are  allowed to
evaporate.  The piece may  then enter an oven, and after cooling, may be sanded, after which
subsequent coatings may be applied.

      The coatings presently  used by this industry  are  primarily solventborne coatings.
Residential furniture manufacturers generally use nitrocellulose lacquers,  which cure by solvent
evaporation. The remainder of the industry uses urea-formaldehyde and melamine-formaldehyde
acid-catalyzed coatings, as well as nitrocellulose lacquers.

      Based on information obtained from  wood furniture manufacturers, EPA estimated that
about 94 percent of the total VOC emissions result from finishing operations, with the remaining
6 percent being attributable to cleanup operations. Volatile organic compound emissions in the
finishing operation occur as a result of solvent evaporation in the spray booths, flash areas, and
ovens.  Cleanup VOC emissions result primarily from  application equipment cleanup, which
usually  occurs  in the spray booth.   Additional  cleanup  VOC emissions result from repair
operations, which also usually occur in the spray booth,  and miscellaneous cleanup operations,
which occur throughout the finishing area.

      In  order to evaluate potential control strategies, EPA had to develop model plants to
represent the wood furniture industry as a whole. The industry was broken down into two main
groups:  residential furniture manufacturers  and other.  Included in the  "other" category are
cabinet  manufacturers, office and  institutional  furniture manufacturers, and  store fixture
manufacturers.  This category is referred to as "office/cabinet", though institutional furniture and
store  fixture manufacturers are also  included in this category.

      The residential furniture manufacturing segment was further broken down into short and
long finishing sequence, and then by size. The majority of the office/cabinet segment  uses the
same finishing sequence, but this segment was broken down by manual and automatic spraying,
(since both application methods are used by this segment  of the industry),  and then by size.  Due
to the capital investment required for an automatic spray  application system, it was assumed that
small facilities would not use automatic spraying.

      For purposes of the analysis,  the size of the model plants was based on total annual VOC
emissions.  Total VOC emissions  of 50 tons per year (ton/yr) corresponds to the small model
plant, 225 ton/yr corresponds to the medium model plant, and 500 ton/yr corresponds to the
large  model plant.

      In  order to evaluate lower-VOC coating alternatives, finishing  sequences had  to be


                                       842
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developed for each of the model plants just discussed. The finishing sequences described during
the presentation are intended to represent typical finishing sequences.  Actual finishing sequences
may, and probably will, differ from those shown.

       The office/cabinet industry uses a finishing sequence that consists basically of application
of stain, sealer,  and topcoat.   Residential furniture manufacturers  using  a short finishing
sequence use essentially the same sequence, except they also apply washcoat  after stain, before
sealer.  Residential  furniture manufacturers using a long  finishing  sequence use the same
coatings as manufacturers using a short sequence, but the coatings are applied more frequently,
and additional coatings, including filler, wiping stain,  and highlight, may also be used.

       The relative VOC emissions from each of the finishing steps was presented.  Topcoat
application contributes from 35 to 40  percent of the total finishing VOC emissions.  Stain and
sealer both constitute about 25 to 30 percent of the total finishing VOC emissions.

       A  variety of factors were considered  in evaluating control methods, including:  the
control techniques available, the types of coatings and finishing sequence used, total VOC
emissions and the concentration of VOC's in the exhaust stream, the number and types of VOC's
present in the exhaust, and the total exhaust flowrate to  be  controlled.

       Based  on the evaluation of the applicability of various control methods,  two primary
control alternatives  were  considered for the finishing process.   The  control alternatives
considered included lower-VOC coatings,  add-on controls,  and a combination of  the  two
methods.  Though these control methods have limited use in this industry, they are not presently
widely  used in the wood furniture coating industry.

       The lower-VOC  coatings evaluated  include waterborne,  polyester,  and polyurethane
coatings.  The add-on controls evaluated include recuperative thermal incineration, regenerative
thermal incineration,  catalytic  incineration, and  combined adsorption/thermal  incineration.
Because the capital and operating costs of add-on controls  are a function of  the  flowrate
controlled,  add-on control vendors  indicated that exhaust  flow  reduction  is  an  essential
consideration when evaluating add-on  controls. Therefore, two exhaust flow reduction methods
were evaluated. These include spray booth recirculation, which involves recirculating a portion
of the spray booth exhaust back into the spray booth, and the air curtain system.  The air curtain
system uses an air curtain to separate  the worker from the VOC emissions.  The worker stands
outside the booth and  reaches through the air curtain to spray apply the coating  to the piece.
Since the worker is not inside the booth,  VOC levels do not have to be maintained below the
permissible exposure limit, and therefore, high exhaust flows are not required and thus, the
spray booth exhaust is significantly less than that of a comparable manual spray booth.

       Three  primary  control alternatives were considered for cleanup operations, including
work practice modifications, reformulation of cleanup materials, and the use of add-on  controls.
Work practice modifications may include the use of enclosed spray  gun cleaners  and  closed
containers for the  storage of  saturated  rags.   Cleanup material reformulation  may include
reformulating with lower-volatility solvents, or may involve the use of aqueous-based  cleaners.
The same add-on controls just described for finishing operations may also be used to control


                                        843
-------
 VOC emissions resulting from cleanup operations.

       The control alternatives  were evaluated for each model plant, then permutations of
 different controls being applied to different model plants were developed to form RACT options.
 Under a single RACT option, the same controls may not necessarily be applied to all model
 plants.  Therefore, the RACT option descriptors do not necessarily indicate the control strategy
 being applied to all model plants.

       A total of nine RACT options were developed.  Options 1 through 4 involve the use of
 lower-VOC coatings; RACT Options 6 through 9 involve the use of add-on controls; and RACT
 Option 5  involves the use of lower-VOC coatings in conjunction with add-on controls.

       RACT Option 1 is described as full waterborne.  Under this RACT option, office/cabinet
 manufacturers and residential furniture manufacturers using a short finishing sequence use full
 waterborne coating  systems which involve waterborne coatings  for each  of  the coating
 application steps.  The  majority of the  coating  suppliers and wood furniture manufacturers
 contacted indicated that full waterborne coating systems are not presently suitable for residential
 furniture  manufacturers using a long finishing  sequence.  Therefore, under RACT option 1,
 residential furniture manufacturers using a long finishing sequence were assumed to use hybrid
 waterborne coating systems.

       RACT Option 2 is described as hybrid waterborne. Under this RACT option, all plants
 use a hybrid waterborne  coating system consisting of waterborne sealer, topcoat, and highlight
 (as applicable), with conventional solventborne  coatings for the remaining coating steps.

       RACT Option 3 is described as poly ester/poly urethane.  Based on conversations with
 coating suppliers and  wood furniture manufacturers, it was assumed that a dust-free environment
 is required when applying polyester/polyurethane coatings, due to the difficulty in repairing these
 coatings.  Because of the capital investment required for a dust-free environment, it was assumed
 that  small facilities (that   is,  those with less than  100  employees)  would  not apply
 polyester/polyurethane coatings.  Therefore, under RACT option 3, it was assumed that small
 facilities would use hybrid waterborne coating systems, and all medium and large facilities use
 polyester/polyurethane sealer, topcoat, and filler (as applicable) in conjunction with conventional
 solventborne coatings for the remaining coating steps.

       RACT Option 4 is described as polyester/polyurethane with waterborne coatings. RACT
 option 4 is essentially the same as RACT option 3 except that office/cabinet manufacturers and
 residential furniture manufacturers using a short finishing sequence also use waterborne stain and
 washcoat, and residential furniture manufacturers using a long finishing sequence use waterborne
"highlight.

       RACT Option 5 is described  as hybrid waterborne in conjunction with add-on controls
 being used to  control VOC emissions from selected coating steps. Under this RACT option, all
 facilities use hybrid waterborne coating systems.  Due to the capital investment required for add-
 on controls, it was assumed that add-on controls are not used by facilities with less than 50
 employees. Thus, under RACT Option 5, at all facilities with more than  50 employees, it was


                                        844
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assumed that in addition to using hybrid waterborne coating systems, add-on controls are used
to control VOC emissions from stain and washcoat operations.

      RACT  Options  6  through  9 are different  combinations of the four add-on controls
previously discussed being used to control VOC emissions from all coating steps.  Again,
because of the capital investment required,  it was assumed that facilities with less than 50
employees do not use add-on controls.  Because exhaust flow reduction can significantly affect
the capital and operating costs associated with add-on controls, each of the four add-on RACT
options considered the use of add-on controls with and without spray booth recirculation and the
air curtain system.

       The emission reduction and cost associated with applying each of the nine RACT options
previously described to all wood furniture facilities located in ozone nonattainment areas were
evaluated.  The nationwide emission reduction; the nationwide control cost; and the associated
cost effectiveness, that is, the dollars per megagram of VOC emissions reduced, were presented.
For example, RACT Option 1 is described as full waterborne. If this RACT option is applied
to all wood furniture facilities located in ozone nonattainment areas, nationwide VOC emissions
would decrease by almost 95,000 megagrams per year, which represents a 72 percent reduction
over uncontrolled nationwide emissions.  The associated annualized cost to industry would be
about $229,000,000, with a corresponding cost effectiveness of about $2,400 per megagram of
VOC emissions reduced.

       EPA PRESENTATION DISCUSSION

       Following the EPA presentation, Mr. Brian  Taranto of the NAPCTAC asked if the
impact in  the EPA presentation represented just nonattainment areas.  Ms. Mary-Jo Caldwell
responded that this was the case.  Mr.  Taranto then inquired about what percentage of the
emissions  from the wood furniture coating industry are in nonattainment areas.  The project staff
were unable to provide that information and promised to provide it to Mr. Taranto at a later
time. (Mr. Taranto was later told that based on EPA's estimate of nationwide  VOC emissions
for the wood furniture industry, approximately one-third of the total wood furniture coating VOC
emissions  occur in non-attainment areas).

       Ms. Vivian Mclntire noted that  "small"  appeared  to be defined several different ways
throughout the presentation,  as  50 tons/year  of  VOC, 50 employees,  and less than 100
employees.  Ms.  Caldwell explained that the use of less than  100 employees was the Census of
Manufacturers definition.  Because this encompasses most of the industry, the EPA analysis had
to further subcategorize the plants to conduct a meaningful analysis.  The subcategories were
0-35, 36-50, and 51-100 employees.

       Ms. Deborah Sheiman asked for the basis of the decision that some control alternatives
are too expensive for plants employing 50 people or less.  Ms. Karen Catlett of EPA stated that
the cost effectiveness values (dollars per ton of VOC emissions reduced) were much higher for
facilities with less than  50  employees.  For  plants with  at least 50  employees, the cost
effectiveness values range from $500 to 8,000/ton, while for plants with less than 50 employees
the cost effectiveness values ranged from $6,000 to 9,600/ton. Mr. Jordan elaborated that it was


                                       845
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staff judgment that  the costs  are too high.   Ms.  Sheiman  then suggested that  the  line
distinguishing between cost effective and ineffective control may have been drawn in the wrong
place, that some of the plants with less than 50 employees may be able to afford add-on controls.
Ms. Catlett responded that EPA will look into this issue further.

       Mr. John  Pinkerton asked  if this industry is largely uncontrolled, which Ms. Catlett
confirmed. He then inquired about which MACT list the wood furniture coating industry is on
and what the  "best of the best" control is likely to be. Ms. Susan Wyatt replied that it is on the
4-year list. Ms.  Catlett further responded that there are very few controls being used by  this
industry and  that the MACT level of control has not been determined  yet.  Mr. Pinkerton
concluded with the recommendation that the CTG and NESHAP efforts be closely coordinated,
so that the industry is not affected twice by different levels of control.  Ms. Wyatt assured Mr.
Pinkerton that EPA is aware of this possibility, which is the reason the wood furniture coating
industry is on the 4-year list. Ms. Wyatt explained that in this way, the CTG and NESHAP can
be considered together,  and industry will have knowledge of both sets of requirements before
instituting a VOC control strategy.

       Mr. Donald Arkell noted that at this time,  the  MACT floor would appear to be no
control, because most of the industry is uncontrolled.  He asked if the implementation of the
CTG would have the effect of raising the MACT  floor for the NESHAP.  Ms. Wyatt stated  that
the CTG and  the NESHAP are on the same schedule, so the CTG will not be imposed first,  and
thus will not  represent baseline for MACT.  Mr.  Arkell further inquired how MACT would be
determined, if the floor is uncontrolled.  Ms.  Wyatt explained that  EPA  can evaluate control
options more stringent than the MACT floor.  Mr. Jordan  explained that  the MACT floor for
an uncontrolled industry is equal to the minimum control allowed by the  Clean Air Act.  The
EPA is required to set MACT as the maximum  achievable control level.  Mr. Berry of EPA
indicated that since the industry is presently uncontrolled, MACT can be  set at any level after
looking at the impacts of various options.

       Mr. Taranto asked if all of the RACT options are  equally  technically feasible.  Ms.
Catlett said that EPA believes  they are all technically feasible, and that this was one of the
reasons for analyzing the costs for  all of the RACT options.  Mr.  Jordan then  noted  that
technical feasibility means that it can be accomplished; however, it  does not necessarily mean
that performance  won't be affected.

       Ms. Mclntire then inquired if waterborne coatings provide acceptable quality finishes.
Mr. Berry stated  that the wood furniture coating industry has traditionally used nitrocellulose
coatings because the finishes are ideal for the industry because they are easy to repair and have
a high gloss.  According to Mr. Berry, under the current system, consumers do not have a voice
in the marketing decisions.   Mr. Berry said  that it  is  uncertain whether consumers  can
distinguish  between the gloss levels  associated with different finishes, and they would likely
prefer the durability of lower-VOC coatings.   Mr. Berry said that there is a tradeoff between
the workability of the coatings in the plant and the long term performance  of the coatings in the
home.

       Mr. William O'Sullivan noted that many state and local agencies define 25 tons/year as


                                       846
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a "major" source and recommended that EPA conduct an analysis on this basis as well as the
50 tons/year analysis already performed. Mr. O'Sullivan then suggested performing an analysis
of the cost for add-on controls being used to control only the coating steps that emit the majority
of the VOC (topcoat, sealer, stain), rather than for all coatings; this might help to improve the
cost effectiveness values. Ms. Caldwell of MRI noted that, in the EPA analysis, the 50-employee
category was equivalent to about 35 tons/year, close to the value that Mr. O'Sullivan suggested.
Ms. Sheiman interjected that it might be more reasonable  to define cutoffs  on  the basis of
emissions rather than employees.    Ms.  Caldwell went on to explain  that, for nationwide
impacts, it was necessary to use number of employees to classify the plants because that is how
the Census of Manufacturers information is organized.

       Mr. William Dennison emphasized the need for EPA to analyze cleaning emissions (both
spray gun cleaning and housekeeping), which are potentially a large source of VOC emissions.
Mr. Dennison indicated that in his experience in California, spray gun cleaning was a large area
of contention. The EPA staff responded that cleanup emissions will be addressed.

       Mr. Patrick Atkins wondered if EPA had investigated technologies used overseas. Ms.
Caldwell replied that they had looked  at European technologies such as polyester/polyurethane
coatings which  are  used  more  extensively overseas.  However,  furniture is manufactured
significantly differently in Europe,  with the pieces being flatter and more uniform, which lends
the process to some alternative controls.

       Ms.   Sheiman  inquired   about  public  health  issues  related   to  the   use  of
polyester/polyurethane coatings. Mr.  Jordan said that he believed EPA had looked into it and
that there were no risks.  Mr. Jordan stated that he would try to provide details at a later time.

       This concluded the questions from  the NAPCTAC members.  Questions were asked by
a member of the audience.  Mr.  Gerry Currier of Reliance asked if air recirculation and  air
curtains are  commercially available and, if so, where  they  can be obtained.   Ms.  Catlett
responded that air recirculation  is used in  other spray coating industries and to some extent in
furniture coating. Air curtain spray booths are under development and are currently being tested
on a  pilot line.  Ms. Catlett further  explained that  air curtains have been successfully used
commercially on other types of equipment, such as ovens, to contain VOC emissions.

       Mr.  Currier  asked  for  clarification  of Chapter 5 of the CTG document, which he
interpreted as utilizing a permanent a total enclosure incorporating the entire finishing room, not
the individual emission sources.  Ms.  Catlett replied  that he was correct.  The questioner then
asked if any such  enclosures are in use in the wood furniture coating industry.  Ms. Catlett
responded that the industry is largely uncontrolled and, therefore, there is no reason for facilities
to have total enclosures in place since they would merely exhaust to the atmosphere.
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2.    UNICARBR SYSTEM PRESENTATION

      The UNICARBR presentation was made by:

                                     Thayer West
                         Market Manager - UNICARBR System
                                    Union Carbide

      Mr. Thayer presented  a brief description  of how the UNICARBR System works, its
applications, and the VOC emissions reductions achieved (see attached handouts).  The system
substitutes CO2 for conventional solvents in coatings.  This substitution lowers the total VOC
content of the coatings. The CO2 primarily replaces the "fast" solvents and often replaces HAP
solvents. This system offers the additional benefit of often allowing the use of the same resins
currently in use. The coatings used by this system have a high solids content and can be applied
manually or automatically using electrostatic or nonelectrostatic and airless or air-assisted airless
methods.

      The UNICARBR System is currently available for nitrocellulose topcoats and sealers,
pigmented lacquers and enamels, and single component acrylics, polyesters, and urethanes.  A
two-component system is under development and may be available in 1992.

      The VOC reduction achieved by this system varies with the type of coating and final
product and ranges from about 40 to 75 percent.  When looking only at the HAP solvents used
in coatings, reduction of 50 to 85 percent may be achieved.

      The UNICARBR System is  operating commercially at Pennsylvania House, applying
topcoats to chairs. About a 70 percent reduction in VOC emissions from topcoat application has
been achieved, and the plant is achieving more coverage with the same volume of coatings.  A
demonstration system was used at Lehigh,  Marianna that reduced the  number of sealer coats
from four to two by achieving better film builds.  In-plant trials are being conducted at other
furniture manufacturers  and in other industries.  In Japan, the UNICARBR System is being
considered for its performance characteristics,  such as fine particle size and good appearance.

      According to Union Carbide, this system provides numerous advantages, as outlined in
the handouts. It is easy to retrofit because it can be installed at a rate of one line or spray booth
at a time.  Because the faster solvents are replaced with CO2, the majority of the VOC emissions
occur later in the finishing sequence, in the oven.  By moving the solvent emissions from the
booth to the oven, the UNICARBR System makes it easier to control emissions. Finally, Union
Carbide believes that this system has a relatively low investment cost.   It was not included in
EPA's analysis of RACT, and Union Carbide is willing to provide cost information to EPA.

      UNICARBR PRESENTATION DISCUSSION

      Mr. William Dennison asked if there are any size limitations to the technology or any
practical limitations due to cost.  Mr. West stated that it depends on the number of coating steps,
but he believes there  would be economic paybacks even for the plants emitting less than 50


                                      840
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tons/year.  Mr. West indicated that they are working on making the system more affordable,
such as leasing arrangements.  Mr. Dennison inquired about the training requirements for the
equipment, in light of the high employee turnover typical at furniture plants. Mr. West stated
that the training required is minor.  Mr. Dennison also asked if the gun cleaning requirements
for the UNICARBR System are the same as for other guns; Mr.  West said that they are similar
to the cleaning requirements for airless guns.

      Mr. Ralph  Hise asked a series of  questions regarding how  the  CO2  and  paint are
combined and whether the vessel the coating is stored in is pressurized, and questioned the safety
of the highly pressurized system. Mr. West explained that the paint is not under pressure until
after it enters the spray equipment. The liquid CO2 (at 1,100 psi  and 88°F) is fed from standard
gas  cylinders  into  the  spray equipment.   Simultaneously, the paint is pumped  into the
UNICARBR spray apparatus and mixed with the CO2 at pressure.

      Ms. Mclntire inquired whether the UNICARBR System could be considered reasonably
available at this time, even though it seems there is still quite a bit of trial testing ongoing, and
two-component coatings are not expected to  be available until 1992.  Mr. West stated that it is
currently available for nitrocellulose topcoat and sealer and has been used at Pennsylvania House
for about one year. Mr.  West said that Union Carbide has been working on the UNICARBR
System for 4 to 5 years.

      Mr. Atkins noted that Pennsylvania House  apparently achieves  an increased transfer
efficiency with this equipment and asked if Mr.  West could explain why. Mr. West responded
that it was unclear why there is increased transfer  efficiency, it may be due to more careful
handling by the person  doing the coating or it may be inherent to the technology.

      Mr. Ralph Hise asked if the UNICARBR System paint is more viscous than conventional
paints when it hits  the part.  Mr. West replied that it is  more viscous.

3.    CLASSIC SYSTEMS. INC. PRESENTATION

      The presentation on the Classic Systems, Inc., technology was made by:

                                 Mr. David  Brookman
                                 Classic  Systems, Inc.
                                   Statesville, N.C.

      Mr. Brookman provided a description of the Classic Systems  CamBoothR, which is a
spray booth using low velocity air curtains to isolate the worker from the spray  emissions (see
attached handouts).  Traditional spray booths have an open front, so that  VOC's and overspray
are lost. To ensure worker exposure safety, high volumes of air are exhausted from the booth.
The volume of makeup air  to the booth is usually inadequate, resulting in a negative pressure
within the booth. This pressure differential results in (1) dust entering the booth and degrading
product quality and (2) a cold and drafty work place. There is also a high cost associated with
moving and heating the high volumes of air.
                                      849
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       The goal of the CamBoothR design is to minimize the air volumes being handled, thus
decreasing costs.  Attached to the CamBoothR is an enclosed flash tunnel. There are air curtains
at the entrance of the spray booth, the exit of the flash tunnel, and the entrance and exit of the
oven. These curtains prevent VOC emissions from escaping from these areas during the coating
operation.  These air curtains use recirculated air. The open side of the CamBoothR where the
workers stand, also has an air curtain of fresh filtered air (no recirculation) delivered at a rate
of about 600 feet/minute. The air curtains located in between the worker and the piece are kept
at a relatively low speed to reduce  worker arm fatigue.  It is also possible to add a heating
element to the air curtains near the worker in the winter, if desired.

       The CamboothR design uses a cascading air system, with exhaust from the oven supplying
the  flash tunnel and tunnel exhaust venting to the CamBoothR.   Within the CamBoothR, the air
is added  from the top of the booth at 50 feet/minute and withdrawn from vents at the bottom.
Mr. Brookman  speculated  that  this uniform,  low-velocity downdraft  may  help to  increase
transfer efficiency. The exhaust from the  CamBoothR can then be directed to an add-on control,
such as an incinerator. The exhaust from multiple CamBoothsR can be combined and directed
to a single add-on control device.

       Studies have been performed  by Classic Systems demonstrating that overspray deflecting
off a piece  towards  the worker is  contained by the curtain.   Mr.  Brookman's presentation
included pictures of studies in which smoke was introduced into the CamBoothR and the exhaust
system removed the smoke before it appeared outside the booth.

       Mr.  Brookman presented estimated  operating costs  (electricity, heating,  fuel,  and
incinerator)  for  a typical  spray  booth using 120,000 cubic feet per minute (ftVmin) and a
CamBoothR using 21,000 ft3/min. The total operating costs were about $992,000 for the typical
spray booth and about $145,000 for the CamBoothR.  The largest individual difference was in
the fuel cost for the incinerator.

       CLASSIC SYSTEMS PRESENTATION DISCUSSION

       There were no questions following the Classic Systems presentation.

4.     GRACO. INC. PRESENTATION

       The Graco presentation on transfer efficiency was made by:

                                    Mr. Steve Kish
                             Market Development  Manager
                                       Graco, Inc.

       Mr. Kish presented the results of a study of the transfer efficiencies of different types of
spray guns  (see attached handout). Most of the presentation is included in the handout and will
not be repeated here.

       Mr. Kish agrees with EPA that there are many factors influencing the transfer efficiency


                                       850
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of a coating system.  The primary factor is operator spray technique (e.g., gun setup, proper
gun position,  proper spray speed, fan pattern adjustment,  cleaning).   However,  operator
technique cannot be controlled.  Therefore, Graco focused their study on the transfer efficiency
of just the application tool (i.e., the spray gun) rather than the entire system.  They tested six
spray  guns under controlled conditions and achieved transfer efficiencies ranging from 30 to 75
percent.  Only the electrostatic  methods achieved transfer efficiencies over 50 percent.  They
feel that the standard target used in this study is typical of what is coated by their customers.

       While admittedly looking at only part of a complex system, Mr. Kish believes that studies
of relative transfer efficiencies of spray guns can provide valuable information. More efficient
application tools will reduce the amount of paint used to finish a part, thus reducing the VOC
emissions.

       GRACO  INC. PRESENTATION DISCUSSION

       Mr. Taranto asked if Mr. Kish agreed with EPA's decision not to numerically define and
include transfer efficiency in the CTG. Mr. Kish stated that if you are looking at the transfer
efficiency of the total system, as EPA  does, then he agrees that it cannot be  quantified.
However, it is possible to look at the transfer efficiency of the application tool (i.e.,  the gun)
alone, as his presentation demonstrated.  Mr.  Dennison noted that if you isolate and evaluate
each  of  the parameters,  you  are not looking at reality, and Mr.  Kish agreed with this
observation.

5.     ENSR PRESENTATION

       The industry-sponsored presentation on the technical aspects of the study being conducted
by the industry group was made by:

                                  Mr. Robert Mclnnes
                            ENSR Consulting and Engineering

       Four trade associations for industries affected by the wood furniture coating CTG formed
a Joint Industries Steering Committee, which sponsored two studies of the cost and economic
impact of possible emission control scenarios.   The goal of the Committee and the  studies are
to assist  in developing  a CTG  that  is  environmentally protective,  technically  feasible,
economically justifiable, and does not restrict the industry.  The study is  not final yet, but will
be completed shortly.  The information in the attached handouts from the presentation will not
be reproduced here.   Instead, this discussion will present clarifying and additional statements
made by Mr. Mclnnes.

       The wood furniture industry is essentially a "fashion" industry,  in  that  it responds to
consumer demands.  In addition, wood is not a uniform substrate, such as metals. Both of these
factors increase the complexity of the manufacturing process and the analysis. A detailed survey
of 160 facilities and site visits  to  24  facilities  were performed, to  develop model plants and
determine the technical feasibility and economic impact of possible control options.
                                      851
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       Technical limitations of many control options that were noted include:

       1.     Wood is sensitive to heat and water.  Therefore,  control technologies cannot
             simply include changes to waterborne coatings and changes in oven temperature.

       2.     Full waterborne coatings are not in use for the "long-sequence" segment of the
             industry and are not available for some types of coatings.  In addition, there are
             quality problems.

       3.     Current coatings and colors have been developed over years of trial and error,
             developed  specifically for each plant and customer by onsite testing.   These
             coatings cannot be changed over night.  Customers  must be provided consistent
             quality. There may also be OSHA and insurance questions regarding the use of
             this technology.

       4.     Air  recirculation is used only in a  very small  number  of plants and is not
             applicable  to all industry segments.   There  may also be  OSHA and insurance
             questions regarding the use of this technology.

       5.     Air curtain systems are not commercially available.

       6.     The UNICARBR System is  not commercially available  for  all coatings, has
             technical problems delivering sufficient coating volumes, and requires longer
             drying times.

       7.     Mobile zone spray  booths and Terr-Aqua  UV/AO  oxidation are developing
             technologies that are not commercially available.

       Twelve model plants were developed to characterize the industry.  Ten parameters were
used to define  each model plant (see  handouts).   The cost  effectiveness of sixteen  control
technologies  were evaluated,  including add-on controls, different application  methods, and
reformulation of coatings (see handouts).  Mr. Mclnnes outlined problems with each of these
categories of control technologies (see handouts).  The cost analysis was performed for different
numbers of ovens and booths, which significantly affects  the cost effectiveness values.   The
model plants contained from five to fifteen booths per facility.  Capital cost, annual cost, and
cost effectiveness were calculated using OAQPS guidelines.

       The capital costs (per plant average  for the industry as a whole) varied widely for each
control category:  from $400 to $210,000 for spray techniques; from $98,000  to $1,030,000 for
reformulations; and from $163,000 to $1,026,000 per booth for add-on controls (see handouts).
The estimated annual operating costs for each control category ranged from:  a cost savings of
$51,000 to expenditures of $470,000  for  spray  techniques; a cost savings of $163,000 to
expenditures  of $1,222,000 for reformulations; and expenditure of from $68,000 to $321,000
per booth for add-on controls  (see handouts).  The cost savings occurred for only one of the
twelve model plants. The average annual operating cost for the remaining eleven model plants
was over $200,000.


                                      852
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      The VOC emissions reductions achieved for the industry varied widely for each control
alternative, from 2 to 33 percent for improved  spray techniques, 28 to 80 percent for coating
reformulations, and 3 to 86 percent for add-on controls (see handouts). The cost effectiveness
values for each control category ranged from:  a cost savings of $2,100/ton to expenditures of
$9,400/ton for spray techniques; a cost savings of $500/ton to expenditures of $15,800/ton for
reformulations; and expenditures of $1,300 to $87,300/ton for add-on controls (see handouts).

      Mr. Mclnnes concluded his presentation with a discussion of several industry concerns
other than cost.   First, the industry recommends that the units of the standard not be in terms
of pounds of VOC per gallon of coating minus water.  The trend is towards using water in
coatings, and if water is deleted  from the calculation, there will still be high VOC levels. Use
of this format does not show the actual VOC reductions achieved by using waterborne coatings.
Second, because the wood furniture industry is so technically and economically diverse, there
should be different standards for different industry segments.  Finally, Mr. Mclnnes made the
strong recommendation that, if the CTG includes the use of some of the emerging technologies
(e.g., full waterborne coatings), EPA  needs  to  allow sufficient time  for research and
development of these technologies in the CTG.

6.    NERA PRESENTATION

      The industry-sponsored presentation on economic impacts of the CTG was made by:

                                  Dr. Mark Berkman
                        National Economic Research Associates

      The second study sponsored by the Joint Industries Steering Committee was an evaluation
of the economic impact of possible CTG control options on the wood furniture industry. The
Committee decided to conduct a study of the total industry impacts and to assume that the goal
of EPA is to reduce VOC emissions in nonattainment areas at the lowest possible industry cost.
This summary of the presentation will  not include a repetition  of  the  handouts, which are
attached.  Instead, statements made by Dr. Berkman to clarify and expand on the handouts will
be discussed.

       The study looked at total annual operating costs, plant closures, and employment losses.
These economic  factors  were studied as a  function of  increasing  percent VOC emissions
reduction, from  10 to 80 percent.  Over  this range of VOC control, total annual cost ranged
 from $53 to 543 million (see handout for details).

       The projected plant closures for this range of VOC closures ranged from 930 to 2,539
 (see handouts for details).  However, the economic analysis is not complete, and Dr. Berkman
 stated that the plant closure estimates will likely increase in the final report. The closings will
primarily occur among the smaller facilities.

       The number of jobs lost over the range of VOC reductions was  5,283 to 86,534 (see
 handouts for details). The largest number of job losses represents about 30 percent of the total
employment in this industry. The largest facilities in the wood furniture industry will probably


                                      853
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not close as a result of a CTG but there would be sizeable employment losses.

       Dr. Berkman then presented a discussion of the cost of control to this industry relative
to its VOC emissions.  First, the wood furniture coatings contribute less than 1 percent of the
VOC emissions in the  U.S..  Second, the average cost effectiveness values for the wood
furniture industry is about $3,000/ton.  Dr. Berkman presented the results of a  study by the
Office of Technology Assessment demonstrating that there are numerous other industries with
cost effectiveness values at or below $2,000/ton. This is not to suggest that the wood furniture
industry should not be controlled but rather that it is not a major contributor of VOC emissions
and  should be controlled proportionately to its emissions.
       The study determined that there is a wide range of cost effectiveness values for each
control option for the different model plants. The lowest cost of attaining a 30 percent VOC
reduction ranges from a slight profit to about $15,000/ton for seven of the model plants. For
these reasons, Dr.  Berkman suggested that EPA  consider the cost impacts of the different
segments of the industry separately.

       The  NERA study  also analyzed  the  effect of different  VOC  control  options on
profitability for each of the model plants (see handouts for details).  The cost of VOC control
is difficult to pass along to the customers and, therefore, the CTG would significantly impact
profitability.  The model plants included as part of their initial analysis happened to all be part
of the upper profit quartile.  Therefore, to further analyze the impact of decreased profitability,
they are  adjusting their analysis to include smaller, less profitable model plants.

       The study further analyzed the annual failure rate in  this industry in the absence of any
regulations.   For the period 1986  to  1990, the failure rate of the wood  furniture industry
outstripped the nationwide  failure rate for  all other industries  combined  (see handouts for
details).  In part, this is due to substantial and growing  foreign competition,  which increased
from a value of about $1 billion in  1981 to almost $4 billion in 1990.  The impact  of the CTG
will be to increase the competitive advantage of foreign imports.

       The study also evaluated the impact of the  capital cost of the different levels of VOC
control.  If a plant is able to stay in business following the implementation of the CTG, the cost
of the control will limit the ability to upgrade,  modernize, and  expand the facility.   This
limitation will further decrease the competitiveness of this industry.

       Dr.  Berkman concluded with two  recommendations  to EPA in the development of the
CTG.  First, this industry appears  to be  a  prime candidate for a market-based approach to
regulation.  Second, EPA must review and regulate the industry in the context of its contribution
to total nationwide VOC emissions.

       ENSR/NERA PRESENTATION DISCUSSION

       Mr. Taranto asked if the projections  on plant closures and job losses are for all of the
industry  or only  the facilities in nonattainment areas.   Dr. Berkman replied that the study


                                     854
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assumed all plants will be affected by the CTG. They are continuing their analysis and plan to
analyze the impacts on only those plants in nonattainment areas.  Dr. Berkman hypothesized that
although the closures and job losses may be decreased when only facilities in nonattainment
areas are considered, the decrease may be offset by (1) increased closures in nonattainment areas
because those facilities would be at an economic disadvantage compared to those in attainment
areas and (2) the increased stringency of some of the financial tests NERA plans to utilize.

      Ms. Mclntire asked whether the NERA study had included an analysis of the impact of
the application of MACT to plants emitting over 10 tons/year in attainment areas, to determine
whether facilities in attainment areas would have a cost advantage. Dr.  Berkman  replied that
this has not been explicitly addressed but that their analysis considers to some extent a combined
RACT/MACT.

      Ms. Mclntire asked why, in the NERA analysis, the use of full waterborne coatings and
ultraviolet (UV)-cured coatings does not eliminate VOC emissions. According to Mr. Mclnnes,
these coatings still contain some amount of VOC.  In addition, there is no UV-cured stain.
Therefore, only about 65 to 70 percent VOC emissions reduction is achieved using these coating
technologies.

       Mr. Dennison asked why UV air oxidation was considered an  emerging technology in
the ENSR study when this technology is an  accepted technology in the aerospace industry.  Mr.
Mclnnes responded that he was unaware of its use in the aerospace industry.  Their classification
of UV air oxidation as an  emerging technology  was based on the fact that  it has not been
demonstrated long term in the wood furniture coating industry; it is currently in use in only one
wood furniture facility.

       Mr. Dennison asked  whether the NERA analysis had considered what would happen
regarding  plant closures in the absence of any regulation,  whether this industry is currently
economically viable. According to Dr. Berkman, the NERA analysis addresses this issue in part
because it includes analysis of current economic conditions  and other factors beside the CTG.
Dr. Berkman agreed that the industry has been undergoing contraction and consolidation and that
a number of existing companies are operating in a negative financial status.  However, the
regulations will exacerbate the problems and confirm the closure of currently marginal facilities.
The final report will have benchmark closure projections as well as demonstrate the additional
effect of the CTG on plant closures.

       Mr. Dennison further noted that, while VOC emissions from wood furniture coating may
be a small percentage of the nationwide VOC emissions, the more important factor to consider
is the industry's percent VOC contribution in only nonattainment areas.  Dr. Berkman concurred
that if you look only at nonattainment areas, the percent VOC contribution of this industry may
increase somewhat.  However, Dr. Berkman said  that the cost to this industry may not be
proportional to the level of VOC emission  reduction achieved relative to other industries.  He
also indicated  that  the stringency of a standard should be proportional to its contribution and
economic impact.

       Mr. Pinkerton asked the EPA staff how economic factors will affect the MACT decisions


                                      855
-------
for the NESHAP. Ms. Wyatt responded that an economic analysis will be performed for control
options above the MACT floor and the results will be used in selecting options for MACT.

       Ms. Mclntire asked if the NERA analysis was new to EPA.  Ms. Wyatt stated that EPA
knew an analysis was  being  performed but  had not seen any  of the results prior to the
NAPCTAC presentation.

       Mr. O'Sullivan asked what the current dollar value of U.S. sales is for this industry. Dr.
Berkman responded that their study does not directly have this information but that there were
about $4 million in foreign sales in 1990, which is about 15 percent of total U.S.  sales.

       Mr. O'Sullivan further inquired whether the NERA analysis assumed control of all of the
spray booths at a facility.  Mr. O'Sullivan recommended to EPA that they look  at this type of
incremental analysis to develop cutoffs on what types of control technologies should be required
for each type of facility. Dr. Berkman  explained that the NERA study looked at varying levels
of control at a facility, from 10 percent to over 80 percent. If add-on control was the least cost
option for a particular control level, that was the cost used to calculate cost effectiveness. These
different levels of control could be achieved by incrementally controlling different numbers of
spray booths.  Mr. Berkman said that this will be made clear in the final report.

       Mr. O'Sullivan stated that,  from the NERA study, it looked as if there were some clear
decision points for EPA to control at  about the 25, 50, and 75 percent control levels.  He asked
if industry  had any recommendations.   Dr.  Berkman responded  that they  did not  have
recommendations at  this time.  When the report is final, which should be soon,  the industry
plans to work with EPA to analyze the study results.

       Mr.  O'Sullivan  asked  how it can be  feasible to  get promising control technologies
demonstrated in an industry that is essentially uncontrolled. Mr. McGinnis responded that the
industry is currently  trying to use waterborne coatings on several lines.  The industry is always
looking for better and less expensive technologies.  Mr.  O'Sullivan noted  that the state
implementation plans (SIPs) must have a contingency plan in case the state fails to meet  its
emission reduction goals within a specified time.  If the goals are not met, it  triggers the
requirement for add-on controls. It may be possible to use the "hammer" provisions to provide
incentive to this industry to try new  technologies.  He asked how long it takes to  make a new
technology commercially viable.  Mr. Mclnnes estimated that it takes 2 to 4 years to test and
implement new approaches.

       Mr. O'Sullivan asked what NERA would recommend as a cost effectiveness cutoff. Mr.
Mclnnes declined to make  a recommendation.  He noted that the model plants  reflect a wide
range of cost effectiveness values, and that the total amount of VOC emitted from a spray booth
is the primary cost factor.  Booths are  fairly standard in size, and the speed of production is a
key factor, influencing how much VOC is emitted, and  thus, the associated cost effectiveness
of add-on controls.  Mr. O'Sullivan asked if the NERA report included the incremental cost  for
adding add-on controls to a spray booth, to which Mr. Mclnnes replied in the affirmative.

       Mr. O'Sullivan asked if EPA had any policy or thoughts on the issue that had been raised


                                        856
-------
several times regarding adjusting the VOC limits to subtract out water.  Mr.  Berry responded
that this was a complex issue and that EPA was aware of it. Mr. Berry said that there is some
problem with very low solids coatings; however, some parties tend to stretch this anomaly over
the full gamut of waterborne coatings, which is not appropriate.  Mr. Berry said that EPA will
be giving this issue further consideration in the development of the CTG.

      Mr. Pinkerton asked if industry has any concerns regarding the two on-going regulatory
tracks (i.e.., development  of RACT and MACT).  Mr.  Mclnnes responded  that industry
definitely would like to see the two developed in parallel, to avoid the problems of multiple and
differing   standards.    Mr. Pinkerton  concurred  that  this  would  be his  very  strong
recommendation.

      Mr. Jordan said  that he was  intrigued by the market-based controls concept briefly
discussed in the industry presentation, and indicated a desire to further discuss this concept in
the future.    Mr. Jordan asked when the NERA study would be completed. Industry responded
that they expect the study to be finished by the end of the year.

7.     MQBAY  CORPORATION PRESENTATION

       The Mobay presentation on polyester and polyurethane  coatings (which is attached) was
made by:

                                  Mr. John Williams
                             Director, Technical Marketing
                                     Mobay Corp.

       Mobay  supplies aliphatic and aromatic polyisocyanate resins  for use in polyurethane
coatings.   These coatings provide  greatly improved  performance (e.g., alcohol and mar
resistance), which will help with foreign competition. The CTG document contains a value of
about 3.4  Ib VOC/gallon for polyurethane coatings and, while this is technically achievable, it
is outside  the typical values. There are two-component solventborne polyurethane coatings for
clear topcoats  that contain 4.6  to 5.5 Ib VOC/gallon.   This represents  about a 23 percent
reduction  from nitrocellulose coatings.  In addition, the high film  build results in a reduced
number of coating applications.  The drawbacks to polyurethane coatings  are the need for (1)
a dust-free coating  environment and (2) worker training  in  the use of the two-component
equipment.

       Non-air inhibited unsaturated polyester coatings are high-gloss, high-build systems.  Clear
topcoats and sealers are commercially available and contain about 1.5 Ib VOC/gallon.  Use of
polyester coatings achieves about 40 to 75 percent VOC reduction for air dry and 88  to 97
percent reduction for ultraviolet (uv)-cure.   Overseas furniture  manufacturers are using these
coatings because of the improved performance. Development is continuing on other coatings.

       Work is ongoing to develop a two-component waterborne polyurethane topcoat and  sealer
containing about 0.9 Ib VOC/gallon.  It should be commercially available in  1 to 2 years.
                                     857
-------
       Customers have expressed some concern about worker health and safety because of the
polyisocyanates in these coatings.  Mobay has conducted extensive monitoring in plants using
polyisocyanates and has found no problems.

       Both the polyurethane and polyester  coatings are to some extent limited to certain
segments of the wood furniture industry.  Mobay supports the use of low-VOC technologies, but
only when combined with improved performance because of the need to increase competitiveness
of U.S. products.

       Mobay supplies  raw materials to coating manufacturers,  but  works closely  with the
coating suppliers and the coating buyers, such as wood furniture manufacturers,  to ensure the
end product satisfies all parties.  Mobay would like to work with EPA, a coating  supplier, and
a wood furniture facility to install and use these new technologies on a demonstration basis.

       Mr. James Berry, ESD/EPA, concluded this session by noting that the wood  furniture
industry has used nitrocellulose coatings for a long time. Polyurethane and polyester coatings
are relatively new to  the  wood furniture industry.   However,  he  suggested  that  industry
representatives look closely at this technology. Mr. Berry said that looking at all paint systems
being used everywhere on every conceivable  end-product, polyester/polyurethane coatings are
generally accepted as the premier coatings for durability, color retention, etc., and may be able
to achieve large VOC emissions reductions at a reasonable cost.  Wood furniture coating is the
largest uncontrolled single-industry VOC source remaining, and EPA  cannot just ignore these
emissions.

       MQBAY PRESENTATION DISCUSSION

  Mr. Atkins inquired about possible health problems associated with  using isocyanates.  Mr.
Williams responded that coatings with isocyanates can be used safely.  He said that all coatings
have some type of hazard, and general safe handling procedures are sufficient to protect workers
from isocyanates.

       Mr. Atkins also  asked if there are special costs associated  with the use and  monitoring
of a polyester or polyurethane coating system.  Mr. Williams acknowledged that  the two-
component coating system requires  two coating pots and a special  spray gun.  He noted,
however, that the equipment  is commonly available and used extensively by the military.

       Ms. Mclntire asked if the toxicity of the two-component coatings is higher than that of
solvents used in conventional coatings.  Ms.  Mclntire said that after  the permit program and
MACT standards are in place, it will be difficult to switch to more toxic coatings.  Mr. Atkins
replied that the solvents used in the two-component coatings are similar to those in conventional
coatings.

       Ms. Mclntire noted that RACT should genuinely be reasonably available.  There are a
number of developing control technologies for the wood furniture coating industry.  While it
may not be within the realm of the CTG process, the Clean Air Act Amendments clearly contain
mechanisms  for encouraging switching to new  technologies that probably are related to the
-------
economic incentive programs.  Incentives that might be offered are extended compliance times,
grants, and issuance of general permits during initial startup phase.

       Mr. Jordan read one question from the audience, which stated that there is at least one
dip tank in use in the industry and asked if EPA would require controls on such an activity.  Mr.
Berry responded that it would depend in part on the VOC content of the coatings and suggested
that the questioner talk to Mr. Berry after the meeting about the specifics of the situation.  Mr.
Jordan also read a comment from the audience, strongly recommending that any size cutoffs be
made in  terms of tons/year  of VOC, not number of employees,  since some companies
subcontract coating of parts and only assemble the finished parts.

       The session concluded with  one question from the audience, stating that the Joint
Industries Steering Committee was unaware of the new waterborne polyester coating discussed
in the Mobay presentation, or Mobay's offer to work with a plant to develop a system and
wondered why EPA had not informed the Committee prior to NAPCTAC. Mr. Berry responded
that  he had  informed Mr. Buck  Deal of Bernhardt (a member of the Joint  Committee)
immediately after hearing the Mobay information. Mr. Deal responded that given the timeframe
of this notice (a few weeks  before NAPCTAC), he did not feel that the Mobay presentation was
appropriate for the NAPCTAC meeting.
                                      859
-------
        CONTROL TECHNIQUES GUIDELINE
        CONTROL OF VOC EMISSIONS FROM
      WOOD FURNITURE COATING OPERATIONS
CO
-------
CD
CT5
                    INTRODUCTION


BACKGROUND

   • OVERVIEW OF WOOD FURNITURE INDUSTRY

   • EMISSION SOURCES


REGULATORY ANALYSIS

   • MODEL PLANTS

   • CONTROL ALTERNATIVES

   • RACT OPTIONS

   • IMPACTS
-------
              INDUSTRIES EVALUATED BY THE ANALYSIS

  SIC CODE    INDUSTRY

  RESIDENTIAL
    2511       WOOD HOUSEHOLD FURNITURE, EXCEPT UPHOLSTERED
    2512
    2519
to
    2517
WOOD HOUSEHOLD FURNITURE, UPHOLSTERED

HOUSEHOLD FURNITURE, NOT ELSEWHERE CLASSIFIED
  CABINETS
    2434       WOOD KITCHEN CABINETS
WOOD TELEVISION, RADIOS, PHONOGRAPH,  AND SEWING  MACHINE
CABINETS
  OFFICE
    2521
WOOD OFFICE FURNITURE
  INSTITUTIONAL
    2531       PUBLIC BUILDING AND RELATED FURNITURE

  FIXTURES
    2541       WOOD  OFFICE AND STORE FIXTURES, PARTITIONS,  SHELVING, AND
              LOCKERS
-------
                    DISTRIBUTION OF FACILITIES
                   BY INDUSTRY SEGMENT
                      APPROXIMATELY 11,000 FACILITIES TOTAL
           FIXTURES (17%)
CO
INSTITUTIONAL (5%)


     OFFICE (6%)
                                            CABINETS (34%)
            RESID. FURN. (37%)
-------
                 DISTRIBUTION OF FACILITIES BY SIZE
CD
                     LARGE (3%)
                MEDIUM (5%)
small 1 -99 employees

medium 100-249 employees

large >249 employees
                                      SMALL (92%)
-------
                                                    SMALL 1-99 EMPLOYEES
                                                    MEDIUM 100-249 EMPLOYEES
                                                    LARGE >249 EMPLOYEES
CD
O3
CJ1
LARGE (32%)
                                           SMALL (39%)
                  MEDIUM (28%)
-------
                               FINISHING SCHEMATIC
CD
 Coating
Application
                                  Oven
 Coating
Application
                    Finishing Operations ~ 94% total VOC emissions
                    Cleanup Operations - 6% total VOC emissions
-------
                REGULATORY ANALYSIS
ONCE THE INDUSTRY AND FINISHING PROCESS WERE CHARACTERIZED,




THE REGULATORY ANALYSIS WAS CONDUCTED, CONSISTING OF:






   • DEVELOPMENT OF MODEL PLANTS




   • EVALUATION OF VOC CONTROL ALTERNATIVES




   • DEVELOPMENT OF RACT OPTIONS




   • IMPACT ANALYSIS
-------
                                     MODEL PLANTS
                Residential Furn.
CD
en
I medium} [ large [  j email |  [medium | | large
                                                                      medium I  I large
                                       Small 50 TRY
                                     Medium 225 TRY
                                       Large 500 TRY
-------
                    FINISHING SEQUENCES
OFFICE/CABINET  RESID. FURN. (SHORT)
STAIN           STAIN
STAIN

SEALER

TOPCOAT
STAIN

WASHCOAT

SEALER

TOPCOAT

TOPCOAT
RESID. FURN. (LONG)
    STAIN

    STAIN

    STAIN

    WASHCOAT

    FILLER

    WIPING STAIN/GLAZE

    SEALER

    TOPCOAT

    HIGHLIGHT

    TOPCOAT

    HIGHLIGHT

    TOPCOAT
-------
             RELATIVE VOC EMISSIONS-FINISHING STEPS
                           (PERCENT)
        TOPCOAT
       HIGHLIGHT
         SEALER
o
  WIPING S./GLAZE
          FILLER
      WASHCOAT
           STAIN

                               NOTE:
                               HIGHLIGHT,
                               WIPING S.,
                               & FILLER
                               USED ONLY
                               IN LONG
                               SEQUENCE.
                 0
10  15   20  25   30   35  40
-------
     PARAMETERS CONSIDERED DURING
       CONTROL METHOD EVALUATION
CONTROL TECHNIQUES AVAILABLE
TYPES OF COATINGS PRESENTLY USED
FINISHING SEQUENCE / INDUSTRY SEGMENT
TOTAL VOC EMISSIONS AND CONCENTRATION
NUMBER AND TYPES OF VOC'S PRESENT IN EXHAUST
EXHAUST FLOWRATE TO BE CONTROLLED
-------
             CONTROL ALTERNATIVES FOR THE
                     FINISHING PROCESS
       LOWER-VOC COATINGS
     • ADD-ON CONTROLS
S3
«vj
10              • RECUPERATIVE THERMAL INCINERATION
               • REGENERATIVE THERMAL INCINERATION
               • CATALYTIC INCINERATION
               • COMBINED ADSORPTION/THERMAL INCINERATION
       COMBINATION OF LOWER-VOC COATINGS AND ADD-ON CONTROLS
       EXHAUST FLOW REDUCTION IS ESSENTIAL FOR ADD-ON CONTROLS

               • RECIRCULATION
               • AIR CURTAIN SYSTEM
-------
       CONTROL ALTERNATIVES FOR
           CLEANUP OPERATIONS
WORK PRACTICE MODIFICATIONS TO MINIMIZE EVAPORATION
REFORMULATION OF CLEANUP MATERIALS
ADD-ON CONTROLS
ANALYSIS NOT COMPLETE
-------
            DEVELOPMENT OF RACT OPTIONS

     • CONTROL ALTERNATIVES EVALUATED FOR EACH MODEL PLANT

     • PERMUTATIONS OF DIFFERENT CONTROLS BEING APPLIED TO THE

     MODEL PLANTS WERE DEVELOPED TO FORM THE RACT OPTIONS
eo
^    • UNDER A SINGLE RACT OPTION, DIFFERENT CONTROLS MAY BE

     APPLIED TO DIFFERENT MODEL PLANTS

     • THUS, RACT OPTION DESCRIPTORS DO NOT NECESSARILY INDICATE

     THE CONTROL STRATEGY APPLIED TO ALL MODEL PLANTS
-------
                         RACT OPTIONS


  1.   FULL WATERBORNE



  2.   HYBRID WATERBORNE



  3.   POLYESTER/POL YURETHANE



5 4.   POLYESTER/POLYURETHANE WITH WATERBORNE
CJl


  5.   HYBRID WATERBORNE AND ADD-ON CONTROLS ON SELECTED STEPS



  6-9  ADD-ON CONTROLS FOR ALL COATING STEPS


                • WITHOUT RECIRCULATION


                • WITH RECIRCULATION


                • WITH AIR CURTAIN SYSTEM
-------
            RACT OPTION 1
          FULL WATERBORNE
O/C & RESIDENTIAL SHORT - FULL WATERBORNE
RESIDENTIAL LONG - HYBRID WATERBORNE
-------
                  RACT OPTION 2
               HYBRID WATERBORNE
S   • WATERBORNE SEALER, TOPCOAT, AND HIGHLIGHT (AS
-J


    APPLICABLE) FOR ALL PLANTS
      CONVENTIONAL SOLVENTBORNE FOR ALL OTHER STEPS
-------
                  RACT OPTION 3
            POLYESTER/POLYURETHANE
    • SMALL PLANTS USE HYBRID WATERBORNE
CD

    • POLYESTER/POLYURETHANE SEALER, TOPCOAT, AND FILLER

    (AS APPLICABLE) FOR ALL MEDIUM AND LARGE PLANTS


    • CONVENTIONAL SOLVENTBORNE FOR ALL OTHER STEPS
-------
CD
                RACT OPTION 4



   POLYESTER/POLYURETHANE WITH WATERBORNE






• SAME AS OPTION 3 EXCEPT:






• O/C & RESIDENTIAL SHORT - WATERBORNE STAIN AND




WASHCOAT (AS APPLICABLE)






• RESIDENTIAL LONG - WATERBORNE HIGHLIGHT, REST




CONVENTIONAL SOLVENTBORNE
-------
                    RACT OPTION 5

 HYBRID WATERBORNE & ADD-ON CONTROLS ON SELECTED STEPS
©3
CD
• HYBRID WATERBORNE COATING SYSTEMS (AS DESCRIBED

PREVIOUSLY) FOR ALL PLANTS


• ADD-ON CONTROLS USED ON STAIN OR STAIN AND WASHCOAT

OPERATIONS AT ALL FACILITIES WITH MORE THAN 50 EMPLOYEES
-------
                 RACT OPTIONS 6-9

    ADD-ON CONTROLS FOR ALL COATING STEPS
    • ALL FACILITIES WITH FEWER THAN 50 EMPLOYEES EXEMPT



S3
2   • FOR EACH RACT OPTION, ADD-ON CONTROLS EVALUATED:
r*=*                       '


      • WITHOUT RECIRCULATION OR AIR CURTAIN SYSTEM


      • WITH RECIRCULATION


      • WITH AIR CURTAIN SYSTEM
-------
      NATIONWIDE IMPACTS
FACILITIES IN OZONE NONATTAINMENT AREAS



€0
CO





RACT OPTION DESCRIPTION
1 FULL WATERBORNE
2 HYBRID WATERBORNE
3 POLYESTER/POLYURETHANE
4 POLYESTER/POLYURETHANE
HYBRID
5 HYBRID WATERBORNE & ADD-ON
6-9 ADD-ON CONTROLS
W/OUT RECIRCULATION
W/RECIRCULATION
W/AIR CURTAIN SYSTEM
NATIONWIDE
VOC EMISSION
REDUCTION
(1000 Mg/YR)
94.8
73.4
69.9
80.9
91.2

64.2
64.2
66.1

72
56
53
61
69

49
49
50
NATIONWIDE
ANNUAL
CONTROL COST
(MM$)
229
147
264
260
347

331-418
244-293
181-211
AVERAGE
COST
EFFECTIVENESS
($/Mg)
2400
2000
3800
3200
3800

5200-6500
3800-4600
2800-3200
-------
11/15/91
1-HTW
          UNICRRB  SYSTEM®

          NttPCTHC  MEETING

         NOUEMBER 21, 1991
                  o .
-------
    LDHflT IS THE UNICRRR® SYSTEM?
      THE UNICflRB® SYSTEM IS fl

  POLLUTION PREUENTION TECHNOLOGY

    FOR THE RPPLICflTION OF SPRRY

    RPPLIED  INDUSTRIRL CORTINGS
11/15/91
2-HTW              084
-------
   HOW DOES THE UNICRRB® SYSTEM
               WORK?
   THE UNICARB® SYSTEM SUBSTITUTES
CARBON DIOXIDE FOR A SIGNIFICANT
AMOUNT OF SOLVENTS IN CONVENTIONAL
SPRAY APPLIED COATINGS, THEREBY
REDUCING VOC'S AND AIR TOXICS.
   UNICARB® COATINGS ARE HIGH IN
SOLIDS, AND CAN BE APPLIED MANUALLY,
AUTOMATICALLY, ELECTROSTATICALLY,
NON-ELECTROSTATICALLY WITH AIRLESS
OR AIR-ASSISTED AIRLESS TYPE SPRAY
GUNS.
11/15/91
3-HTW             J385
-------
    WHERE IS THE UNICRRB® SYSTEM
  flPPLICRBLE IN THE WOOD FURNITURE
             INDUSTRY?
   NITROCELLULOSE TOPCORTS  RND
   SERLERS

   FOR:  RESIDENTIRL  FURNITURE
         CRRINETS
         OFFICE/INSTITUTIONRL

   PIGMENTED  LRCQUERS  RND  ENRMELS

   SINGLE COMPONENT  RCRVLICS,
   POLYESTERS  RND URETHRNES

   2 COMPONENT EQUIPMENT RND
   CORTINGS RRE CURRENTLY IN  THE
   DEUELOPMENTRL STRGE RND SHOULD
   BE RURILRBLE IN 1992 FOR IN-
   PLRNT TESTING
11/15/91
4-HTW
-------
  HOW MUCH CAN THE UNICARB® SYSTEM
            REDUCE VOC'S?
•  FOR NITROCELLULOSE SERLER flND
   TOPCORT RPPLICRTIONS 60%-75%

•  FOR THE MODEL PLRNTS LISTED IN
   TRDLE 4-4 OF THE CTG DRRFT, THE
   TOTRL FINISHING  LINE  UOC
   EMISSIONS WOULD BE REDUCED  BV:

FINISHING LINES   UOC'S RIR TOHICS

LONG FINISHING LINES    37%     50%
SHORT FINISHING LINES    44%     60%
OFFICE/CABINET        44%     50%

   THIS RSSUMES THE UNICRRB® SYSTEM
   IS  USED FOR  BOTH NITROCELLULOSE
   SERLER RND  TOPCORT RPPLICRTIONS
   RT R 65% REDUCTION OF UOC'S
   (4.7LB/GRL),  RND RIR TOHICS
   REDUCTION OF 857.

•  UNICRRB® SYSTEM  NITROCELLULOSE
   CORTINGS HRUE BEEN FORMULRTED
   UJITH.R 90%  REDUCTION IN RIR
   TOHICS
11/15/91
5-HTW
                G81
-------
  IS THE UNICARB® SYSTEM BEING USED
           COMMERCIALLY?
   THE SYSTEM HflS BEEN INSTflLLED
   RND IS OPERRTING COMMERCIRLLV
   RT PENNSVLURNIR  HOUSE
   fi SUCCESSFUL DEMONSTRRTION OF
   THE SYSTEM UJRS CONDUCTED RT
   LEHIGH
   SEUERRL OTHER FURNITURE
   MRNUFRCTURERS RRE CURRENTLY
   CONDUCTING IN-PLRNT TRIRLS IN
   UlRGINIfl,  MISSISSIPPI, CRLIFORNIR
   RND RRIZONR
   TRIRLS  RRE BEING CONDUCTED  IN
   SEUERRL OTHER INDUSTRIES
   INCLUDING:   RUTOMOTIUE OEM,
   RUTOMOTIUE  COMPONENT, PLRSTIC
   CRBINETS RND PLRSTIC RUTOMOTIUE
   COMPONENTS
11/15/91
6-HTW
                O O i
-------
            unlCRRB®  SVSTEM
 ADVANTAGES FOR SEALER AND TOPCOAT
              APPLICATIONS
1)  CONTINUED USE OF NITROCELLULOSE
    CORTINGS

2)  REDUCED UOC'S...65%-75% FOR SERLERS UNO
    TOPCORTS

3)  REDUCED RIR TOHICS...80%-90%

4)  EflSY TO RETROFIT

5)  RELRTIUELV LOW CRPITRL INUESTMENT

6)  HIGHER FILM BUILD

7)  POSSIBLE COST SRUIN6S WHERE MULTIPLE
    SERLERS OR TOPCORTS RRE RPPLIED

8)  COMPLIMENTRRV TO OTHER CORTIN6  SYSTEMS

9)  MOUES SOLUENT EMISSIONS FROM BOOTH TO
    OUEN

10) POLLUTION PREUENTION TECHNOLOGY
11/15/91
7-HTW
-------
                                                       i/M
                                       090
P.O. Box 6130 • Buffalo Shoals Rd. • Statesville, N.C.  28677 • Tel 704-878-9523/Fax 704-878-2914
-------
                                              November 21, 1991


         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

              "Finishing Systems for Wood Furniture"

                      - Emerging Technology  -


 I.    Int roduct i on

      Classic Systems,  Inc. - Turnkey Contractor -
      primarily furniture  industry

      A.      Involvement  in new technology for
              control 1 ing VOC em i s s i o n s

      B.      CamBooth  - unique use of low velocity,
              push-pull air curtains to  isolate operator
              from unhealthy work environment and greatly
              reduce  exhaust air

II.    Background  for  Development -
      analysis of typical  problems  and complaints:

      A.      Inadequate capture of fumes and over-
              spray  in  typical  open front spray booths

      B.      Inadequate make-up air
              1.       Negative  pressure  in  finishing  room -
                       infiltration  of dust  degrades quality
                       of end product
              2.       Cold and  drafty work  place  in winter
              3.       High operating costs

      C.      Pending VOC  reduction requirements  -  high  initial
              and operating costs with present  large  volume
              exhaust  system

      Conclusion:      Most problems could be  resolved by  greatly
                       reducing  the  amount of  exhausted  air  from
                       the  work  space
                             esi
-------
III.     Review Transparencies

        A.       Typical  System - individual exhaust for oven,
                flash tunnel  and spray booths (open ends)

        B.       CamBooth System - one exhaust for all segments
                (closed  ends)

        C.       Views (front, plan and end)

        D.       Air flow patterns

        E.       Finishing Room - Typical
                1.       Exhaus t fan unit
                2.       Diverter dampers
                3.       VOC system tie-in

        F.       Energy cost comparisons (basic benefits)

 IV.     Slides

        A.       Various  views

        B.       Airflow patterns
                1.       Fron t a i r cur ta i n
                2.       End air curtain
                3.       Internal down draft

        C.       Demonstrate how worker is protected from
                internal environmental

  V-     Questions  and answers
                             G:
-------
                                       OVENOHAUST
                                    Q)
                                                                                                    FUSH TUK1DHAUST
                                                                                                                                               SMATBOOTH DWAUST
                                                                 CONVENTIONAL FINISHING SYSTEM LAYOUT
O
                                                                           OWN EXHAUST ROUTED TO FlAffl TIMCL
OVEN EXT
AIR CURTAH  i.
Lc.-;:;
                                                                                                                      JJU
                                                                                                       BOOTH OOW-ORAn FAN -i
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                                                                                                 FLAW TUML
                                                                                                  AD OJRTAM
                                                                                             OVENNIT
                                                                                             ABCURTAW
                                                               NEW CAMBOOTH  RNISHING SYSTEM  LAYOUT
                                                                                                                                                 CLASSIC  SYSTEMS. INC.
                                                                                                                                                          P.O. BOX «iao
                                                                                                                                           STATESVILLE. NORTH  CAROUNA 28677
                                                                                                                                                      1CLSPHONE TO4-«7B-eS23
-------
FLASH TUNNEL     \ I  /
 AIR  CURTAIN    C-
                                                   BOOTH EXHAUST FAN
                                BOOTH  DOW-DRAFT FAN
                                 PULLING AIR FROM FLASH TUNNEL
                                                                                                 AIR CURTAIN FAN AND FILTER
0
                                                                                          BOOTH OPERATOR OPENING
                                                                                               W/ AIR CURTAIN
                                                                                    WATERPAN OR DRY MEDIA FILTER SYSTEM
                                           FIASH TUNNa
                                                                                                 SPRAYBOOTH
                                                                                                                                      FTT  BOOTH INLET
                                                                                                                AIR  CURTAIN
                                                              FRONT  ELEVATION
                                                                                                                                               CLASSIC^SYSTEMS. ma
                                                                                                                                          STATESV1LLE, KORn? CAROLINA 88*77
-------
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       FLASH  TUNNEL
         AIR CURTAIN
                                                                                            BOOTH  EXHAUST FAN
                                                 -BOOTH DOWN-DRAFT FAN
                                                   PULLING AIR FROM FLASH  TUNNEL
                                                                                  PLAN VIEW
                                                                                                              LIGHTS
                                                                                                            AIR PLENUM
                                                                                                       AIR CURTAIN FAN AND FILTER
                                                                                                                                          BOOTH INLET  AIR CURTAIN
                                                                                                                                                      CLASSIC SYSTEMS. INC.
                                                                                                                                                 STATESVOLE, NORTH CAROLINA Start
                                                                                                                                                         nunm m n ttn
-------
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                                                                                                                  • WATERPAN OR DRY MEDIA FILTER SYSTEM
                                                                                             END ELEVATION  AT SPRAYBOOTH
                                                                                                                                           CLASSIC SYSTEMS, INC.
                                                                                                                                       STATESVILLE. NORTI? CAROLINA 28077
-------
CO
                    AIR CURTAIN
                     FAN AND
                      FILTER
AIR PLENUM
 FILTERS FOR  OOWNORAFT AIR
                                       WATERPAN FILTER SYSTEM
AIR CURTAIN
 FAN AND
  FILTER
AIR PLENUM
 FILTERS FOR  DOWNORAFT AIR
                                                                                                                                     CART
                                                             DRY MEDIA FILTER  SYSTEM
                                                                 	  AIR CURTAIN AT 600 FPM

                                                                    •«=-  DOWNDRAFT AIR AT 50 FPM

                                                                 	>  FINISHING SPRAY FROM SPRAY GUN



                                                                INTERIOR VIEW OF FLOW  PATTERN
                                                                                      •FILTER
                                                                                                                                                   CLASSIC SYSTEMS, INC.
                                                                                                                                              STATESVUIZ mem CAROLINA eaerr
-------
                                    OVEN
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                                                                  UNLOAD
                                                                 LOAD
                    TYPICAL FINISHING SYSTEM
                                                                                             CLASSIC SYSTEMS, INC.
                                                                                         STATESVILLE. NClRTlf CAROLINA
-------
                     BOOTH EXHAUST
                        BOOTH EXHAUST
                                       REMOVABLE
                                        BALANCING
                                         DAMPER
CO
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                                                  ACCESS DOORS
        SPRAYBOOTH ROOF
  REMOVABLE
SPCOL SECTION
                                                       SPRAYBOOTH  EXHAUST FAN
                        SPRAYBOOTH ROOF
                                                                                                                                    CLASSIC SYSTEMS, INC,
                                                                                                                                STATB3VILLE, NORTH CAROLINA 20077
-------
EXHAUST TO ATMOSPHERE (CLOSED)
EXHAUST TO ATMOSPHERE (OPEN)
                                                TO INCINERATOR (OPEN)
                                               TO INCINERATOR (CLOSED)
                                                                                                                 ROOF
           FROM
         SPRAYBOOTH
           FROM
         SPRAYBOOTH
                              SPRAYBOOTH EXHAUST DIVERTER VALVE
                                                                                                                         CLASSIC SYSTEMS.  INC.
                                                                                                                    STATESVIUK NORTH CAROLINA 2MT7
-------
STACK
            	I BLOWER
        _rw
INCINERATOR       \-ABQRT DAMPER
              VOC INCINERATION SYSTEM
                                                     -O

                                                                         CLASSIC SYSTEMS, INC.
                                                                              PA KB (00
                                                                      STATGSVniK. NORTH CAROUNA 28877
-------
                                                       •NIRQY  COST  EVALUATION
                                                                                                                                 1900.000
         35
         30
         25
         20
         15
         10 -
   ANNUAL
 OPERATING
   COST IN
 THOUSANDS
OF DOLLARS
                                                               130.000
                                                               ^/Vy/Vy
                                             $22,000
5  -
                   $3,000
                                                         $8,000
                                                                                                                                            1125.000
                    MAKE-UP  AIR
                        HP
                                        SPRAYBOOTH
                                           HP
     FUEL FOR MAKE-UP AIR
GAS
STEAM
              BASIC ASSUMPTION:  A. (6)  EACH  CONVENTIONAL SPRAYBOOTH SYSTEM = 120.000 CFM
                                 (6)  EACH  CAMBOOTH SYSTEM                =  21.000 CFM
                               B. HEATING COST - 1  SHIR, 6 DAYS/WEEK,  18 WEKS/YEAR, AND AVERAGE SOT
                                                TEMPERATURE RISE: GAS 0 $5/MBTU PER HOUR
                                                                STEAM 0 $4/1OOOJ PER HOUR
                               C. HORSEPOWER COST  6 $300 PER HP/YR
                               D. THERMAL  OHDIZER - WITH HEAT RECOVERY. VOC FUEL VALVE INCLUDED.  2600 ANNUAL
                                                   OPERATING HOURS
VOC INCINERATION
  FUEL  -  GAS
                                                                                                                    CONVENTIONAL SPRAYBOOTH  SYSTEM

                                                                                                                    CAMBOOTH SYSTEM
                                                                                                                                CLASSIC SYSTEMS. INC.
                                                                                                                           STATESVIUE. NORTH1 CAROLINA 28*77
-------
Saves Energy & Materials

80% Reduction in CFM
Requirements*

 • reduces energy costs

 • substantially less airflow to
   exhaust control devices

 • increases transfer efficiency
   of spray gun

•Compared to typical conventional
 designs.


Better Quality Production

Reduced Airflow Allows:

 • better operator control of
   coatings applications

 • greatly enhanced dust free
   environment for cleaner finish
      AIR CURTAIN
                              Safer Operation

                              Helps Meet New EPA and
                              OSHA Standards by:

                                • limiting operator exposure to
                                  VOC vapors

                                • lower decibel levels


                              CAMBOOTH Specfications

                              BASIC DESIGN:
                                down-draft with dry filters, air
                                curtains at operator station and
                                all entry and exit points.

                              DIMENSIONS:
                                Based on product size and
                                finishing schedule.

                              EXHAUST RATE:
                                3000 scfm per 20' booth.

                              HORSEPOWER:
                                3 HP per 20'booth.
                       The CAMBOOTH is
                       Adaptable*

                         • can be installed in present
                          booth location

                         • works with overhead or pallet-
                          type conveyor line

                         • can be equipped with the
                          following options:
                            — Flash Tunnel
                            — Drying Oven
                            — Catalytic or Thermal
                               Oxidizer
                            — Carbon Absorption Filter
                               Module

                         • can be supplied as water-
                          wash booth

                       *MODEL AVAILABLE FOR INSPECTION
                        AND PRODUCT TESTING
                                                              EXHAUST FAN
  General Office
Buffalo Shoals Road
   P.O. Box 6130
Statesville, N.C. 28677
 TEL: 800-362-5003
 FAX: 704/878-2914
                                          DRY FILTER MEDIA
                                       OR WATER FILTER SECTION
    SPRAY BOOTH-
                                          AIR CURTAIN
IT-.
-------
                              Introducing The All New
     GVMBOOIH
CLASSIC SYSTEMS, INC.
 Increased Efficiency In The
Manufacturing Environment
  Now in our fifteenth year,
Classic Systems is a company
dedicated to designing and
building products which solve
specific problems relating to
materials handling, and to EPA
and OSHA regulations.
  We currently operate from
2 North Carolina locations with
over 130 employees and annual
sales of more than $10 million.
We serve our customers nation-
wide with innovative solutions
in the following categories:
   • Dust Collection Systems
   • Finishing Systems
   • Fume Control
   • Materials Handling
      CLASSIC
                             from Classic Systems, Inc.
 The CAMBoom utilizes a
 unique Air Curtain design
 and offers the following:
 • Significantly Increased Efficiency
     • Environmental Safety
• Higher Quality Coatings Applications
       FOR USE AS A:
       • Spray Booth
     • Fume Control Device
     SYSTEMS
                            'Patent Pending
-------
GRACO COMMENTS REGARDING PROPOSED
CTG FOR THE WOOD INDUSTRY
Thank you  for the opportunity to present our
comments on the  proposed CTG for the wood
industry.  In  our presentation today, we will
address the issue of transfer efficiency as it
relates to the performance of the  paint
application device.

In reviewing the Draft Chapters 1  through  4
of the Control of  Volatile Organic  Compounds
from Wood Finishing Coating Operations, we
noted several references  to a  lack of a
standard transfer efficiency test.
Specifically, Pages 2--3G and 3--4S.
Basically, transfer  efficiency is
the amount of paint that actually lands on a
part, compared with  the total amount  of paint
being sprayed from the gun.
Our goal is to  maximize transfer
efficiency and minimize the amount of paint
used to paint a part.  Higher transfer
efficiency will result in lower paint usage,
fewer solvent emissions, reduced exposure  by
plant personnel to solvent fumes, less sludge
to  dispose of, and less maintenance and less
paint handling in  general.  This task is
complicated  by  the demands of  real world
production.
The  formula  that expresses  this relationship
is  as follows:
T.E.= Wp/%S x Q x T
-------
Where:

T.E.= Transfer efficiency

Wp= Weight of the paint solids deposited on
parts after baking

%S= Percentage of the sprayed paint that is
made up of solids

Q= Paint  flow rate

T= Time of spray  operation
At Graco, we have long recognized the need
for  a standardized method that would provide
meaningful data to determine  which
application device would provide the most
efficient means of applying  paint to a
customer's product. Our customers range from
companies that paint huge  metal structures
such as aircraft and road graders to
companies that  paint  considerably smaller
objects  like wood spindles  for chairs.
In addition to  part size, shape and substrate
differences, some customers  paint indoors
and some paint outdoors. Some apply paint at
a high delivery rate because they are  painting
product moving down   a conveyor line while
other  paint stationary product  in a paint
booth. The painting environment varies
greatly as well. Some customers have down
draft  paint booths with very  sophisticated air
movement  controls;-others  have  less than
ideal  conditions.
Given this wide array of equipment,  Graco has
-------
developed  a test for determining the transfer
efficiency of the  paint application tool.  We
recognized early on  that there were a number
of factors which will  have an affect on
transfer  efficiency.
Among  them-


• Operator Spray Technique

• Fluid  Delivery Rate

• Atomizing Air Pressure

• Target Size

• Type  of Application  Tool

• Condition  of Application Tool

• Part  Configuration

• Air  Velocity  in the Spray  Booth

• Fluid  Pressure

• Distance of the Spray Gun from the Target
There are also quality standards which  vary
from industry to industry  and even  from plant
to plant  within  the same industry.
Given all of these factors, Graco designed a
transfer  efficiency  test  that  attempted to
eliminate as many variables as  possible. By
doing so, we  felt that the tested  performance
of the  application  tool would  be meaningful
to our needs in product development  and also
our customers' requirements  for the most
-------
efficient  application  tool commensurate  with
their needs  for speed and quality.
At this  time, I  would like  to take this
opportunity  to  describe  that test procedure
for  you.

Graco  uses a test method for determining the
transfer efficiency of each type of
application tool that we feel provides a
reasonably  accurate tranfer efficiency
number for  each application tool. Through this
method, we have removed the  variables of
operator technique,  air  flow past the  booth,
part configuration and so  forth. The test that
we  use calls for painting a group of ten 4 foot
by 6 inch panels hung vertically on  12 inch
centers that are wrapped  with  preweighted
aluminum foil.  The  painting is performed  by a
test gun that has been  preset to approximate
the  demands of a production environment. We
trigger the gun six  inches  before the spray
contacts the first panel and release the
trigger once the last panel has  moved six
inches beyond the gun. By doing so, we can
accurately determine the amount of
paint dispensed through the gun and compare
that to the amount  of paint by  weight that
ended up on the panels. We determine the
weight of  the paint  on the panels by weighing
the  panels before and after spraying and
noting  the difference.
By using this method we are able to provide a
realistic  transfer efficiency  figure that one
could reasonably expect from
each method of spray finishing.  By using the
same test criteria,  here  is how the various
spray technologies performed.
                     o-n
                     Jl O
-------
                                         'o
                                         'o
Air Spray                              30%

HVLP Air Spray                        40%

HVLP Air Assisted Airless Spray        45%

Electrostatic  Ajr  Spray (65kv)          65%

Electrostatic  Air Assisted  Airless
                           Spray      70%

Electrostatic  Air Spray  (85kv)         75%
I  would like to point out that  this method
shows that electrostatic guns  are the only
finishing  tools  that, achieve  transfer
efficiencies of more than  50%.

Due to the recent enactment of air quality
equipment rules  that  prescribe  compliant
types of  finishing equipment, many of you
have  probably heard of another spray
technology, commonly referred to as "HVLP".
The term HVLP stands  for High Volume Low
Pressure  spray. As its name suggests, High
Volume Low Pressure spray uses large
volumes  of air under reduced  pressure
(typically  10 psi  or less)  to atomize  coatings.
Because  the  atomized  paint is propelled from
the HVLP gun at a lower velocity, there is  a
 reduced  chance  of overspray.
Today, there are two forms of HVLP
atomization. These are HVLP air spray and
HVLP air assisted  airless  spray. HVLP air
spray uses large volumes of air at low
pressure to atomize  coatings, while HVLP air
assisted airless spray  uses fluid pressure to
atomize coatings and reduced air  pressure to
-------
sculpt the fan pattern  of the  atomized spray.
Claims  of  extremely  high  transfer
efficiency have been made for HVLP. However,
as I  have tried to make clear, tests can  be
designed to provide a high transfer  efficiency
value.  HVLP can generally provide finishers
with  higher transfer  efficiency  than
conventional air spray systems. And at  its
best,  HVLP will generally exceed the transfer
efficiency  of air spray and approach  the
transfer efficiency  of air assisted  airless
spray while providing  a  high  quality finish.
But it is important  to remember  that HVLP
air  spray  operates  at generally  lower  fluid
flow rates  than  other  spray finishing
methods. The lower atomizing pressures of
HVLP means that you may be forced to  reduce
your fluid  flow  rate  to maintain finish
quality.  At these lower atomizing  air
pressures,  there may simply  not  be enough air
atomizing  pressure  to keep up.

On  the  other hand, HVLP air assisted airless
spray operates  at  fluid flow rates similar  to
conventional  air assisted  airless spray and
therefore  lends  itself to  higher  production
environments.

But please remember, the  test method  I have
described  is  designed to test relative
performance  levels. However, we can say that
this test method has been  shown to be very
useful both to us and to end-users. These
findings have also been corroborated by
anecdotal  evidence.

We know  of  a furniture finishing operation
that was able to achieve  a 40% materials
savings when they "switched  from
-------
conventional air spray to HVLP.

But as we have already noted,  in the real
world, spray finishing conditions are much
more complex.

In addition,  the  industrial finishing  line is
governed by two overriding  concerns—finish
quality and productivity. The finished
appearance of  the product being painted is
essential  to  its success in the  marketplace.

The  need to produce as many finished parts
as possible in  as short a time as possible  is
also essential  to keeping  production costs
down. These two factors  will determine the
selection  of finishing  tools and
the way  they are used on the finishing  line.

We  believe  that transfer efficient  application
tools  will  reduce the amount  of paint used to
finish a  part. This  reduction  will result in
fewer VOC emissions released into  the
environment which  in  turn will benefit
overall air quality. The key issue in
identifying such  transfer  efficient  tools is
the standardized test  method by which we
will  select  them.
-------
Mobay's Role  in the Wood Furniture   Mobay
Coating Industry
         Mobay is the leading North American supplier of
        aliphatic and aromatic polyisocyanate resins for use in
        polyurethane coatings for wood
        Mobay is also the leading North American supplier of
        non-air inhibited unsaturated polyesters for use in
        polyester coatings for wood
        Mobay sells resins to wood coating manufacturers
        Mobay seeks to act as a technical partner to the wood
        furniture coating industry
   Presentation to U. S. Environmental Protection Agency, November 19-21, 1991
-------
Mobay's Role as a                             MobaX.
Raw Material Supplier
         To define the status of our technology with respect to
         VOC compliance
         Enable us to demonstrate technology developments
         and feasibility by working with furniture
         manufacturers and coatings manufacturers
   Presentation to U. S. Environmental Protection Agency, November 19-21,1991
-------
Current Status  of  2-Component           Mobay
Solvent-Borne  Polyurethane Coatings
for Wood  Furniture	_____

      Commercially Available System   VOC (Ibs/gal)
      Clear Top Coats
 Benefits
   Up to a 23% VOC reduction from
   nitrocellulose coatings
   (approximately
   6.0 Ibs/gal to 4.6 Ibs/gal)
   Greatly improved performance
   properties (e.g. alcohol resistance/
   mar resistance)
   High film build resulting in the
   reduced number of coating
   applications
   Currently being used in production
            4.6-5.5

Present Limitations
•  May require adjustments to existing
   production operation and different
   equipment for safe or cost efficient use
   in some wood coating operations
•  May require a degree of wood coatings
   user training/adjustment in operating
   procedure for their proper use
•  Deviation from existing repairability
   procedures
   Presentation to U. S. Environmental Protection Agency, November 19-21, 1991
-------
Current Status of Non-air Inhibited
Unsaturated  Polyesters for use in
Polyester Coatings  for Wood
                                                  Mobay
      Commercially Available System
        Air Dry Clear Top Coats/Sealer
      Developmental Systems
        Air Dry Clear Top Coats/Sealer
        UV-Curable Top Coat
        UV-Curable Sanding Sealer
        UV-Curable Top Coat
        UV-Curable Sealer
                               Contains
                               monomer

                               solvent
                               monomer
                               monomer
                                water/s
-------
cn
    Current Status of  Non-air Inhibited      Mobay
    Unsaturated Polyesters for use in
    Polyester Coatings for Wood  (ContdL)
Benefits
•  40-75% VOC reduction for Air Dry
   unsatu rated polyesters as compared to
   nitrocellulose (i.e. NC @ 6.0 Ibs/gal)
•  88-97% VOC reduction for UV-Cure
   unsaturated polyesters as compared to
   nitrocellulose (i.e. NC @ 6.0 Ibs/gal)
•  Greatly improved performance properties
   (e.g. alcohol resistance/mar resistance)
•  High film build resulting in the reduced
   number of coating applications
•  Two alternative curing methods
Present Limitations
•  May require a degree of
   wood coating user
   training/adjustment in
   operating procedure for
   their proper use.
•  May require additional
   or different equipment
   for safe or cost efficient
   use in wood coatings
   operations.
       Presentation to U. S. Environmental Protection Agency, November 19-21,1991
-------
Mobay Supports                                     Mobav
         ^f      H ^1                                            .•.•.VVV-V.V.V.'.V.SWAVW.-.V.V;
                                                               >MXiX4<«x-:-:->x<»M>
          The reduction of VOC by use of 2-Component Polyurethanes
          and Non-Air Inhibited Unsaturated Polyesters

          The need for continued cooperation by the EPA with
          coatings raw materials suppliers, coatings manufacturers,
          and wood coatings users

           In allowing VOC compliant products to be optimized
           through continued development
           To allow market acceptance of products based on
           economic benefit, property performance, as well
           as VOC reduction.
   Presentation to U. S. Environmental Protection Agency, November 19-21,1991
-------
   Goals of Mobay Development
Mobay
CO
          Environmentally responsible coatings systems
          High performance coatings
      Presentation to U. S. Environmental Protection Agency, November 19-21,1991
-------
t- 3
to
     Future Developments in
     Wood Coatings
                                                     Mobay
        VOC reduction down to 0.9* Ibs/gal via
        2-Component water-borne polyurethane
        topcoats and sealers
Potential Benefits
•  85% reduction in VOC from
   nitrocellulose coatings
•  High performance of a
   2-Component solvent- borne
   polyurethane
•  Clarity of finish
•  Higher film build

* VOC value is less water
Present Limitations
•  No large scale production at this
   point
•  Commercial availability in 1-2
   years
•  Technology would require:
  • cooperative development with and the
    approval of wood coatings manufacturer
  • acceptance of furniture coatings users
        Presentation to U. S. Environmental Protection Agency, November 19-21,1991
-------
Mobay Supports                           Mobay
     The cooperative efforts between the Joint
     Industry Steering Committee (JISC), the paint
     and coatings industry and the EPA by offering
     raw materials and technology that will reduce
     VOC levels and greatly improve the
     performance properties of wood furniture
     coatings and provide off-setting cost benefits
     during the application process
  Presentation to U. S. Environmental Protection Agency, November 19-21, 1991
-------
                                                               101 California Street
                                                               San Francisco, California 94111
National Economic Research Associates, Inc.                                (415) 291-1000
Consulting Economists                                                   Facsimile (415) 291-1020


                        ECONOMIC IMPACTS OF

                       VOC EMISSIONS CONTROL

          ON THE FURNITURE AND CABINET INDUSTRIES
                        PRELIMINARY  FINDINGS
                                   Presented to:

                           National  Air Pollution Control
                          Techniques Advisory Committee


                                   Presented by:

                                 Mark P. Berkman
                                 Senior Consultant
                       National Economic  Research Associates


                                   On Behalf of:

                    American Furniture Manufacturers Association
             Business and Institutional Furniture Manufacturers Association
                     Kitchen Cabinet  Manufacturers  Association
                National Paint  and Coatings Manufacturers  Association
                                November 21, 1991
                              Durham, North Carolina
                                A Marsh & McLennan Company
     White Plains, NY / Washington, DC / Los Angeles / Cambridge, MA / Philadelphia / San Francisco / New York, NY / Ithaca, NY / Seattle / London / Madrid
                                      ~
-------
 PROJECTED TOTAL ANNUAL COST TO THE WOOD FURNITURE
    AND CABINET INDUSTRY OF REDUCING VOC EMISSIONS
    Annual Cost ($ millions)
(9
    600
    500 -
    400 -
    200 -
    100 -
            l        I
          10 %     20 %
30 %    40 %    50 %
Reduction in VOC Emissions
60%
70%
-------
               PROJECTED PLANT CLOSURES
         IN THE WOOD FURNITURE AND CABINET INDUSTRY
   RESULTING FROM THE COSTS OF VOC CONTROL TECHNOLOGY
Number of Plants Closing
3,000
2^00 -
2,000 -
1,500 -
1,000 -
 500 -
  0  I—
                       1,488    U24    1,524   1,524
        10%     20%    30%     40%    50%     60%
                          Reduction in VOC Emissions
70%
80%
-------
SO
                PROJECTED EMPLOYMENT LOSSES
       IN THE WOOD FURNITURE AND CABINET INDUSTRY RESULTING
            FROM THE COSTS OF VOC CONTROL TECHNOLOGY
    Number of jobs lost
    100,000
     80,000 -
     60,000 -
     40,000 -
     20,000 -
17,764   17,764
                          12,513   12,513
             10%     20%     30%    40%    50%    60%
                             Reduction in VOC Emissions
              70%
80%
-------
               Estimated Cost-Effoctlvsnsss of VOC Emission Control Methods In 1994 In Nonsttslnmsnt CWs»


   Oaaolln* volatility
                T80Fa


                 RACT


        Enhanced I/M


              Stag*  II


            New CTOa


       Mathanol fuel*


  Architect, coating*


    Onboard controla


    New mobll* atd'a.


  Stag* II » Onboard
                          Low • $8,700 p*r ton
                          Mean • $30.000  p*r ton
                          High • $61.000 p*r  to ON.
                                                   \
Coal-*lt*ctlv*n*aa In 2004
                        0123468789
                                                    $1.000/ton of VOC r*duo*d
 The cost-effectiveness of enhanced Inspection and maintenance (VM) programs and new mobile standards Include only the cost of VOC
 confrol. Since Onboard controls and new mobile standards do not take affect until after 1994. we present the cost-effectiveness In 2004.
 The thick horizontal bars represent the average cost-effectiveness in nonattainment cities. The thin horizontal lines for gasoline volatility.
 methanol fuels, and l/M programs represent ranges of uncertainty associated with assumptions we used to estimate total annual costs.
 The very large uncertainty associated with the methanol fuels Is due to the uncertainty of methanol prices relative to gasoline prices. We
 were unable to estimate cost-effectiveness uncertainty for other control methods. See figure 7 for a description of control methods.
 SOURCE Otlto* ol1
                  •ft A*«
Catching OurBnath —Next Steps for Reducing Urban Ozone, Congreu of the United States/Office of Technology
Aiaeument, July 1989, Page 17
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        WOOD FURNITURE AND FIXTURES MANUFACTURERS
         ACCOUNT FOR LESS THAN ONE PERCENT OF TOTAL
                             VOC EMISSIONS
                Small Stationary
                   42.23%
 -
P
                                                    Large Stationary
                                                       7.83%
      Air, Rail, Marine
         5.58%

       Wood Furniture
        and Fixtures
        Manufacturers
         0.54%
               Highway Vehicles
                  43.82%
   Emission from Wood Furniture and Fixtures
   Manufacturers were subtracted from Large
   Stationary.
Source: Derived from 'Catching Our Breath:
    Steps for Reducing Urban Ozone,"
    U.S. Congress, Office of Technology
    Assessment 1989.
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    LOWEST ANNUAL COST OF ATTAINING A 30 PERCENT
       REDUCTION IN VOC EMISSIONS FOR DIFFERENT
       WOOD FURNITURE AND CABINET PLANT TYPES
Cost (dollars/ton)
12,000
 10,000

 8,000

 6,000

 4,000

 2,000

    0

(2,000)
            %£*•
            I
          Casegoods
          10-14 Coats
  Casegoods
  Highspeed
(Up to 10 Coats)
Office Furniture
 (High End
 Casegoods)
Chair
Plant
  Print
  Finish
(Flat Line)
 Kitchen
 Cabinets
(Tow Line)
 Small
Upholstered
 Plant
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                       THE EFFECT OF VOC CONTROL TECHNOLOGY ON PROFITS
                        MODEL PLANT 3 (HOUSEHOLD FURNITURE: 19 COAT STEPS; $27.0 MILLION)
See
P
           PROFIT/SALES (%)
           6.00%
           4.00% -
           2.00% -
           0.00%
-2.00%  -
          -4.00% -
          -6.00%
                    No Control    HVLP Spray Gam  Hybrid Wtterbome  PuU Wttabame     Union*

                                         VOC CONTROL TECHNOLOGY
    Carbon Adwxptioa
                                                                           Regenerative
                                                                           locutennoB
                    Low Profit Quartile
                                   Model Plant Profit
High Profit Quartile
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               THE EFFECT OF VOC CONTROL TECHNOLOGY ON PROFITS
     MODEL PLANT FOUR (OFFICE CASEGOODS: 15 COATING STEPS; SALES $11.0 MILLION)
  PROFIT/SALES (%)

 10.00%
  5.00%
  0.00%

 -5.00%
-10.00%
•15.00%
               5.90%
            1.20%!
           -1.00%
                           5.99%
1.29%
                          I
                                                             5.41%
              4.56%
                                                  4.07%
                                   0.71%
                                                                         0.41%
             I
I
I
           No Control   HVLP Spray Guns Hybrid Walerbome Full Waterbome    Unicarb

                                    VOC CONTROL TECHNOLOGY
                                           Carbon Adsorption  Regenerative
                                                        Incineration
              Low Profit Quaitile
              Model Plant Profit
             High Profit Quartile
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               THE EFFECT OF VOC CONTROL TECHNOLOGY ON PROFITS
     MODEL PLANT EIGHT (KITCHEN CABINETS: 4 COATING STEPS; SALES $13.4 MILLION)
 PROFIT/S ALES (%)
 8.00%
-4.00%
          No Control   HVLP Spray Guns Hybrid Walerbome Full Waierbome    Unicub   Outran Adsorption UV Roll Coating   Regenerative
                                                                                  Incineration
              Low Profit Quartile
VOC CONTROL TECHNOLOGY

  Model Plant Profit      ^  ^ High Profit Quartile
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               Annual Failure Rates per 10,000 Concerns
                    (Enterprises listed in Dun & Bradstreet Census
                               of American Business)
Failures per 10,000 companies
200
150 -
100  -
           1986
1987
                            Furniture
1988           1989

All Manufacturing
1990
Source: Business Failure Record, 1986-1990
Dun & Bradstreet Corporation
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     Millions of Dollars
     $4,000
                                     U.S. HOUSEHOLD FURNITURE INDUSTRY (SIC 251)
                               DOLLAR VOLUMES OF FOREIGN IMPORTS AND U.S. EXPORTS
                                                         1981-1990
     $3,000
3 to $2,000

^



     $1,000
        $0
                                  I
I
I
I
I
I
_L
            1981      1982       1983      1984      1985      1986       1987

                                        Foreign Imports  U.S. Exports
                                       1988
                                        (est)
                             1989
                             (eat)
                             1990
                             (est)
     Source: U.S. Census Data as reported in The U.S. Household
           Furniture Industry," Economic Industry Reports, Inc., 1990.
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9
                    PROJECTED PLANT CLOSINGS
          BY PLANT SIZE AND VOC REDUCTION LEVEL
    Number of Employees in Plants Experiencing Losses
    in excess of 5% of sales
     3,000
     2,500 -
     2,000 -
     1,500 -
     1,000 -
      500 -
        0
1,950
             1-19
                                      25
      20-99   100-249  250-499  500-999
               Size of Plants
              (Number of Employees)
                                                  2,539
  I      I
1000+  All Plants
                80% VOC Reduction

                60% VOC Reduction

                50% VOC Reduction

                40% VOC Reduction

                30% VOC Reduction

             H 20% VOC Reduction

             ^ 10% VOC Reduction

             I  I Already experiencing losses
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is
               PROJECTED EMPLOYMENT LOSSES BY
          BY PLANT SIZE AND VOC REDUCTION LEVEL
     Number of Employees in Plants Experiencing Losses
     in excess of 5% of sales
     100,000
      80,000 -
      60,000 -
      40,000 -
      20,000 -
              11,075
..A1,   19334
17,012  HBHHH   15>949   15,927
                                                        86,534
               1-19   20-99   100-249  250-499  500-999
                                Size of Plants
                             (Number of Employees)
                             I       I
                            1000+  All Plants
80% VOC Reduction

60% VOC Reduction

50% VOC Reduction

40% VOC Reduction

30% VOC Reduction

20% VOC Reduction

10% VOC Reduction

Plants already
experiencing losses
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          POLICY IMPLICATIONS
A MARKET-BASED VOC REDUCTION APPROACH SHOULD BE
CONSIDERED AS A SUBSTITUTE FOR OR IN CONJUNCTION
WITH RACT FOR SEVERAL REASONS:

1.   THE  WIDE VARIATION IN CONTROL COSTS AND
    FINANCIAL IMPACTS WITHIN THE INDUSTRY PROVIDES
    AN OPPORTUNITY TO ACHIEVE  SIZEABLE REDUCTIONS
    AND  AVOID  ADVERSE  ECONOMIC  CONSEQUENCES
    THROUGH EMISSIONS TRADING

2.   THE AVAILABILITY OF LOWER COST REDUCTIONS FROM
    OTHER SOURCES PROVIDES AN OPPORTUNITY TO LOWER
    THE OVERALL COSTS OF VOC REDUCTIONS

AT A MINIMUM, THE RACT FOR THE FURNITURE INDUSTRY
SHOULD ACCOUNT   FOR  THE RELATIVE  COSTS AND
CONTRIBUTIONS OF THE INDUSTRY TO THE GOAL OF VOC
REDUCTION
                  n/e/r/a
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Wood Furniture and Kitchen
     Cabinet Industry
Volatile Organic Compound
 Control Technology Study
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Mission Statement

The mission of the Joint Industries Steering Committee is
to participate in the federal Wood Furniture CTG
development process in order to achieve guidelines that:

  • Enhance and improve the environment of the United
   States and the world;
  • Are technically feasible;
  • Are economically justifiable;
  • Do not restrict the future growth and development of
   the United States Wood Furniture and Kitchen
   Cabinet Industries
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Joint Industry Steering Committee
Members
  • American Furniture Manufacturers Association
   (AFMA)
  • National Paint & Coatings Association (NPCA)
  • Kitchen Cabinet Manufacturers Association
   (KCMA)
  • Business and Institutional Furniture
   Manufacturer's Association (BIFMA)
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Industry Characterization

  • Detailed Survey of 160 Industry Facilities
     - Provided Industry-wide Technical and Economic Data
     - Used as Basis for Development of Model Plants
  • Facility Technology Demonstrations and Site
   Visits
     - Visited 24 Facilities
     - Provided On-Site Observations and Analyses of
      Technologies
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  ndustry Characterization (cont)


    • Industry Experts

       - Provided confirmation/refinement to model plant
 ,       characterizations
^      - Collective Knowledge of Actual Conditions at Hundreds
        of Facilities
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Development of Representative Model
Plants

  • Defined 12 Model Plants to Cover Industry
   Characteristics
  • Grouped Survey Responses into the 12 Model
   Plant Categories for Characterization
  • Augmented Survey Data with Site Visits and
   Industry Expertise
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JISC Model Plants
Considerations:
  • Industry Complexity Does Not Lend Itself to
   Simple Characterization
  • Complex Finishing Systems Driven by Consumer
   Demand for Product Quality and Aesthetics
  • Many Coatings with Varying VOC/Solids Contents
  • Multiple Substrates with Differing Properties
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'.J
JISC Model Plants (cont.)

  • Heat and Water Sensitive Substrates
  • Coatings Sensitive to Variations in Temperature
   and Humidity
  • Multiple VOC Emission Points
  • Varying Price Points of Goods Produced
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Model Plants -- Key Parameters

  • Finishing Schedule (No. of Coats and Type)
  • Type of Wood Substrate, Production Line, and
   Product Produced
  • Annual Usage of Each Coating
  • Number/Flow Rate of Spray Booths and Drying
   Ovens
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Model Plants -- Key Parameters (cont.)v

  • Production Rates/Line Speeds
  • Annual VOC Emissions
  • Number of Employees
  • Number and Type of Spray Guns/Roll Coaters
  • Number of Pumps
  • Coating Storage Method
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Control Technologies Evaluated
  • Recuperative Thermal Incineration
  • Regenerative Thermal Incineration
  • Fixed Bed Catalytic Incineration
  • Fluidized Bed Catalytic Incineration
  • Carbon Adsorption
  • Carbon Adsorption/Incineration
  • Full Waterborne Coating System
  • Hybrid Waterborne Coating System
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Control Technologies Evaluated (cont.)
  • UV Curable Coatings
  • UNICARB® System
  • HVLP Spray Guns
  •Terr-Aqua UV/AO
  • Sunkiss Ovens
  • Mobile Zone Spray Booths
  • Recirculating Spray Booths
  • Air Curtain Spray Booths
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Engineering Limitations for Certain Control
Technologies

  • Reduced Flow by Air Recirculation
     - Not Generally Applicable to All Segments of the Industry
     - Limited Actual Use in Industry Facilities
     - OSHA and Insurance Considerations
  • Reduced Flow by Air Curtain
     - Developing Technology, not Commercially Available
     - OSHA and Insurance Considerations
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Engineering Limitations for Certain Control
Technologies (cont.)

 • Full Waterborne Technology for Long Finishing
   Sequences
     - Technical Problems in Meeting Quality Specifications
     - Not Commercially Demonstrated for These Types of
     Finishes
 - UNICARB® for High Speed Lines and Stains
     - Technical Problems in Delivering Sufficient Coating Volumes
     - Slower Evaporating Solvents Require Longer Drying Time
     - Commercially Available for Topcoats and Sealers Only
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Engineering Limitations for Certain Control
Technologies (cont.)
  • Mobile Zone Spray Booths
     - Developing Technology, not Commercially Available
  • Terr-Aqua UV/AO Oxidation
     - Developing Technology, Requires Further Study
  • Sunkiss Ovens
     - Does Not Achieve Sufficient VOC Reduction to be
      Considered a Control Technology
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c:n
Control Technology Evaluation

Determined Capital and Annual Costs for Potentially
Feasible Controls
  • Add-On Emission Controls
     - Catalytic Incineration (fixed bed and fluidized bed)
     - Thermal  Incineration (recuperative and regenerative)
     - Carbon Adsorption
     - Carbon Adsorption/Incineration
  • Application Methods (Transfer Efficiency)
     - HVLP Spray System (slower lines)
     - Roll Coating
     - UNICARB® (slower lines)
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Control Technology Evaluation (cont.)
   Reformulation
     - Hybrid Waterborne Systems
     - Full Waterborne Systems
     - UNICARB® Finishes
     - UV Cured Finishes
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 Potential Mass VOC Reductions Available
 (Plant-Wide)
•'.J
Control Technology
Industry as Whole
Spray Techniques:
HVLP
UNICARB®
2-15%
8-33%
Reformulation:
Hybrid Waterborne
Full Waterborne
UV Cured
28-61%
60-75%
42-80%
Add-On Controls:
Incineration
Carbon Adsorption
Carbon Adsorption/Incineration
3-86%
3-86%
3-79%
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Problems with Add-On Control Equipment

  • High Capital/Operating Costs
  • High Energy Demand
  • Secondary Environmental Impacts
  • Skilled Labor to Operate Equipment
  • Gas Pretreatment Required
  • OSHA, Safety and Insurance Considerations
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	EIKR
Problems with Waterborne Coatings
  • Production Line Color Control with Waterborne
   Stains
  • Sags and Film Thickness on Vertical Surfaces
  • Repairability
  • Ease of Application/Drying Time
  • Sensitivity to Temperature/Humidity Changes
  • Print Resistance
  • Rubbing Characteristics (Layering)
  • Appearance (Clarity/Color)
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Problems with UNICARB®/UV
   UNICARB®:
   •  Developing Technology
   •  Available Only for Sealer/Topcoat
   •  Restricted to Slower Line Speeds
   UV:
   •  Applicable to Limited Industry Segments
   •  Casegoods Technology Still Under
     Development
   •  Difficult to Repair
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Costs of Alternative Controls


  • Evaluated 11 Control Technologies for the 12
   Model Plants

  • Developed Capital Costs, Annual Costs, Cost
   Effectiveness Following OAQPS Guidelines
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Capital Costs of Alternative Controls
Control Technology
Industry as Whole
Spray Techniques:
HVLP
UNICARB®
$400/HVLP Gun
$75,000 -$21 0,000
Reformulation:
Hybrid Waterborne
Full Waterborne
UV Cured
$165,000 -$1,005,000
$286,000 - $1 ,030,000
$98,000 - $1 ,005,000
Add-On Controls:
Incineration
Carbon Adsorption
Carbon Adsorption/Incineration
$163,000 - $1 ,026,000/booth
$312,000 - $673,000/booth
$419,000 - $885,000/booth
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Annual Operating Costs of Alternative
Controls
Control Technology
Industry as Whole
Spray Techniques (Negative Numbers Indicate Cost Savings):
HVLP
UNICARB®
($51, 000) -$2,000
$25,000 - $470,000
Reformulation:
Hybrid Waterborne
Full Waterborne
UV Cured
($163,000) -$547,000
($166,000) -$300,000
$95,000 - $1 ,222,000
Add-On Controls:
Incineration
Carbon Adsorption
Carbon Adsorption/Incineration
$103,000 - $321,000/booth
$68,000 -$170,000/booth
$106,000 - $223,000/booth
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 Cost Effectiveness of Alternative Controls
Control Technology
Industry as Whole
Spray Techniques (Negative Numbers Indicate Cost Savings):
HVLP
UNICARB®
($2,100)-$1,800/ton
$2,100-$9,400/ton
Reformulation:
Hybrid Waterborne
Full Waterborne
UV Cured
($500) - $1 1 ,500/ton
($400) - $8,600/ton
$800-$15,800/ton
Add-On Controls:
Incineration
Carbon Adsorption
Carbon Adsorption/Incineration
$1 ,500 - $87,300/ton
$1,300-$44,100/ton
$1 ,400 - $63,500/ton
••-J
C75
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Additional Issues

  • Units of VOC Limits
  • Multiple Levels for Various Industry Segments
  • Phased Implementation of Developing
   Technologies
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Technical-Economic Analysis  Interface
       ENSR
        Technical Feasbility

        • Evaluate Controls
        • Evaluate Capital and
         Annual Operating Costs
NERA
 Economic Feasibility

 • Identify Least Cost Controls
 • Estimate Financial and
  Employment Impacts at
  Plant and Industry Level
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    November 8,  1991


    Mr. Bruce  C.  Jordan
    Director,  Emission Standards Division  (MD-13)
    Office of  ftir Quality Planning and Standards
    U.S. Environmental Protection Agency
    Research Triangle Park,  N.C.  27711


    Dear Mr. Jordan:

         Subject:   Comments on Draft Chapters  1-4  of the Control
                    Technique Guidelines  (CTG)  for  Control of Volatile
                    Organic Compound Emissions  from Wood Furniture
                    Coating Operations


    We have seven  (7)  plants that will be  affected by the final
    outcome of the control techniques guidelines.   While we are
    optimistic that  source reduction of VOCs will  be one of the
    options in the CTG and one which we can ultimately achieve, we
    are concerned  about the model plant parameters that will be used
    to determine  the  cost of add-on controls.

    Specifically  refer to page 4-3 of the  draft  CTG,  model plant no.s
    2 and 5, and  read the exhaust rates for those  two (2) plants.
    These residential  furniture models are assumed to exhaust the
    same amount of air even though one finishing sequence is twice as
    long as the other.   The short finishing sequence represents six
    (6) finishing  steps which would reasonably correlate to six (6)
    spray booths  while the long finishing  sequence represents twelve
    (12) finishing steps which would reasonably  correlate to twelve
    (12) spray booths.   The exhaust rates  for the  long sequence could
    reasonably be  expected to be twice as  high as  the exhaust rates
    for the short  sequence.

    The use of the above-mentioned exhaust data  will result in
    inaccurate cost figures for those model plants since the cost of
    add-on controls is largely a function  of size  determined by air
    flow rates.   In order to effectively accomplish what you have set
    out to do  you  would need to look at the exhaust rates for the
    long and short  sequences of the model  plants separately.

    We are also concerned about the comments addressing  the
    potential  for  booth enclosure,  especially without the advantage
    of your including  a visit to a residential furniture
    manufacturer.  Due to the number of surfaces that must be coated
    a  worker does  not  merely stand to finish a piece of assembled

Thomasvillc Furniture Industries, Inc.  • P.O. Box 339 • Thomasville, North Carolina 27361  • 919472-4000
                                 P- f* r>
                                 •>' • O J
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Thomasville Furniture Industries, Inc.
Thomasville, North Carolina
    residential furniture  as indicated  in  the  document on  page  3-23.
    The  worker moves on  the  line with the  piece.  Further enclosure
    would  probably be possible but with drastic changes in
    product i on.

    Finally,  it would have  been desirable  to have the draft  of
    Chapter  5 prior to the  NftPTAC meeting.  Mary Jane Clark  in  OAQPS
    has  indicated that the  comment period  following the meeting will
    probably  be two (2)  weeks.   fis it stands we will have  limited
    time for  review and  comment on what may be the most critical part
    of the document.

    Your consideration of  these matters will be greatly appreciated.
    Sincer
    Sherry  Stookey,  Supervisor
    Environmental Compliance
    cc:   Larry Belton
          George Griffin
          Dan  Little
          Jim  Johnson
          Carlyle Nance
          Charley O'Brien
          Dave Masters
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                     AUTOMOBILE REFINISHING
                   CONTROL TECHNIQUES GUIDELINE

                   Presented by: Darcy Campbell
                       Radian Corporation

     The full text from the Environmental Protection Agency's
(EPA's)  presentation of the draft control techniques guideline
(CTG) is provided below.   Following that is a summary of the
questions and discussion that occurred with the National Air
Pollution Control Techniques Advisory Committee (NAPCTAC) after
EPA's presentation.
INTRODUCTION

(Slide 1)
     I would also like to introduce Ellen Ducey, the EPA's Lead
Engineer on this project.
     The facilities covered under this CTG repair and/or refinish
automobiles, vans, motorcycles, and light- and medium-duty
trucks.  Heavy duty trucks are currently covered by another CTG
that EPA developed for Miscellaneous Metal Parts.
     "Shops" are defined as:
        independently-owned shops that repair collision damage
     and do some complete repainting,
        shops at car dealerships that repair transportation
     damage and collision damage that occurs after a car is sold,
     and
        production shops that specialize in complete repainting
     rather than collision repair.
     The definition also includes any facilities that repair new
vehicles damaged in transit.

(Slide 2)
     I will first discuss the refinishing process, along with the
volatile organic compound (VOC) sources.  I will then discuss the
VOC control methods that have been evaluated in terms of their
emission reductions and costs, present the results of our
regulatory analysis, and discuss the implementation of a
regulation for this industry.

(Slide 3)
     Estimates of the number of body shops in the U.S. vary.  We
estimate that there are roughly 63,000.  Extrapolating by
population, there are roughly 30,000 shops in nonattainment
areas.  Taking into consideration the existing State and local
regulations already in place in Texas, New York, New Jersey, and
-------
California, we estimate that about 100,000 tons of VOC's are
emitted each year from body shops in nonattainment areas.


THE REFINISHING PROCESS

(Slide 4')
     Surface preparation refers to the removal of dirt, wax,
grease and silicone.  Surface preparation products are used
whether a replacement part is painted or the existing finish is
sanded off.
     Several different types of coatings are used in refinishing.
"Primers" are any coatings applied before the topcoat.  Types of
primers include pretreatment wash primers, precoats, primer
surfacers, and primer sealers.  Topcoats determine the final
color of the refinished area.
     Many shops apply coatings in some type of spray booth.  Each
coating is applied to a certain "dry film thickness," which is
expressed in mils, or one-thousandths of an inch.
     An important consideration in the refinishing process is
matching the existing car color.  This is a very complex problem
because there are so many car colors, and more new colors are
introduced every year.  For example, one car manufacturer alone
can introduce 20 new colors each year, and have a total of 70
colors for cars in a given model year.  Refinishing is also made
difficult because topcoats applied by original equipment
manufacturers (OEMs) may be complex two-, three-, or even five-
stage products.
     Additives and specialty coatings are different from the
other coatings.  They are used in small amounts as needed for
easier repair and less customer dissatisfaction.
     After the refinishing process, spray equipment is cleaned
with solvent to remove the paint so the gun can be used again on
another job.


EMISSION CONTRIBUTIONS

(Slide 5)
     Emission contributions shown on this slide have been
estimated using "model" shops, which will be discussed in more
detail later.  As you can see, the majority of emissions are from
application of coatings.  Equipment cleaning contributes
9 percent of the VOC's, additives and specialty coatings
5 percent.  Three percent of emissions are from surface
preparation.  For our purposes, coating emissions begin with
spraying; any emissions that might arise from the mixing process
were not considered.
                            966
                                2
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REGULATORY ANALYSIS

(Slide 6)
     Eight model shops were developed to analyze emission
controls.  They were used to establish a common basis by which to
calculate a baseline and the impacts of any recommended control.
The mode'l shops were developed from information in trade
journals, and from discussions with industry and State agency
representatives.
     Our model shops represent the diversity of the industry.
Shops are delineated by size, equipment, and types of coatings
used.

(Slide 7)
     The model shop size is reflected by the number of employees
and number of jobs.  Anything less than painting an entire car is
considered a "spot" or "panel" repair, and is shown here as a
partial job.
     The information we gathered from trade journals helped us
delineate shops B through H.  Based on discussions with industry
representatives, we added shop A to represent very small shops.
Eighty percent of the model shops are medium-size, with a large
range in the number of jobs they do each year.  Model Shop H
represents the large national chains that have more than 10
employees and a large portion of their work is full jobs.

(Slide 8)
     The model shops have different types of equipment.  Model
Shops A and B represent the smallest shops, which are assumed not
to invest in much equipment.  They do not have gun cleaners or
spray booths.  The other medium-size shops (besides B) are
distinguished by the variety of equipment they have.  Shop C has
a gun cleaner, D has a crossdraft booth, E has both, F has a
downdraft booth, and Shops G and H, the largest shops, have
invested in the most equipment: they use gun cleaners and
downdraft spray booths.
     A distinction is made between crossdraft and downdraft
booths because downdraft booths cost twice as much, and
reportedly produce a much higher quality paint job.
     The combinations of equipment present in the model shops
were developed based on national estimates of the percent of
shops that use this equipment.

(Slide 9)
     The model shops use different types of coatings.  Lacquer is
the easiest to use and the most "forgiving" type of coating.  It
dries quickly and is buffed after drying to remove dirt and dust.
However, it results in the lowest quality finish in terms of
durability.
     Enamels and urethanes dry more slowly because they have
lower VOC levels and higher solids contents, resulting in lower
VOC emission potentials than lacquers.  Because they dry more
slowly,  it is more important that the painting area be as clean
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as possible.  Enamels vary in their finish quality:  there are
low-quality and high-quality enamels.  Urethanes produce the
highest quality finish in terms of gloss, and are the most
durable.

(Slide 10)
     Model Shops A and B use a large percent of lacquer coatings
because they do not have any kind of spray booth.  It is possible
that these shops also use urethane coatings, but in our analysis
we assumed that they only use lacquers and enamels.
     Shops C, D, E, and F use all three types of coatings in
different combinations.  Shops G and H use mostly high-quality
urethane coatings.
VOC CONTROL OPTIONS

(Slide 11)
     To identify VOC control options for this industry, we
surveyed the industry, reviewed published literature and existing
State regulations, and met with several industry representatives
to identify control options.  We then used model shops to
determine emission reductions achievable through the use of these
control options.
     Surface preparation emissions can be reduced by using
products that have lower VOC levels.  Coating application
emissions can be reduced by using coatings with lower VOC levels,
whether they are higher in solids or waterborne rather than
solventborne.  The results of our survey indicated that in most
cases this industry now tends towards higher solids rather than
waterborne coatings.
     Add-on control devices could also be used to control coating
emissions.  Add-on controls are not currently used by any shops,
but they were evaluated because they are used in many other
industries that spray-apply coatings.  An add-on control device
would control emissions from all operations that take place in
the booth.
     Emissions from equipment cleaning can be reduced by using
gun cleaners that minimize evaporation and recirculate the
solvent for several cleanings rather than manually cleaning the
spray equipment.  If a gun is cleaned manually, solvent may be
sprayed through the gun either into the air or into a container
from which it is allowed to evaporate.  With a gun cleaner,
solvent is drawn by suction through the spray guns after they are
attached to hose connections.  The outside of the gun is then
either rinsed manually or automatically, depending on the type of
gun cleaner.  In our evaluation of gun cleaners, we found that in
general they can be divided into two groups: enclosed cleaners
with lids that are shut during the cleaning cycle, and open
cleaners that have no lid.
     Finally, making sure that shops properly dispose of their
waste solvent would further reduce evaporative emissions.


                            968 4
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SURFACE PREPARATION

(Slide 12)
     Emissions from surface preparation products can be reduced
through the use of waterborne rather than solventborne products.
Waterborne products have VOC levels below 1.7 pounds per gallon.
These prbducts are somewhat harder to use than conventional
products because they are more labor intensive and it takes
longer to clean the surface.  They are currently required in
California and Texas.
     Low-VOC products reduce emissions from surface preparation
by 75 percent.  The cost increase is about $5 per gallon, or $1
per full job.
COATINGS

(Slide 13)
     Industry reports that they are actively developing lower VOC
coatings in response to State regulations.  We surveyed the six
major coating manufacturers in the summer of 1990 for information
on their lower VOC coatings.  We asked them to list any
limitations with the use of these products, especially problems
with topcoat color matching.  Color matching is of continuing
concern because a painter may have to repaint a larger area if he
has trouble making the refinish color look the same as the
existing color.  If the color match is not reasonably good,
painters will have to paint a larger area until they reach some
natural break on the car such as a fender or a door.
     Color matching is so important, and there are so many car
colors, we could not just set limits based on the lowest VOC
primers and topcoats identified in our survey-  Taking into
consideration information provided on color match and product
compatibility, we grouped the lower VOC coatings into two
regulatory options.  It should be noted that VOC emission
reductions are not linear.  If you had a coating with a VOC
content of 6.5 Ibs VOC/gal and you wanted to reduce emissions by
40 percent, you could do so by replacing it with a coating with
6 Ibs VOC/gal.  This is due to the fact that the lower VOC
content coating has more solids in a given volume of paint so
less volume is needed to coat the part.  A coating with 5.5 Ibs
VOC/gal reduces emissions by 60 percent from that of the coating
with 6.5 Ibs VOC/gal.  The VOC levels shown on this slide are all
expressed as Ibs VOC/gal coating, less water.
     The VOC contents of the baseline coatings were derived from
the model shops7 use of lacquers, enamels, and urethanes; the
high end reflects greater lacquer use and the low end reflects
more use of urethanes.
     Option 1 coatings are currently available to shops.  We
think that they are widely used because they are not very
different from baseline or existing technology coatings.  We
think there are no color match limitations associated with the
                           969
                                5
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use of Option 1 topcoats.  They do, however, eliminate the use of
essentially all lacquers.
     The Option 2 VOC levels are more stringent.  Coatings with
these levels were reported by at least one company that responded
to the survey.  We have already received some comments that the
Option 2 limits will be difficult to meet, and I think we will
hear more about this in some industry presentations.
     Compared to the baseline, emissions from coatings would be
reduced 35 percent if all shops used Option 1 coatings, and
55 percent if all shops used Option 2 coatings.  The biggest
emission reductions come from the smaller shops that are assumed
to currently use large quantities of lacquers.

(Slide 14)
     With Option 1, the smallest shop can reduce its coating
emissions by 50 percent, or 0.4 tons.  The largest shop reduces
its emissions by 20 percent, or 2.5 tons.
     The cost increases shown here are the incremental paint
costs only and do not include any additional labor or equipment
costs that might be incurred.  There is no cost increase for the
largest shops with the Option 1 coatings because they already use
coatings with low VOC levels.  With Option 2, the smallest shop
can reduce 60 percent of its coating emissions, and the largest
shop can reduce 45 percent of its emissions, or 5 tons per year.
The increased paint costs for Option 2 represent a 9 percent
increase per full car for the smallest shop and a 6 percent
increase for the largest shop.


ADD-ON CONTROLS

(Slide 15)
     For add-on controls, we evaluated catalytic incineration,
carbon adsorption, and biofiltration.  We only evaluated add-on
controls for the largest model shop, where the use of these types
of controls is most feasible because of its high volume of work.
If the spray booth is in relatively constant use> then add-on
controls are more affordable.
     With biofiltration, the spray booth exhaust is passed
through material that contains microorganisms that convert the
VOC's to carbon dioxide and water.  Even though this is only in
the developmental phase in this country, it may be the best add-
on for this industry because it reportedly can function even with
periods of non-use and with low solvent air streams.
     We will continue to investigate the use of add-on controls
for this industry, especially biofiltration.  In particular, we
will investigate whether overseas shops use any type of add-on
control.
                            970
                                6
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ADDITIVES AND SPECIALTY COATINGS

(Slide 16)
     Our analysis indicated that the best way to control
emissions from additives and specialty coatings is to limit their
use rather than require reformulation or discontinuation of their
use.  The use of these products probably prevents some VOC
emissions because a painter can prevent some surface defects from
occurring, and can better blend the new paint into the old
without having to paint a larger area.  These products also
prevent having to repaint areas because of problems such as a
coating flaking off from a refinished bumper.
     Limiting the use of additives and specialty coatings to less
than 5 percent of all coatings also closes the potential loophole
of shops identifying a product as a "specialty coating" and then
using a high volume of it.


GUN CLEANERS

(Slide 17)
     To reduce emissions from gun cleaning, it is recommended
that shops use a gun cleaner rather than manually cleaning their
spray guns.  Based on comments we have received to date, I think
we will be hearing more about the gun cleaning issue in later
presentations.
     Closed gun cleaners are required by some States.  We were
also going to suggest that States require their use until we saw
the results of an independent study that indicates that there is
a large range in the sum of the active and passive VOC losses
from closed gun cleaners.  Some models are not efficient in
controlling evaporation.  The study showed that open gun cleaners
have evaporative losses as low or lower than closed gun cleaners.
Gun cleaner manufacturers are researching ways to further reduce
VOC losses, which may make closed gun cleaners preferable in the
future, especially because from an environmental standpoint a
combination of the two types of gun cleaner designs would
probably be best.
     The primary benefit of a gun cleaner is that roughly 10 guns
can be cleaned with the same amount of solvent that would be used
to clean 1 gun manually.  In terms of emission reductions, this
translates to about an 88 percent reduction in gun cleaning
emissions for a shop that installs a gun cleaner.  This amounts
to an annual emission reduction of 0.2 tons for the smallest shop
and 1 ton for the largest shop that does not already have a gun
cleaner.
     Costs range from $36/year for the smallest model shop to a
cost savings of $800/year for the largest shop because of the
money it saves on solvent purchases.
                            9717
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SUMMARY

(Slide 18)
     The costs and emissions given in this presentation are for
the 30,000 shops in nonattainment areas, and take into
consideration existing State regulations.
     Surface preparation emissions can be reduced by 1600 tons at
a cost of about $2200 dollars per ton.
     An emission reduction of 25,000 tons would result from the
use of Option 1 coatings,' at a cost of $59 million.  The use of
Option 2 coatings would result in an emission reduction of 53,000
tons at a cost of $122 million.  Both options represent a cost of
about $2300 per ton reduced.
     Option 2a is Option 2 coatings used by all shops except H,
which uses carbon adsorption.  Emissions are reduced by 68,000
tons per year at a cost of $292 million.
     The use of gun cleaners results in a national cost savings
because shops will have to purchase less solvent.  The smallest
shops, however, would bear a total national cost of $80,000
because the value of solvent saved would not completely offset
the cost of the gun cleaner.
IMPLEMENTATION

(Slide 19)
     We recommend the following requirements for States
implementing a regulation on the automobile refinishing industry:
        For lower VOC surface preparation products, a State would
     use an operational standard that requires shops to use
     products with VOC levels below 1.7 Ibs per gallon cleaner;
        An operational standard would also be used to require the
     use of lower VOC coatings;
        An equipment standard would require the use of a gun
     cleaner that recirculates solvent, collects spent solvent,
     minimizes evaporation, and meets fire safety and
     occupational safety and health codes.
Most requirements would be enforced by recordkeeping:
        Shops would be asked to maintain records on the number of
     jobs they do, the VOC content and amount of surface
     preparation product they use, and the amount of coating,
     catalyst, and reducer used and their mix ratio; and
        Shops would also be asked to record the VOC content of
     the coating, as applied, less water.
     A shop would know the VOC content if the VOC content was
provided by the manufacturer along with the coating; we will
include a section in the CTG on how shops should get this
information, whether it be given through the "as supplied" and
"as applied" VOC levels on labels, material safety data sheets,
the microfiche provided with mixing machines, or some type of
separate "Application Guide."
     For gun cleaners, compliance would be determined by having
shops maintain records of the amount of replacement solvent they

                           972R
                                o
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use per month and-documentation of the amount of waste solvent
transferred to waste treatment facilities.
OTHER APPROACHES

(Slide 20-)
     Some other "nontraditional" ways to reduce VOC emissions
from body shops that are discussed in the CTG and that may have a
big impact on this industry are some pollution prevention and
market incentive measures.   The EPA's Pollution Prevention office
is looking into these approaches and plans to evaluate their
impacts on the refinishing industry.
     One example of a pollution prevention measure is for the
U.S. Department of Transportation to raise the minimum standard
for the strength of automobile bumpers so that less damage occurs
in a "fender bender" and less of the vehicle has to be repainted.
     Educating consumers about the costs of the more complex
coatings, and showing them that they pay more for these coatings,
may cause car manufacturers to reduce the complexity of topcoats.
     As long as there are an infinite number of colors available
for new cars, there will be a continuing impact on the
refinishing industry.  It is possible that setting a VOC limit on
refinish coatings may make it impossible to color match some OEM
colors.
     We are suggesting that States establish a permitting program
that would help locate shops, and States could use this type of
program to push the industry to be more aware of measures it can
take to reduce VOC emissions.
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    CONTROL
  TECHNIQUES
    GUIDELINE
       Control of
Volatile Organic Compound (VOC)
      Emissions from
Automobile Refinishing Operations
 NAPCTAC Meeting Presentation
       November 1991
         974
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 AUTOMOBILE REFINISHING
OUTLINE OF PRESENT A TION

  • Description of Process

  • Sources of Emissions

  • Regulatory Analysis
   - Control Options
   - Costs

  • National Impacts

  • Implementation
             975
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   CONTRIBUTION TO
    VOC EMISSIONS
-63,000 body shops in the U.S.
-30,000 located in nonattainment areas
Approximately 100,000 tons per year of
VOC's emitted in nonattainment areas
         9763
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       DESCRIPTION OF
   REFINISHING PROCESS
1.  Prepare surface
2.  Apply coatings
   - pretreatment wash primers
   - precoats
   - primer surfacers
   - primer sealers
   - topcoats
   - additives and specialty products

3.  Clean Equipment
             977
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            SOURCES OF VOC EMISSIONS IN
               AUTOMOBILE REFINISHING
 Coating Application
    83%
GD
en
                                                 Equipment
                                                 Cleaning
                                                   9%
                                              Additives and
                                            Specialty Coatings
                                                 5%
                                           Surface Preparation
                                                3%
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REGULATORY ANALYSIS
Eight model shops
Delineated by
-  Size
-  Equipment
-  Types of Coatings
         979
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Shop
Size
Small
Medium
Large
Model
Shop
A
B
C
D
E
F
G
H
Percent
of Shops
10
14
5
10
39
7
5
10
Number of
Employees
<5
5-10
5-10
5-10
5-10
5-10
5-10
>10
Number of
Jobs/Month
Partial
12
29
42
62
83
75
104
62
Full
1
1
2
2
4
8
8
50
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EQUIPMENT
Model
Shop
A,B
c
D
E
F
G,H
Gun
Cleaner

X

X

X
Booths
Crossdraft


X
X


Downdraft




X
X
  981 e
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COATINGS
Type
Lacquer
Enamel
Urethane
VOC Emission
Potential
High
Varies
Low
Finish Quality
Low
Varies
High
  S829
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                     TYPES OF COATINGS
   100
c
0)

o

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    VOC CONTROLS FOR
    EMISSION SOURCES

Surface Preparation
   - Use detergent rather than solvent


Coating Applications
   - Lower VOC coatings
   - Add-on Controls
Equipment Cleaning
   - Automated Gun Cleaners
-------
 CONTROL OPTION FOR
SURFACE PREPARATION
 Reformulation to Lower VOC products
 - Baseline:    6.4 Ib VOC/gal cleaner
 - Lower VOC:  1.7 Ib VOC/gal cleaner


 Emission Reduction
    25 Ibs/yr   —> 600 Ibs/yr
 (smallest shop)   (largest shop)


 Increase in Materials Cost
    $5/gallon ($1/fuil car)
           985
12
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    CONTROL OPTION FOR
   COATING APPLICATIONS
 REFORMULATION*
Coating
Type
Pretreatment
Wash Primers
Precoats
Primer Surfacers
Primer Sealers
Topcoats
Baseline
Technology
6.5
6.5
4.8 to 5.7
4.6 to 5.6
5.2 to 6.0
Overall Emission Reduction
Option 1
6.0
6.0
3.8
4.6
5.2
35%
Option 2
5.5
5.5
2.1
4.6
4.5
55%
*lb VOC/gal, less water
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   EMISSION REDUCTIONS
          AND COSTS
Option 1
   Emission reduction
      0.4tons/yr   —> 2.5tons/yr
    (smallest shop)   (largest shop)

   Increase in materials cost
      $9/full car  —>  $0/full car
    (smallest shop)   (largest shop)
Option 2
   Emission reduction
      0.5 tons/yr   —>  5 tons/yr
    (smallest shop)   (largest shop)

   Increase in materials cost
      $25/fuilcar   —> $17/fullcar
    (smallest shop)   (largest shop)
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   CONTROL OPTIONS FOR
   COATING APPLICATIONS
ADD-ON CONTROLS

  • Evaluated for Largest Model Shop Only


  • Catalytic Incineration
   -  Emission Reduction:
     from 11tons/yr to 0.6 tons/yr
     (reduces 95% of coating application emissions)
   -  Cost: $155,000/yr

  • Carbon Adsorption
   -  Emission Reduction:
     from 11 tons/yr to 1 ton/yr
     (reduces 90% of coating application emissions)
   -  Cost: $66,000/yr

  • Biofiltration
   -  Emission Reduction:
     from 11 tons/yr to 1 ton/yr
     (reduces 90% of coating application emissions)
                  15
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     ADDITIVES AND
 SPECIALTY COATINGS
Include uniform finish blenders, adhesion
promoters, elastomeric materials, gloss
flatteners, and anti-glare/safety coatings

Necessary for unusual performance
requirements

Used in relatively small amounts to
improve or impart desirable properties

Recommend limiting use (<5 percent of
coating use by volume) and VOC content
(<7lbs VOC/gal, as applied)
             16
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  CONTROL OPTION FOR
  EQUIPMENT CLEANING
• Use gun cleaning equipment designed to
 reduce solvent consumption and
 evaporation

• Emission Reduction
    0.2 tons/yr  —>  1 ton/yr
  (smallest shop)    (largest shop)
 Costs
    $36/year  -
  (smallest shop)
Savings of $800/year
   (largest shop)
              17
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VOC EMISSIONS AND COSTS IN
    NONATTAINMENT AREAS*

Surface
Preparation
Coating
Applications
Option 1
Option 2
Option 2a**
Gun
Cleaning
Baseline
(tpy)
2,400
88,500
9,000
Emission
Reduction
(tpy)
1,500
25,700
53,500
68,500
5,500
Total
National
Costs
(million $/yr)
$33.35
$59.20
$122.00
$292.00
Savings***
Cost
Effectiveness
($/ton VOC
removed)
$2,230
$2,300
$2,280
$4,260
—
'Takes into account existing State and local regulations.

**Add-on control for Model Shop H (Carbon Adsorption).

'"Costs of $81,000 would be borne totally by small shops. Larger shops save
money by using a gun cleaner with national cost savings of approximately
$375,000/yr.
                99118
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IMPLEMENTATION/RECORDKEEPING
    Control
   Technology
      Type of
     Standard
   Recordkeeping
 Lower VOC Surface
Preparation Products
Operational (process and
   material change)
- Amount used
- VOC content of product
- Labeling
Lower VOC Coatings
Operational (process and
   material change)
- Volume of coating,
catalyst, and reducer used
- Mix ratio
- VOC content of coating
- Labeling
  Add-on Controls
     Emission
                                    - Performance records
   Gun Cleaners
     Equipment
- Amount of replacement
solvent used
- Amount of waste solvent
removed
- Documentation of proper
disposal
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 OTHER APPROACHES
Decrease Collision Damage

Educate Consumers
- Cost of "Glamorous" Coatings
- Repair Costs
- Insurance Costs

Permitting Shops
- Identifies Shops
- Require Training
          9S32Q
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COMMITTEE DISCUSSION ON EPA PRESENTATION

     Ms. Mclntire suggested that references to decreasing
collisions and consumer education were beyond the scope of work
of the CTG.  Mr. Berry responded that EPA is supposed to be
giving guidance to the States on how they can achieve emission
reductions.  The EPA is looking at things States can do to
educate consumers, for example, by explaining that since
insurance companies do not inguire as to the color of a car,
those who own cars with glamorous finishes are being subsidized
by those who own cars with less expensive finishes.  The EPA
feels that these recommendations are appropriate.  Mr. Johnson
agreed that these recommendations are within the scope of the
CTG.  Ms. Mclntire agreed on the need for consumer education, but
indicated that it seemed inappropriate to place it in a CTG on
automobile refinishing.  Dr. Pinkerton commented that consumer
education seems like interference.
     Ms. Mclntire suggested that the 5 percent limit for
specialty coatings be for an averaging period longer than a day
because, in some cases, a specialty coating may be the only job a
small shop has for an entire day.
     Dr. Pinkerton inquired on the VOC component from refinishing
activities and whether the VOC's are included in the list of 190
Hazardous Air Pollutants.  Ms. Ducey said some, but not all, are
included.  Ms. Wyatt said that the industry is not on the list of
major sources because the facilities are too small; however, it
is being considered for inclusion as an area source.
     Ms. Mclntire asked how the number of facilities in
nonattainment areas was derived.  Ms. Campbell responded that the
number was population-driven.  Ms. Mclntire suggested that EPA
verify the number.
     Dr. Atkins inquired whether refinishing is driven by the
original equipment manufacturer  (OEM) coating.  Ms. Ducey said  it
-------
is;  colors must be matched,  but the refinishing process uses
different paints because the cure temperature must be much lower.
     Mr.  O'Sullivan asked why there was no mention of transfer
efficiency (TE) in the CTG,  especially if it is more cost-
effective than other control measures.  The EPA responded that it
is an attractive option that will be encouraged, but a
quantitative requirement based on it will not be part of
recommended RACT in the CTG.
     Mr.  O'Sullivan suggested using Options 1 and 2 as a phased
approach.  He questioned whether the cost-effectiveness figure on
slide 18  (for Option 2a) is  average or incremental.  Ms. Campbell
responded that it is average.  Mr. O'Sullivan suggested showing
incremental cost-effectiveness from Option 2 to Option 2a.  He
also commented that the recordkeeping requirements would be tough
for industry and that permitting should be avoided for small
facilities, although perhaps a standard permit could be
developed.
     Ms.  Mclntire hoped that placing VOC limits on products would
not place industry in a bad  position regarding matching colors.
Mr.  Taranto questioned the statement that limiting VOC levels may
make it impossible to match  OEM colors, and whether it might
require that an entire vehicle be refinished rather than just a
portion.   Mr.  Berry responded that the OEMs could always
introduce colors that refinishers can not match, but while OEMs
are trying to go with "snazzier" coats and colors, EPA is
pressing  the other way.   Eventually, designers of original colors
and repair capabilities must come together to strike a balance
between VOC limits and color match.
     A member of the audience asked how odor varied between
Options 1 and 2.   Ms.  Campbell did not know.  The audience member
recommended odor as well as  air toxics control because odor is
the  major source of complaints for body shops.  Mr. Berry
commented that add-on controls can mitigate odors.
-------
     The EPA presentation was followed by six industry speakers.
These presentations are provided below in full text.  After each
industry speaker, NAPCTAC members were provided an opportunity to
ask questions.  These questions and the ensuing discussions are
summarized for each presentation.
                             9S6
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Industry  Presentation #1
                                                              «•,
                                                                   \National
                                                              ^  'Coatings
                           POSITION PAPER                      Association

             OF THE NPCA AUTOMOTIVE REFINISH COALITION

                             CONCERNING

     DRAFT AUTOMOBILE  REFINISHING CONTROL TECHNIQUE GUIDELINE

                           **************

                            Introduction

 The NPCA Automotive Refinish Coalition:  The Automotive Refinish
 Coalition was formed in 1988 under the auspices of the NPCA  to
 work for effective and nationally consistent VOC regulations for
 the automotive refinish industry.

 The active participants in the Coalition are the six national
 manufacturers of automotive refinish paints and coatings:  AKZO
 Coatings, Inc.; BASF Corporation; E.I. du Pont de Nemours; Nason
 Automotive Coatings; PPG Industries, Inc.; and the Sherwin
 Williams Company.  Collectively, these companies account for the
 lion's share of the total volume of automotive refinish products
 that are sold in the United States.  These companies also provide
 the majority of the training that is taken by individuals to
 become proficient in the use of automotive refinish products.
 The six individuals who represent these companies on the
 Automotive Refinish Coalition collectively possess over 150  years
 of experience in the industry.  They therefore are in a
 particularly good position to comment on the industry's products
 and the underlying economics and  operational requirements of
 automotive refinish facilities.

 The Coalition also has as adjunct members a number of trade
 associations that represent user segments of the industry.   While
 the adjunct members generally support the positions taken by the
 six manufacturer members of the Coalition, they have not had an
 opportunity to review this position paper.  Consequently, the
 positions taken should be seen as representing only those of the
 six manufacturers.

 Objective of the Coalition;  The objective of the Coalition  is
 the development  of nationally consistent VOC regulations that
 achieve significant, real and effective reductions in VOC
 emissions from automotive refinish facilities while not imposing
 unnecessary additional costs or losses in productivity on the
 automotive refinish facilities.

 Moving to lower VOC containing products will create enormous
 productivity problems for automotive refinish facilities.  Our


                               997
 1500 Rhode Island Avenue, NW • Washington, DC 20005-5597 • 202/462-6272 • FAX 202/462-8549
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concerns on this score are particularly strong because the
industry has a large population of small businesses.
Approximately 40% of the shops employ less than five individuals
and have sales volume of under $150,000 annually, according to a
1988 EPA study of the industry-

           Effective VOC  Regulations  Must  Recognize and
    Incorporate  Industry's  Practices  and Operational Realities

To achieve the objectives of significant reductions in VOC
emissions from automotive refinish facilities at the least amount
of unnecessary economic disruption to the industry, a regulatory
program must incorporate fundamental technical, operational, and
economic features of the industry.

Achieving Adequate Matching of Repair to OEM Finish:  Achieving
an adequate repair that matches the existing coat so that the
repaired area is imperceptible is the central requirement of the
industry-  Thousands of colors and coatings must be available for
all model years of the various car manufacturers to match the
many different features of thousands of original coatings, such
as their color,  gloss, and durability,  as well as the effects
that time and the elements have had on the OEM color and finish.
All of this must be accomplished at facilities with far less
sophisticated equipment,  under much more difficult and
uncontrolled circumstances than exist at the original equipment
manufacturers' facilities.

Systems Nature of Today's Products;  Today's products are
provided by individual manufacturers in the form of chemically
complex interrelated components to a single system.  The
components of a particular repair system must be used only within
the system of the particular manufacturer and pursuant to the
manufacturer's instructions to ensure that the refinish job will
not fail.

Composite Calculation for Multiple Coat Topcoats is Essential;
The use of multiple coats involving a base coat for color and
clear coats for appearance and protection  as well as in some
cases a midcoat  is the predominate  original equipment
manufacturer (OEM) topcoat system.  The appearance of these OEM
topcoats must be matched by the automotive refinish industry  and
consequently, the industry must use multiple coats in a topcoat
system.
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            Comments Concerning Regulatory Approaches

The RACT VOC Limits of the California Guideline for the Industry
Should be Selected as the RACT Limits for the CTG

The purpose of the CTG is to establish  technology that is the
presumptive norm for "reasonably available control technology"
(RACT) which must be implemented by states in their ozone
nonattainment areas.  EPA has defined (and Congress has accepted)
RACT to mean: "The lowest emission limitation that a particular
source is capable of meeting by the application of control
technology that is reasonably available considering technological
and economic feasibility.  RACT for a particular source is
determined on a case-by-case basis, considering the technological
and economic circumstances of the individual source.  (44 Federal
Register 53761, 53762 (September 17, 1979))

On the basis of this standard — a standard that emphasizes the
economic and technological feasibility of control technologies in
light of technological and economic circumstances of the
sources — the VOC limits that have been established by
California's Air Resources Board's  Automotive Refinish Guideline
for RACT under California's Clean Air Act (which has a much
tougher standard and program for ozone attainment than the
federal law) should be RACT for the national program.  (See
attached chart for the California Guideline RACT limits.)

While the terms "reasonably available" and "feasibility" are not
defined by the EPA, an ordinary dictionary definition of
"feasible" is something that is "capable of being used or dealt
with successfully;"  "available" has been defined in a manner
especially relevant to this discussion as "present in such
chemical or physical form as to be usable;"  and "reasonably"
has among its ordinary meanings "moderate, fair, and
inexpensive."  When the meanings of these terms are coupled with
the requirements of "economic and technological feasibility" and
the additional requirement that the feasibility of the control
technology be ascertained on the basis of the "economic and
technological circumstances of particular sources,"  then
whatever else RACT means, it certainly cannot mean  the
imposition of technology-foreing standards on existing sources.

The California RACT limits have much to recommend them for
adoption in the CTG.

First, by actual implementation in automotive refinish
facilities,  they have been proven to be currently "reasonably
available" and "technologically and economically" feasible.
Second, they have been established by the toughest clean air
program in the country.  In this connection,  we note that the

                                3

                            999
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California Clean Air Act has a much more stringent ozone design
value of .09 ppm  as compared to the federal standard of .12 ppm.

The attached chart represents a comparison of VOC reductions that
could be achieved by implementing the California Guideline's RACT
limits.

According to the Study's Own Findings. Option 1 and Option 2
Limits Are Technology-Forcing Standards; They. Therefore. Are
Completely Inappropriate for the CTG

By the study's own statements, Options 1 and 2 represent
"technology-forcing" VOC limits, requirements that are not
currently "reasonably available" as that term is defined by the
EPA.  Therefore, these options do not qualify as RACT.  Moreover,
if the base coat/clear coat composite calculation method is not
employed, then the limits specified for topcoats under both
Option 1 and Option 2 are not only  "technologically and
economically infeasible" for the "particular sources" of
automotive refinish facilities, they are absolutely impossible to
achieve with today's technology.

The study indicates that lacquer product systems are still widely
used by many of the smaller shops that do not have spray booths.
(See pages  2-7, 2-20 through 2-25 of the study.)  The study also
assumes that such shops constitute  approximately 30% of the
industry.  (See Table 2-1 at page 2-22.)  Moving these shops away
from lacquer products to other more difficult to use and slower
drying products will be difficult and very costly.  The
unmistakable implication of the topcoat limits of Options 1 and 2
is that a large number of the industry's smaller shops will be
put out of business.  The study estimates that the cost of a
spray booth would be approximately $30,000.  We believe that this
estimate is low.  And most of these shops are currently grossing
at most $150,000 per year.  Few if any banks, especially in
today's economic climate, would lend the amounts needed for such
a capital outlay to the smaller shops.  Consequently, topcoat
limits of Options 1 and 2 which would prevent the use of any
lacquer system  do not represent a "currently"  "reasonably
available control technology" as judged on the basis of
"technological and economic feasibility" of these "particular
sources."

The study also states that, "Option 1 VOC limit had the reported
disadvantage of poorly matching OEM colors (especially
metallics), indicating that they are best suited for complete
vehicle refinishing jobs."  (See page 3-4.)  In view of the fact
that the study also finds that the "... the OEMs use metallic and
*pearl' coatings on at least 50 percent of all new vehicles....";
it should be clear that the Option 1 VOC limits do not constitute
"reasonably available control technology" for this industry.
Establishing the Option 1 or 2 limits, according to the study's
-------
own findings and conclusions, would in effect mandate that a
larger proportion of the repairs be accomplished by complete
refinish jobs.  This would necessarily result in the emissions of
more, not less, VOCs and would fail to achieve the fundamental
objective of RACT — achieving reasonable further progress
towards attainment.  Additionally, there is the question of
whether establishing VOC limits that "poorly match OEM colors"
for 50% of the vehicles the industry repairs constitutes a
"technologically and economically feasible" control technology
for an industry that has as its sole reason for being the ability
to make repairs so that the repair is imperceptible.
The study also contains a number of misleading assumptions
concerning the VOC emissions that should be associated with the
industry's products and operations.  The first of these involves
assuming that the VOC content of products that are supplied to
areas which currently have regulations constitute the baseline
"current technology" of the industry's products that are
generally used in the United States.  (See Table 3-1 at page
3-6.)  In fact, the majority of the products supplied by the
manufacturers are to areas for which no VOC limits for their
products exist, including the vast majority of current ozone
nonattainment areas.  Defining baseline technology as the study
does would lead to  a gross understatement of the contributions
in VOC reductions that properly should be attributed to this
industry introducing lower VOC containing products to areas that
heretofore have not required  lower VOC containing products.  The
Act's new requirement for reducing by 15% overall VOC emissions
in the top four categories of ozone nonattainment areas by 1996
will place extraordinary pressures upon all sources to reduce
their fair share of VOC emissions.  Thus it is essential that the
CTG accurately characterize the existing VOC emissions from this
industry in these areas to ensure that it is not tasked with
regulations that exact an unreasonable contribution in VOC
emissions reductions.

Additional misleading statements and assumptions in the study
concern the following subjects:  the statement concerning current
usage of coatings that implies that all coatings material
supplied to refinishers are in fact applied, when approximately
20% — 25% in practice is wastage and is disposed of by
incineration in which there is no release of VOCs; overstatements
of the required or recommended film thicknesses; and
overstatements of the paint consumption in each of the coatings
categories.  These are more fully discussed in the submission
from BASF.

We anticipate the argument that since the  California Guideline
1992 limits are just around the corner and that since some of
these limits are more stringent than comparable limits in Option
1,  the manufacturers should be able to meet the limits of Option
1 nationwide if they can meet the California 1992 VOC limits in
California.  In answer to such an argument, we point out that the
                          1001
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products that are needed to meet some of these limits, especially
the topcoat limit, are still not yet at a stage of development
that would allow the manufacturers to introduce them into
facilities without substantial expenditures in time and
resources.  These products will require the use of spray booths,
which the study itself notes are not widely used by  the smaller
shops which makes up about 30% of the industry.  Moreover they
will require the use of drying equipment, because the products
will be .mostly waterborne products with substantially longer
drying times.  In order to maintain today's levels of
productivity in terms of the number of vehicles that are
completed substantial expenditures for drying equipment will be
required.

Finally there is a question of scale involved here.  It should be
noted that the California 1992 limits will be confined only to
certain air quality districts in California.  While the
manufacturers may have sufficient resources to weather the
problems and expenditures that will be associated with
introducing these products into  a limited number of areas in
California, imposing similar requirements nationwide results in
an effect on the manufacturers that certainly qualifies as
"economically infeasible."

We realize that the EPA is interested in crafting a GTG that
accurately reflects what can  be accomplished by the industry at
the time the CTG is published and that it is confronted with the
difficulty of a moving target in the technologies.  The six
manufacturers have expended literally tens of millions of dollars
thus far in efforts to develop lower VOC products and the EPA is
right to anticipate that these efforts will continue.  But this
problem  of RACT being overtaken by new developments is addressed
in the newly amended federal Clean Air Act which now requires
that the EPA periodically revisit CTGs to determine if technology
has moved ahead of existing CTG standards.  We'suggest that this
is the only appropriate process recognized by the Act for
introducing technology-foreing factors into developing CTGs.
Requiring technology-forcing limits in the CTG itself is
completely at variance with the essential "reasonably available"
nature of a RACT standard.

We have another suggestion by which this current effort to
determine an automotive refinish CTG could avail itself of new
technologies that might be available at the time this CTG is
finalized.  If this CTG development process takes until 1993 to
be finalized, it is possible that the experience gained in
meeting the California Guideline's 1992 limits in California will
demonstrate by then that the Option 1 .limits  and perhaps some of
the California 1992 limits are in fact "reasonably available" in
terms of their "economic and technological feasibility" for
national implementation.  We note, however, that, with respect to
the California 1992 limits, the industry at the present time
                            1002
-------
does not have a sealer that would meet the limit specified for
this coating.  Because of this and other potential problems of
introducing such advanced systems nationwide, at the present we
believe that a lead time for implementing such limits would be
needed, e.g., implementation in 1994 or 1995.

The Necessity of Base Coat/Clear Coat Averaging For Determining
the Topcoat Limits

The multiple coat system of topcoats is the current predominate
topcoat technology of the automotive manufacturing industry and
the refinish industry must be able to match these topcoats.
Using a composite calculation for the VOC content of the base
coat and clear coat in a topcoat system to determine compliance
with the topcoat VOC limit is dictated by the actual day-to-day
"technological and economic circumstances" and practices of the
industry.

A statement of the study which may account for the failure of the
CTG Model Rule to include  a base coat/clear coat composite
calculation method is an apparent misunderstanding  of the basis
for weighting base coats and clear coats at a ratio of 1 for base
coats to 2 for clear coats.  The ratio is based upon the actual
usage of the industry.  It is the industry experience that the
volume of base coat paint that is used for any given repair is
approximately on half the volume of clear coat that is used.  In
this connection we refer you to the information that has been
provided by the BASF Corporation which is based upon the actual
usages at an automotive refinish type of operation at the Saturn
General Motors plant and by the Sherwin Williams Company.   In
fact that experience indicates that the ratio is higher, e.g.,
for 1 gallon of base coat, 2.3 gallons of clear coat are used.
The study assumes that because clear coats are a higher solids
product than are base coats, then the volume of clear coat
material that is needed to repair the are covered by the base
coat should be twice  the volume of base coat material.  The
major reason  that the industry generally uses twice the amount
of clear coat material as it does base coat material is the need
to achieve adequate color and finish match for spot repairs that
requires that the clear coat in general be extended far beyond
the area covered by the base coat.  About 90% of the automotive
refinish work that is done is spot repair.

The Systems Nature of the Industry's Products

Because the chemistry of the individual components of a repair
system is highly interdependent, the components of a particular
manufacturer's system must be used according to its instructions
and cannot be interchanged with the products of another
manufacturer.  The systems nature of today's repair products has
two very important implications for a regulatory system that
limits the VOC content of the products.  First, regulators can
                           1003
-------
have a great deal of confidence that refinishers will not attempt
to match relatively higher VOC components of one manufacturer's
repair systems with those from another and that therefore the VOC
levels associated with a particular system will be complied with.
Secondly, the regulations cannot simply select the lowest VOC
components of the available repair systems and dictate that these
components be incorporated into every repair system.
and in the right amounts.  As a recent article from an automotive
refinishers professional magazine points out:

     [T]here is no margin for error in applying or mixing today's
     products.  The paint, company chemist was able to create a
     product to suit, but only if you do exactly as he says.  Not
     only must the painter combine the correct solvent, catalyst
     and topcoat in the correct percentages, but it must be
     applied over the correctly mixed undercoats at the correct
     time... There is only one  right way to use today's
     finishes; exactly according to directions and using only one
     brand.

Auto refinishers will not act as their own chemists; they will
follow the manufacturers' instructions or risk a failed job
without the protection of a warranty.

Another feature of the industry that supports the conclusion that
automotive refinishers will comply with the VOC limits specified
for products is the VOC compliance instruction material and the
training that is supplied by the manufacturers to users of their
products.

The Need for Specialty Coatings

It also is essential to recognize the need for relatively higher
VOC containing specialty coatings.  These products constitute a
very small percentage of the products used by the industry but
they are essential to effectively accomplishing certain repairs.
An important example of these are  "uniform finish blender"
specialty coatings to make spot repairs.  This specialty coating
blends the repaired area in with the surrounding original finish
to match all facets of its appearance, including color, metallic
orientation, texture, and appearance.  Greater VOC emissions
would occur if refinishers do not have the ability to perform
spot repairs because they would be required to paint an entire
panel of the vehicle or the entire vehicle itself in order to
achieve acceptable results.

We recognize that the model CTG includes the category of
"specialty coatings."  But its characterizing them as being
"reportedly" needed for unusual job performance requirements,
however, concerns us because that implies that the need of these
products is debatable. The special role of specialty coatings
should be emphasized by the CTG.  It should not be implicitly
                            1004
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questioned by the CTG which might invite states to modify the CTG
by removing the category.

We also recommend that the California Guideline's definition of
specialty coatings should be adopted.  The definition does not
limit the type of coatings that can fall into this category but
restricts the coatings to 5% the total volume of coatings applied
by an automotive refinish facility.  This approach allows for the
development of additional specialty coatings and the 5%
restrictions ensures that the category will not be abused.

The General Use of HVLP gpray Guns Results in Significant
Reductions of VOC Emissions and Should be Encouraged

The efficiency of transferring coatings to the vehicles has been
greatly improved by the use of high volume, low pressure (HVLP)
spray guns.  The resulting VOC reductions that accompany the
reduced amount of coatings material that is required because of
the improved transfer efficiency should be explicitly recognized
by the regulations.  To do otherwise deprives this industry of
having credited to it significant VOC reductions that in fact
result from the use of HVLP spray guns.  The unwillingness of the
EPA to explicitly recognize and to credit VOC reductions
associated with the use of the equipment is a hidebound adherence
to notions concerning "quantification" and "replicability" of VOC
emission reductions.  These principles were established for a
regulatory regime that focused on well-heeled and richly staffed
large stationary sources which lent themselves to such precise
demands for crediting VOC reductions.  The 1990 amendments to the
law, however, require the regulation of much smaller sources and
therefore the EPA's  VOC emissions reduction accreditation
principles must be retailored to measure the effectiveness of
regulatory controls that are appropriate for the much smaller
sources.

As the study notes, appropriate training has a great deal to do
with the efficacy of HVLP use.  In this connection,  it should be
recognized that extensive training is provided in this area by
the manufacturers of automotive refinish coatings and others.
Further,  aside from the regulatory requirement to use such
equipment, autorefinish facilities have a very strong economic
incentive to use the equipment to reduce their consumption of
coatings.

It also should be noted here that the study seems to assume a 35%
transfer efficiency for the conventional spray gun but is
unwilling to assume any transfer efficiency for the HVLP.  This
is anomalous in that any problems that are associated with
achieving effective transfer efficiency with the HVLP spray gun,
such as variability in operator use and the shape of the object
being coated, also apply to conventional spray guns.
                           1005
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The experience of the Coalition is that the use of HVLP spray
guns results in reductions of 20% — 45% in materials usage and
some credit for the resultant VOC reductions should be given.

Add-On Controls

The various engineering add-on control technologies identified by
the study for facilities would be cost prohibitive and or
technologically infeasible for the great majority of automotive
refinish facilities to adopt at this time.  Nonetheless, the
regulations should recognize such controls as voluntary
alternative control techniques that could be used in lieu of
lower VOC containing products.  The technology of add-on controls
could improve in the near future, perhaps rapidly,  and they
could come to represent cost-effective alternative compliance
methods.
                            Conclusion

The objective of the CTG is to establish a guideline for what is
the presumptive norm for "reasonably available control
technology" (RACT) under the federal Clean Air Act.  In
developing such a guideline, the "reasonableness" of the
technology is to be considered as well as both its
"technological" and "economic" feasibility.  On the basis of
these criteria and our knowledge of the industry — the available
coatings technology and the operational and economic requirements
of automotive refinish facilities — we believe that the VOC
limits specified for RACT in the California Guideline should be
the limits established by the CTG.  The adoption of these limits
from a program that is much tougher than the federal program will
ensure that the industry contributes more than its fair share of
VOC emissions reductions in the nation's ozone nonattainment
areas.  We also believe that specialty coatings must be
explicitly recognized as an essential technology for the industry
to achieve VOC emissions reductions.  Further, it is absolutely
critical that the multiple coat composite calculation technique
for determining compliance with VOC topcoat limits be recognized.
This is the way the industry applies the topcoats and it is the
only way that VOC limits for increasingly waterborne topcoats can
be met.  The contributions made by HVLP spray guns should also be
recognized by the CTG.  Finally add-on controls should be
recognized as a voluntary alternative compliance method.

The possibility that the Option 1 or even some of the California
Guideline's 1992 VOC limits may be demonstrated to be "reasonably
available" by the time the CTG is finalized in 1993 is also worth
considering.  The six manufacturers would concur in such an
approach provided that before the limits are adopted as part of
the CTG, the technology has in fact been shown to be reasonably
available and that an appropriate lead time is afforded (e.g.,
until 1994 or 1995) to ensure that the products in fact are
"reasonably available."

                                10

                              1006
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DRAFT CTG
COMPARISON OF VOC EMISSIONS REDUCTIONS

                        GARB'S GUIDELINE
Baseline
Coatina Cateaorv VOC*
Pretreatment Wash
Primers & Precoats 6.5
Primer Surfaces 4.8 - 5.7
Primer Sealers 4.6 - 5.6
Topcoats*** 5.2 - 6.0

Surface Cleaning 6.4
Enclosed Equipment
Cleaning 6.7
Specialty Coatings 7.0
Transfer Efficiency 35%
DRAFT CTG
Reduction Achieved -0-
% of
Total Coatings
Option 1 Ootion 2 CTG CARB Coatina Cateaorv
Pretreatment Wash
6.0 .15% 5.5 .31% 2% . 1% Primers
3.8 4.0% 2.1 7.6% 12% . 12% Primer/Primer
Surfaces
4.6 0.9% 4.6 0.9% 5% . 5% Primer Sealers
5.2 7.7% 4.5 14.5% 58% . 17% Topcoats***
Iridescent***
1.7 5.9% 1.7 5.9% 8% . 8% Surface Cleaning
Enclosed Equipment
85% 0.8% 85% 0.8% 10% . 10% Cleaning
7.0 0.0% 7.0 0.0% 5% . 5% Specialty Coatings
35% 0.0% 35% 0.0% . Transfer Efficiency
CARB GUIDELINE
18.6% 30.0% . Reductions Achieved
Baseline CARE'S
VOC RACT
6.
6.
6.
6.
6.
6.
6.
6.
7.
7
7
7
7
7
8
7
7
0
25%


6.5
6.5
6.0
6.0
6.0
6.0
1.7
88%
7.0
45%'

-0-
0
0
2
2
3
8
6
0
2
.1%
.1%
.3%
.3%
.2%
.7%
.0%
.8%
.8%
0.0%

26

.3%
GARB'S
1992 Limits**
6.5
6.5
2.8
3.5
5.0
5.0
1.7
98%
7.0
45%'


0
0
12
4
22
19
6
0
2
.1%
.1%
.6%
.3%
.8%
.5%
.0%
.8%
.8%
0.0%

69
II
.0% |
  *Baseline VOC set on controlled areas emission survey data.  Should be based on uncontrolled emissions  survey data.

**Technology forcing limits that can be added to CTG in 1994 - 1995 once technology has been demonstrated in California  in 1992 -
  1993.

***VOC limits based on composite multi-stage topcoat calculations.
l.*5*/z5x = *••" factors applied to VOC reduction categories in column expect for enclosed equipment cleaning and surface cleaning.
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COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

     Karl Schultzf National Paint and Coatings Association,
Automotive Refinish Coalition  (See attached Presentation  #1)

     Dr. Pinkerton noted that Mr. Schultz's estimate of 40
percent of shops having less than five employees did not  agree
with the CTG's figure of 10 percent.  Mr. Schultz said his
information was from a magazine survey and he thought it  was
accurate.  He suggested that the model shop analysis might
mislead States in that it misrepresents the industry (i.e.,
lacquer use may be underestimated for a given model shop).  He
noted that shops in this industry can not be pigeonholed; for
example, there are very small shops that specialize in high-
quality work.  Mr. Hise noted that if the magazine survey showed
shops with 5 or less employees, then the model shops could match
40 percent because they show a range of employees.  Ms. Ducey
commented that the number of employees is not used in EPA's
analysis, and does not have to be shown in the CTG.
     Dr. Pinkerton asked whether the Coalition agreed with the
estimate of 100,000 tons per year of VOC being emitted from body
shops in nonattainment areas.  Mr. Schultz said he had not seen
that estimate before, but guessed that it was probably close.
Dr. Pinkerton asked what national emission reductions would their
RACT (and 1992 limits) recommendations achieve.  Mr. Schultz said
they had not been calculated.  Mr. Arkell asked why, on the table
Mr. Schultz provided, the percent reductions in emissions with
CARB's 1990 RACT limits and 1992 limits are higher than EPA's
Option 1 and Option 2 percent reductions.  Mr. Schultz responded
that the differences in solids content per gallon paint were not
taken into consideration in their estimates.  The CARB values
take into consideration a TE of 25 percent for both the baseline
and the 1990 limits,  and a TE of 45 percent for the 1992  limits.
                                1
                            1008
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     Mr.  Arkell questioned whether the major factor in the
difference in percent reductions is the use of different baseline
values.   Mr.  Schultz felt that EPA's baseline is based on
controlled limits, and the Coalition's estimated baseline values
are higher.  He strongly disagreed with EPA's figure.  Mr. Hise
asked if the baseline values used by the Coalition were based on
1990 data.  Mr. Schultz said 1988 data were used.  An audience
member commented that the figure was based on sales, not
consumption.   He said the 1990 VOC coating data are not different
from the 1988 data, but sales have fallen.
     Dr.  Atkins asked if Mr. Schultz had said that compliance
with the 1992 GARB rules would require spray booths.  The answer
was yes;  the Coalition recognizes that shops without spray booths
would have difficulty using some coatings and that this will be a
huge adjustment for small shops.
     Mr.  Arkell questioned whether the California rule requires
65 percent TE.  The answer is yes.  Mr. Arkell than commented
that the discussion seems to keep coming back to TE, even though
EPA has said that it is too difficult to quantify.  He suggested
EPA look at it again.  Perhaps a percent reduction credit could
be given for TE.  He also inquired that if EPA can not quantify
TE, how is California doing it.  The response was that they can't
and are working on that problem now.  California recognizes that
it is a difficult problem, but they also know that success would
result in reductions in VOC's.  Mr. Dennison commented that
California defaulted to high-volume low-pressure (HVLP) spray
equipment, and said that other types of spray equipment would
have to demonstrate that they could achieve 65 percent TE.
Subsequently,  manufacturers of other types of spray equipment
have petitioned, and the State has had to defend the 65 percent
TE requirement which relies on a laboratory test procedure.
     Mr.  Schultz noted that another reason for strongly
suggesting that EPA use the California standards is because this
industry  is a  highly spread out, distribution-based industry and
it must have  uniform standards.  A can of paint can be in the
system for 3  to 5 years.  Multiple standards in the U. S. would
                                2
                            1009
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be unmanageable,-and the Coalition feels the California  standard
is stringent enough to be a national standard.
     Mr. Jordan asked Mr. Schultz to clarify whether he  was
recommending that EPA adopt the 1992 California  limits.  Mr.
Schultz responded that the Coalition is recommending that EPA use
the California RACT limits.  The 1992 limits are not "reasonably
available."  The Coalition would support the 1992 limits after
the products have been demonstrated successfully in California.
From a legal standpoint, the Coalition is concerned that if the
CTG becomes law (with the 1992 limits as RACT), and the  limits
are not achievable for all colors, States would not be able to
relax their State Implementation Plan (SIP) requirements.  He
suggested that if the CTG requirements were different from
California's, the coating manufacturers would be forced to
recommend that States ignore the CTG and use California's limits.
     Mr. Berry commented that the definition of RACT that the
Coalition keeps using is not complete.  The RACT does have a
technology-forcing aspect.
     Citing the fact that specialty coatings need a higher VOC
content, Mr. Dennison asked whether the coating manufacturers had
a time frame for reducing the VOC content of specialty coatings.
Mr. Schultz explained that the manufacturers formulate these
products at 7 Ibs VOC/gal for their unique properties and
applications.  If VOC content must be reduced, solids must be
increased and the paint layers could not be applied thinly
enough.  Mr. Dennison asked whether shops vary in their specialty
coating use.  Mr. Schultz replied that 99 percent of shops would
not exceed the 5 percent cap on their use, but there would be
some small specialty shops, such as van-converters, that might
have trouble with the limit.
     Mr. Dennison inquired about the recordkeeping burden.
Mr. Schultz said that the Coalition feels that it would be real
drain for small shops.   The 2-3 hours per day required for
recordkeeping would be unproductive time.  Mr. Dennison  asked
that if EPA did follow California's lead, would manufacturers be
willing to participate in some type of quantification program.

                            1010
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Mr.  Schultz responded that they do already.  The material safety
data sheets (MSDS) show VOC level.  Mr. Dennison asked whether
the MSDS also show VOC content less water.  The response was yes.
     Ms. Sheiman commented that recordkeeping and public
disclosure of emissions (not already done by this industry) might
go a long way in motivating voluntary compliance by shops and
lead to creative ways of reducing emissions.
     Mr. O'Sullivan asked if manufacturers would consider
developing some type of industry-wide certificate program for
operator training.  Mr. Schultz replied that they are already
looking into this.  The industry does not support distribution of
a product to persons who are not trained in its use.  The
industry is looking at how best to certify operators and the need
for training materials.
     Mr. Berry inguired about how the OEM's ensure that colors
can be matched by refinishers.  Mr. Schultz's answer was that OEM
colors are selected 3-4 years in advance, and properties such as
their handling and consistency are checked.  The colors are also
analyzed for their repair capabilities.  They do sometimes find
that a color can not be matched in refinishing.  Mr. Berry
suggested that the worst thing that could happen (from selection
of any limit) is that it might restrict the designer's future
color choices.  Further, some existing cars would have to be
completely repainted rather than spot repaired because the color
could not be matched.  Mr. Schultz replied that the entire car
may not have to be completely repainted, but at least a larger
area would have to be repainted.
                             1011
                                4
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Industry Presentation #2

BASF Corporation                                    BASF
                                                    Automotive Reflnlshlng
 November 1, 1991
 Mr- Bruce C. Jordan
 Director, Emission Standards Division  (MD-13)
 Office of Air Quality Planning and Standards
 U.S. Environmental Protection Agency
 Research Triangle Park, NC  27711

 Dear Mr. Jordan:

 On behalf of BASF Corporation, I am submitting  the   following  com-
 mentary regarding the September 27, 1991  Draft  of   "Automobile  Re-
 finishing Control Techniques Guideline",  which  you  indicate will be
 the key information source for determination of Reasonable  Avail-
 able  Control Technology (RACT), and subsequent development of con-
 trol  technique guidelines for  regulation of the   volatile organic
 compound (V.O.C.) emissions from the Automobile Refinish  industry.

 In  general, we feel the draft represents an honest attempt to por-
 tray  our industry and does  a good job of  describing  the refinish
 process.  However, there are what we feel to be inaccuracies  that
 tend  to grossly overstate  the industry's contribution  to  V.O.C.
 inventories  that I would like to address, plus present data to you
 that  will substantiate the  use of numerical   averaging  of  V.O.C.
 calculations for multi-stage topcoat systems.

 Major Issues

 I.    The September 27, 1991 Draft does not acknowledge  the  use  of
      numerical  averaging of multi-stage  topcoat systems  for deter-
      mination of V.O.C. content.  Rationale given in the  text  (Page
      3-8)  is that the author felt a "potential" problem  may  exist
      with the equations used to determine the average  V.O.C.  con-
      tent of the combined coatings, in that twice as much clearcoat
      as basecoat may not be needed to cover a given  surface  area.
      Many current state regulations acknowledge the basecoat/clear-
      coat  averaging concept and utilize  the following  equation  for
      calculation of a two-stage topcoat system.



                            1012
19855 West Outer Drive Suite 401 East Dearborn. Michigan 48124 (313) 561-9100
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Page


     V.O.C. r  = V.O.C.    "*" 2 V.O.C.
     Where:    V.O.C. T  =    Total V.O.C.  Content

               V.O.C. BC =    V.O.C. Content  of  Basecoat

               V.O.C. cc ~    V.O.C. Content  of  Clearcoat

The  author of the Draft ; makes the erroneous assumption  that this
equation  was derived from the  ratio of the  dry film thickness of
the  two components  (see  Page 3-7).  In   fact,  the ratios  are not
based  on dry film, but  rather on paint consumption  ratios of two
parts by volume of clearcoat to one part of basecoat.

BASF states in its product literature for  basecoat  clearcoat  sys-
tems to apply the following on each component:

                                APPROXIMATE
                  NUMBER           FILM
                  COATS	   THICKNESS

Basecoat       2-4 Light Coats    0.7 Mils

Clearcoat      2-4 Heavy Coats    2.5 Mils

Material usage ratios under these conditions  actually result  in  a
higher than 2:1 ratio.  This can be substantiated by data collected
by General Motors at their final line repair  area of  their  Saturn
assembly plant in Spring Hill, Tennessee.   The repair  facility  at
Saturn  is basically  a "refinish  shop" and   utilizes our  Diamont
refinish basecoat/clearcoat system.  Material usage at this line is
recorded  on a "material applied"  basis at application.  The  data
below  represents a three  month usage study   conducted earlier  in
1991.

Basecoat/Clearcoat Applied

39.15 Liters Reduced (RFU) Basecoat

89.98 Liters Reduced (RFU) Clearcoat

This  yields a clearcoat/basecoat usage  ratio of 2.30:1, which  is
very favprable compared to the 2:1 ratio for   theoretical  calcula-
tions in B.A.A.Q.M.D. Rule 45, CARS SCM recommendations  and  other
state regulations.

To  further substantiate basecoat/clearcoat usage  ratios, BASF re-
cently did a study on car shells at our Whitehouse,  Ohio  Applica-
tion Facility.  The study was conducted using both conventional air
assisted spray guns and the more efficient HVLP  gun.  Vehicles used
in the study were Caprice Classics, which  are representative  of  a
large size car.  The study also compared usage ratio  for  complete
and  spot repairing.  The study utilized a high  solids (4.4 V.O.C.)
clearcoat with a low solids (6.4 V.O.C.) basecoat so that the worse
case usage ratios would be developed.

                             1013
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Page -3-
Results
     Complete Repainting

     A.   Conventional Air Assisted Gun

          Basecoat                 -



          Guq


          Basecoat Application

          Basecoat Material Usage  -

          Clearcoat                -


          Clearcoat Application

          Clearcoat Usage

          Film Thickness           -
     B.
                              Diamont  Blue  Metallic re-
                              duced  1:0.75 with BR60 re-
                              ducer

                              Sata  Jet Gravity feed  set
                              at 85 PSI

                              Two  medium coats to hiding

                              0.38 gallons

                              Diamont  DC90 2:1 with DH51
                              hardener
                              Two wet coats

                              0.83 gallons

                                  SIDE
HOOD
                              Basecoat
                              Clear
                               1.0 Mils   0.7 Mils

                               2.9        3.5

Volume Ratio Clearcoat :  Basecoat = 0.83:0.38 = 2.18:1

HVLP Spray Gun

Basecoat                 -    Diamont  Blue  Metallic re-
                              duced  1:0.75 with BR60 re-
                              ducer
          Gun

          Basecoat Application

          Basecoat Material  Usage

          Clearcoat


          Clearcoat Application

          Clearcoat Usage

          Film Thickness

                        Basecoat
                        Clear
                              Mattson DC set at 6.0 PSI

                              Two medium coats

                              0.32 gallons

                              Diamont  DC90 2:1 with DH51
                              hardener

                              Two medium coats

                              0.69 gallons

                                SIDE           HOOD
                              0.6 Mils
                              2.1
                              2.7
0.6 Mils
2.9
3.5
                            1014
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page -4-



          Volume Ratio Clearcoat ;  Basecoat = 0.69:0.32 = 2.16:1

2.    Spot Repair

     One  of the most  widely used  technique  for painting a  panel
     with minor damage is to "spot" repair the area.   In  the  case
     of  spot repair, one  of the most  critical qualities the re-
     finish  coating must possess is  the ability to  be  applied  in
     such a fashion that results in the repair area being undetect-
     able from the surrounding original finish in all facets of ap-
     pearance;  including color,  metallic orientation,   texture and
     gloss.   The most popular procedure for spot repairing a base-
     coat/clearcoat finish is to color coat only the  portion of the
     panel  that was damaged and then, in order to  maintain gloss
     and texture, clear coat the entire panel.

     The following technique was used to simulate a  "spot"  repair
     on a vehicle at our Whitehouse,  Ohio facility.

          A.    Spot prime a 2 x 2 foot area on a rear quarter panel
               to simulate the damaged area.

          B.    Color coat with basecoat the "repair"  area,  blending
               out into undamaged portion of the panel.

          C.    Clearcoat the entire panel.

     The  following represents material usage of basecoat and clear
     for the above process.

          Basecoat                 -    Diamont  Blue  Metallic re-
                                        duced 1:0.75  with BR60

          Clearcoat                -    DC90 clear 2:1  with DH51

          Basecoat Usage           -    0.0186 gallon

          Clearcoat                -    0.068 gallons

          Clearcoat:  Basecoat Usage = 0.68:0186 = 3.61:1
                           1015
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Page -5-


     CONCLUSION

     For   BASF,  and  probably  all   other coating suppliers,  the  2:1
     ratio of  clearcoat  to basecoat used on  calculations  for com-
     bined  basecoat/clearcoat V.O.C. actually represents an under-
     statement   of  clearcoat usage.   Since,  to my  knowledge,  no
     commercial  basecoats meet the topcoat  V.O.C.  requirements of
     either Option  I  (5.2  V.O.C.) or option   II (4.5  V.O.C.),  we
     feel  the  topcoat  V.O.C.  requirements  in the  proposal   without
     allowing  basecoat/clearcoat averaging do  not represent reason-
     ably   attainable  control  technology.    The  proposal  should
     therefore either  be modified  to allow averaging, or the V.O.C.
     standards  for  topcoats  should be  raised to  minimum of  6.2
     pounds/gallon.

II.  Option II,  even  with  basecoat/clearcoat  averaging  allowed,
     does   not meet  the  criteria  of Reasonably  Attainable Control
     Technology (RACT) in the area of Pre-Treatment Wash Primer and
     Topcoats,  as the  proposal is  based on  unavailable  technology
     in both areas.

     o     Pre-treatment  requirement of 5.5  pounds/gallon V.O.C.  is
           not   available.   Current  technology is  in   the 6.0-6.5
           range  and chemistry used for  this  type of product does
           not  readily  lend itself  to lower levels.

     o     Topcoat V.O.C. of  4.5 pounds/gallon is not currently at-
           tainable   for  either  metallic  single  stage  colors  or
           multi-stage  topcoat systems even with numerical averaging
           allowed for  the multi-stage systems.

     Recommendation

     Option II does not represent RACT and  therefore should not be
     considered   as  an alternative.   Option I is  acceptable, pro-
     vided multi-stage V.O.C. averaging is allowed.

III. Several questionable assumptions were made in determination of
     Emission  Estimation Techniques in Section 4.0.  These lead to
     a gross overstatement of material usage and subsequently leave
     one to believe  the  industry contributes far more   V.O.C.  than
     it actually  does.

     A.    Section 4.2.1  (Page 4-3) states  "The assumption  is made
           that  all  coating mixed  for the  job  is sprayed and there-
           fore  no emissions  are   attributed to waste   paint."  The
           last  thing  a  painter  wants to  happen  is to run  out of
           paint in the middle of a job.  As  a  consequence,  standard
           practice   is to reduce   at least 25%  more material than
           what  is required and to scrap the overage.   Since by law
           the remaining  material is a hazardous waste,  it is usual-
           ly disposed  of by incineration and consequently,  does not
           contribute to  V.O.C. in  the atmosphere.
                            1016
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Page -6-
     B.   The  film thickness stated  in Section 4.2.1  (Pages 4-5)
          are  overstated compared to what BASF recommends for fin-
          ishes  in  each  category.  The  following represents our
          recommendations compared to what is stated in the draft.

                     FIIH THICKNESS REQUIRED

                                       DRAFT   BASF RECOMMENDATION

          Pre-Treatraent/Pre-Coat     1.0  Mils    0.3-0.5 Mils
          Primer Surfacer            2.25 Mils    2.0     Mils
          Primer Sealer              1.75 Mils    1.0-1.5 Mils
          Topcoat                    3.5  Mils    2.0-3.5 Mils

     C.   Table  4-2 (Pages 4-6) grossly  overstates paint consump-
          tion for each of the coating categories.

          1.    The table suggests 1.6 gallons of pre-coat  or  pre-
               treatment primer is used for a complete  paint  job.
               By  definition  pre-treatment and  pre-coat are only
               used over bare metal areas of the job.    Unless  the
               repaint  is over a completely stripped surface,  only
               3-6  oz. would normally be used.  Even if the job was
               complete  bare  metal, pre-treatment/pre-coat  usage
               would not exceed 0.4 gallons!

          2.    Table  suggests primer surfacer usage  to be 1.2-2.0
               gallons  for complete paint job.   Normal practice is
               to  only apply over poor substrate.   Under this  con-
               dition  only approximately 8 oz.   would be utilized.
               If  complete job were  to be primed   usage would  be
               0.5-1.0  gallons,  depending  on quality  of  primer
               used.

          3.    Table  suggests  sealer  usage of  0.8-1.5  gallons.
               Normal  practice would be to  use approximately  0.25
               gallons of sealer on a complete repaint.

          4.    Table  suggests 2.2-3.8 gallons of  topcoat consumed
               for  a complete paint job.   Actual usage is 1.2-1.75
               gallons.

          5.    Baseline data for topcoat paint consumption given in
               Table 4-2 (Pages 4-6)  is contradictory to that given
               in Table 4-3 (Pages 4-10).   Topcoat  usage per car in
               Table 4-2 is 2.2-3.8 gallons.   Table 4-3 states  1.8-
               3.8 gallons.

     Conclusion

     Data  presented in  Section 4.0  is not  accurate and  grossly
     overstates the baseline V.O.C. contribution for all categories
     of shops in the study.  Therefore,  any of the  analysis utiliz-
     ing  this data as a  baseline is suspect.  This  includes  both
     economic and emission reduction analysis that  are presented in
     the draft.

                           1017
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Page -7-


MINOR ISSUES

I.   Transfer Efficiency

     The draft acknowledges  the  benefits of High Volume   Low  Pres-
     sure spray equipment  in reducing V.O.C.  due to  higher transfer
     efficiency than what  can be achieved by conventional  air as-
     sisted  spray.  However, transfer  efficiency is  not  incorpo-
     rated in the CTG as the author  felt it would be  difficult  to
     control due to variability  of factors such as   coatings  used,
     shape of part and operator  skill.   We acknowledge that the ac-
     tual transfer efficiency will be the result of  a  host of  vari-
     ables  such as operator skill,  size and shape of  part and sur-
     rounding  air velocities.   However,  under any conceivable con-
     dition  there will always be significant advantages  in reduced
     paint usage with HVLP vs. conventional air  atomized  applica-
     tion.   This will range between 20-45%  reduction in material
     usage.

     Recommendation

     We suggest transfer efficiency  be  incorporated  into   the  CTG,
     if not at the upper level the document should   acknowledge  at
     least  a 20% reduction  in paint consumption and with that mag-
     nitude of V.O.C. reduction  require  the use of HVLP or compara-
     ble high transfer efficiency spray  equipment.

II.  Section  2.5.1 (Pages 2-12)  states  Convention Airless  Spray is
     the standard method of  applying coatings in the  refinish  in-
     dustry.  This is a mis-characterization, as to  my   knowledge,
     no  refinish  shops  utilize airless   spray.  The conventional
     means of application  is air  atomized  spray.

III. Section  3.5.3 promotes the  use  of  Biofiltration  as  a  cost ef-
     fective alternative for V.O.C.  control in the   automobile  re-
     finish  industry.   Although the  technology appears to have po-
     tential merit, the fact is  it has never been, to my  knowledge,
     trialed  let alone proven   for  spray  applied  coatings.  Obvi-
     ously,   this  approach  needs considerable  investigation  and
     should  not at this time be considered as representing reason-
     ably attainable control technology.

     Recommendation

     Remove any reference to Biofiltration  from the  CTG unless evi-
     dence  is available the  technology meets the   requirements of
     RACT.
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Page -8-


We  acknowledge  and appreciate  the efforts of  the EPA staff  who
worked on the preparation of the September 27, 1991 Draft for Auto-
motive  Refinishing Control Techniques  Guideline.   The purpose  of
this letter is not to antagonize their efforts, but rather to point
out serious concerns with critical portions of the text.  My desire
and those of my colleagues on the Refinish Coalition is to  aid  in
the  development of a fair and reasonable CTG for our industry.  If
you or any other members of your staff wish to have further discus-
sions  on the issues prior  to the November 21,  1991 NAPCTAC meet-
ing, feel free to contact me.

Sincerely/

BASF CORPORATION
Coatings & Colorants Division
Robert J. Inglis
Director Product Planning

RJI/sep
pc:  D.   Guyomard
     H.J. Robinson
     R.   Sappok
                           1019
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COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

Bob Inglisf BASF Corporation   (See attached Presentation  #2)

     Ms. Mclntire inquired where BASF's estimate that HVLP spray
equipment can improve TE by 20-45 percent came from.  Mr. Inglis
said it was determined through investigations and in practice.
Transfer efficiency does vary by operator and by gun, however, so
you can't just categorize an HVLP gun.  In fact, the same thing
applies to conventional guns.  Ms. Mclntire then asked if TE is
measured by paint consumption.  The answer is yes.  Ms. Mclntire
asked if a standard were to require a certain TE, would shops be
required to maintain records of paint use before and after using
HVLP guns.  Mr. Inglis responded that would be one approach.
There is a definite correlation between paint use and use of HVLP
equipment, and you could establish a ratio.  Operator variability
would be the same in either case.
     Ms. Mclntire asked if manufacturers would be willing to help
small shops in measuring TE.  She also inquired as to how a
baseline would be set.  Mr. Inglis responded that manufacturers
would be willing to work with EPA in setting a baseline.  He
noted that HVLP does improve TE and this should be recognized.
     Mr. Berry requested that Mr. Inglis define "compliant high
TE spray equipment."  He noted that California only says to use
HVLP, which he has heard has difficulty breaking up high-solids
coatings.  California requires the use of HVLP or electrostatic,
and other types of spray equipment are required to prove they can
achieve 65 percent TE.  The question was raised about why HVLP
does not have to prove 65 percent.  California is now in the
process of conducting laboratory tests to allow equipment
manufacturers to prove that their equipment can achieve
65 percent TE, at which point it will be approved for use.  Mr.
Berry stated that HVLP is "directionally" correct, but TE cannot
-------
be quantified.  Further, someone who already has high TE with
conventional spray equipment would not get credit, while a
careless painter who does not get good TE would get the credit
merely because he uses HVLP.
     Mr. Dennison noted that the definition of HVLP is still an
open issue in California.-  Mr. Berry pointed out that as you
reduce air pressure, the painter has to stand closer to the part
being painted.  This in itself improves TE.  Further, high air
flows in spray booths adversely affect HVLP TE.  Mr. Inglis noted
that the same is true if you use conventional spray equipment.
     In reference to the comment that EPA overestimated paint
use, Ms. Mclntire asked how film thickness is measured.
Mr. Inglis replied that there are measuring devices (gauges) that
are easy to use.  Mr. Jordan asked whether a painter could
achieve the very thin mil thicknesses that the coating
manufacturers recommend.  Mr. Inglis replied that they could.
Mr. Jordan noted that he knew from experience that paint shops do
not use the small amounts cited by BASF.
     Mr. Taranto observed that the coating manufacturers raise
some good questions about the baseline data and estimated
emission reductions.  He requested that EPA work with industry on
this issue, especially because the Coalition's projections are
very different from EPA's.  Mr. Inglis noted that the baseline
data are important, but the coating manufacturers are primarily
interested in developing a meaningful, liveable CTG.
     Mr. O'Sullivan asked whether the statement is correct that
even in small shops the extra 25 percent of paint that is mixed
is incinerated and whether coating manufacturers offer this
service.  Mr. Inglis replied that BASF does not offer this
service but the Resource Conservation and Recovery Act (RCRA)
requirements must be followed by shops.
     Mr. Dennison noted that the discussion of using the topcoat
averaging equation seems to indicate that the basecoat limit is
too strict and the clearcoat limit is lenient.  How could
compliance be determined if the standard was based on averaging?
The answer is by recording coating usage.  Mr. Dennison noted
                             1021
                                2
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that it would be very difficult for a regulating agency to
determine compliance solely based on coating usage.  EPA should
strive to profile the industry as best as possible and minimize
recordkeeping.  Shops should only be required to show that they
use compliant coatings, regardless of how much they use.
-------
                                     s
                                 November 5,  1991
                                    JPK 91-296
    Mr. Bruce Jordan
    Director of Emissions Standards  Division (MD-13)
    Office- of Air Quality Planning and Standards
    U.S. EPA
    Research Triangle Park, NC   27711

    Dear Mr. Jordan:

    REF:   Draft Document -- Automobile Refinishing Control  Techniques
                            Guidelines Dated September 27,  1991

    On behalf of Safety-Kleen,  I would like  to  thank  the  U.S.  EPA Advisory
    Committee for the opportunity  to comment publicly on  the proposed
    Automobile Refinishing Control Techniques Guidelines.

    Safety-Kleen is a company dedicated to the  recovery and recycling  of
    solvents, thereby reducing  the environmental  impacts  of the  manufacture
    of new materials and the potential environmental  impacts of  disposal.

    We would like to submit the  following comments for consideration in  a
    final  CTG:

    A)     Spray Gun and Equipment  Cleaner Variations

    One of our products, the Model 1107 Paint Gun and Equipment  Cleaner, is
    referred to in the CTG under discussion.  In  Section  2.6 --  Cleaning
    Equipment -- the draft CTG discusses two types of gun cleaners  --an
    enclosed gun cleaner, and an open  gun cleaner.

    In reference to the enclosed gun cleaner, the draft CTG discusses
    "closed" without complete definition of  the meaning of  the word
    "closed".  The enclosed gun  cleaners currently available are "closed"
    only in that they have a lid.  They do not provide a  vapor-tight
    closure, as implied in the discussion.   Additionally, enclosed gun
    cleaners are available in two  significantly different variations:

    1)     In the simplest configuration, an  enclosed  gun  cleaner uses  only
           recirculated solvent and rinses the passages, ports  and exterior
           of the paint gun and paint cup.  This configuration  does  not
          provide  a final rinse of  virgin material to assure  that  residuals
          are purged from the fine passages  and ports of  the paint  gun.
777 BIG TIMBER ROAD         ELGIN. ILLINOIS 60123         PHONE 708/887-8460         FAX 708/697-1295

                                  1023
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U.S. EPA, November 5, 1991, page 2
2)    An alternate version of an enclosed gun cleaner contains a second
      reservoir which allows for a final rinse of clean material.  The
      clean material is then mixed with the recirculated material and
      used until che it is too contaminated for further use.

The Safety-Kleen Model 1107 described in figure 2-4 in the draft CTG,
provides for both recirculated gross cleaning of the spray gun and cup
and for a clean solvent rinse of the gun and cup to minimize the
potential for contamination of subsequently used paint.

It is important to note that test data provided to the U.S. EPA and
gathered by an independent third party with supervision by the South
Coast Air Quality Management .District of California, indicated that the
use of an open gun cleaner, specifically the Safety-Kleen Model 1107,
resulted in emissions that were significantly less than several gun
cleaners that were identified as enclosed systems.

There is a third type of system available which uses line pressure to
purge a spray gun and cup that has been reviewed by the South Coast Air
Quality Management District and is, I believe, also allowed by its
regulations.  This system is manufactured by LighthalL Industries, and
may be of interest to the Agency for inclusion in the CTG.

B)    Paint Cups

In Section 2.6, reference is made to the use of plastic,  rather than
metal paint pots, for spray gun cleaning with the indication that
plastic may be easier to clean than metal surfaces.  This suggestion
may, in fact, be misleading in that several polyethylene plastic paint
pots can become crazed over time and be, in fact, more difficult to
clean.  Further, there are several metal paint pots currently available
with Teflon coating on the interior.   The Teflon-coated paint pot is
extraordinarily easy to clean and allows for very efficient drainage of
solvents after cleaning, maximizing solvent recovery.

C)    Automatic Vs.  Manual Systems

In Section 2.8.2, entitled "Model Shop Equipment*, reference is made to
the presence or absence of "automatic gun cleaning equipment".  We
suggest that the use of the word "automatic gun cleaner" is exclusive of
the two aforementioned manual products.   We suggest that the use of the
words "gun cleaning system" be included, and exclude the potentially
misleading adjective "automatic".  The use of the word "automatic" or
"automated" appears throughout several portions of the draft CTG, and we
request that it be corrected throughout the draft.  Furthermore, single-
stage, automatic closed units may require a final rinse with clean
solvent that is necessarily done external to the unit.
                               1024
-------
U.S. EPA, November  5,  1991, page  3
D)    Vapor Tight

In Section 6.2, Definitions,  the definition for gun cleaner states:  "A
device made specifically  to clean paint from spray guns which
recirculates solvent to clean a succession of times and is vapor-tight
when  in use.*

No gun cleaner on the market  today is vapor-tight when in use.  Even the
described enclosed gun cleaners are not vapor-tight and emit significant
amounts of volatile organic compounds when they are being used and
subsequent to use.  These losses can be described as "active" losses
during use and "passive"  losses when the product is not being used.
Data  supplied to the Agency has indicated that the use of open systems,
such  as the aforementioned Safety-Kleen Model 1107, are, in fact, more
efficient in reducing emissions in both the active and passive phases.

We suggest that the definition of gun cleaner read:  "A device made
specifically to clean paint from spray guns which recirculates solvent
to clean a succession of  times and minimizes the loss of solvent into
the atmosphere through a  recovery technology".

E)    RACT Considerations

In Section 6.6.2, Gun Cleaners, under Section 6 -- Factors to Consider
When  Implementing Reasonably Available Control Technology - - four
suggestions are made to states:

o     It is suggested that states approve only those gun cleaners that:
      1)    Recirculate the solvent used during the cleaning process,  so
            that the solvent  is used to clean a number of guns before
            being disposed;
      2)    Collect the spent solvent in a manner than insures it is
            available for disposal;
      3)    Are vapor-tight during the cleaning process:
      4)    Meet applicable fire,  safety, and occupational safety and
            health codes, laws, and regulations both in design and in
            the manner in which it can be used.

o     State regulations should specify that the facility is accountable
      for spent solvent from the gun cleaner.   It must not be allowed to
      evaporate.   Documentation must be available to support that it has
      been released to a licensed reclaiming or hazardous waste
      management facility.

Point three requires a system be vapor-tight during the cleaning
process.   This is not consistent with the suggested definition for a gun
cleaner hereinabove,  but, more importantly, it is not consistent with
comments made in Section 3.4,  Emission Reductions From Gun Cleaning, in
which the Agency indicates that equipment is currently available that
                             1025
-------
U.S. EPA, November 5, 1991, page 4
can reduce solvent consumption, evaporation, and worker exposure.  The
Agency further suggests that gun cleaners can be enclosed or open and
cites a report obtained during the CTG investigation that some open gun
cleaners emitted no more VOC" s than enclosed gun cleaners .

F)    Health Considerations

It is important to note that the use of enclosed gun cleaners, when
compared to open gun cleaners, may pose significant exposure and health
effects that are solved with certain open systems.  In this regard, an
open system, such as the -Safety-Kleen Model 1107, may be both safer to
the user and less damaging to the environment.  (See attached ENSR study
on Evaluation of Worker Exposure to Organic Vapors while Operating Paint
Spray Gun Cleaners . )

Should the Agency require clarification of any of the above comments,  I
would be happy to elaborate.  I plan to attend the meeting on the draft
Auto Body Refinishing CTG Document on November 21, 1991.

Once again, thank you for the opportunity to participate in the
development of this CTG.
JoRn Paul Kusz
Manager, Product Development

JPK/pJ

Encl.

cc :   CAATF
     Mike Callahan
     Jim Sanseverino
     REG/TEST/U.S. EPA
-------
COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

John Kusz. Safety Kleen (see attached Presentation #3)

     Mr.  O'Sullivan asked if there is any estimate of the
percentage of small shops that deliver their spent solvent to
reclaiming facilities.   Mr.  Kusz said it is hard to give a
definitive answer.  The numbers are expected to be different in
different regions, e.g., the percentage would be greater in
California and in more commercial areas.  Mr. O'Sullivan wanted
to know what percent of the market Safety-Kleen services.
Mr. Kusz preferred not to make that public knowledge, but said
that some information has already been provided to EPA.
                             1027
                                i
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Industry Presentation #4
                   PRESENTATION OF




                        THE




       NATIONAL AUTOMOBILE DEALERS ASSOCIATION




                     BEFORE THE




         U.S.  ENVIRONMENTAL PROTECTION AGENCY




                         BY




                 DOUGLAS I. GREENHAUS




         SENIOR ATTORNEY,  REGULATORY AFFAIRS




                         ON




                  NOVEMBER 21,  1991
                      1928
-------
     Good morning.  My name is Douglas  I.  Greenhaus and I am the
Senior Attorney for Regulatory Affairs for the National Automobile
Dealers Association (NADA).  It is my pleasure to appear before you
today to present NADA's views  on the U.S. Environmental Protection
Agency's  (EPA)  draft Automobile  Refinishing Control  Techniques
Guideline (CTG).

     NADA is a national trade  association representing over 19,000
franchised car and truck  dealers across the country.  NADA members
are primarily  engaged  in the retail sale  of new  and  used motor
vehicles, both foreign and domestically produced.  NADA members are
also engaged in automotive service repair and parts sales.

     EPA's draft CTG on automotive refinishing is of considerable
importance to  the automobile dealership  body.   NADA's  Industry
Analysis division estimates that  dealership  automobile  and truck
refinishing  operations   account   for  roughly one   third  of  all
autobody sales.   In addition, approximately  sixty  percent of new
vehicle dealerships operate  formal autobody repair and  painting
operations.   In total,  it is estimated that dealership  autobody
departments employ some 103,000 people in 13,500 facilities with an
average of 8 employees per department.

     The average NADA dealership  employees 40 persons  in total.
In addition, over eighty percent of NADA's members are considered
small businesses by the Small  Business Administration.  Given that
                                2
                          1029
-------
the  refinishing  CTG will  substantially  impact  small  business
refinishing operations,  NADA  is actively working with EPA on the
development of guidelines for the implementation of Section 507 of
the Act.

     NADA  previously provided  EPA  with information  in order to
assist  with the  CTG development process.   In  early 1988,  NADA
submitted the results of a comprehensive membership survey of paint
and coating material use rates.  Earlier this year,  NADA submitted
comments on EPA's Revised Summary of Automotive  Refinishing Model
Shop Emission Costs.  The following comments specifically address
the September 27 draft  CTG.

A.   Surface Preparation
     NADA supports the inclusion of controls on surface preparation
products.     However,   NADA   submits   that  EPA  significantly
underestimates the costs associated with using lower  solvent
content preparation  materials.   It is clear  that the  use of these
materials will take  some amount  of applicator  retraining and will
require  additional time to achieve the same  benefits  as higher
solvent  content  counterparts.    EPA   fails  to   include  these
significant costs  in its analysis.

     With  respect to emissions reduction,  NADA  suggests that the
draft CTG  fails to consider whether lower  solvent  content surface
preparation materials aren't  used in greater quantities. EPA also
-------
fails to recognize that solvent volatilization  is proportionate to
the amount of time the preparation product remains on the surface
and to  recognize  that not all  of the  VOC's  in  higher solvent
content materials  become airborne prior to being wiped off the
surface being prepared.  In summary, EPA overstates the  emissions
baseline for surface preparation materials.

B.   Coating Applications
     NADA  supports  the  two   option  approach to  paint  system
regulation.  However, NADA is very concerned about the values EPA
has selected.  Obviously, the values selected for each option are
of critical importance to the refinishing industry.  Without proper
paint system quality and  color match capability,  auto refinish
operations will be unable to adequately service their customers.
NADA suggests that EPA consider adopting  the values set out in the
California Air Resources Board Regulation and endorses the National
Paint and Coating Association's comments on that issue.

     Lower solvent content coating systems  are expected to require
considerable applicator retraining.   In  addition,  it is expected
that surface areas will take longer to paint and that drying times
will be longer.  All of these important costs must be factored into
EPA's impact analysis.

     NADA  strongly  supports   EPA's  decision  not to  include  a
transfer efficiency requirement in its CTG. On the otherhand, EPA
-------
must recognize some VOC emissions reduction benefits attributable
to those shops using improved transfer efficiency.  It is reasnable
to expect that, as reformulated paint systems  become more costly,
facility operators will begin to turn to higher transfer efficiency
equipment in order to reduce costs.

     EPA's  discussion  of higher  transfer  efficiency  fails to
reflect the significant retraining costs involved and the potential
for longer  painting  times,  both  of which are  critical  factors to
the refinishing industry.

C.  Gun Cleaning
     NADA supports the  inclusion of a gun cleaning requirement in
the CTG.  At the same time it is clear that EPA overestimates the
baseline  for this  option and thus  the potential  for  emissions
reduction.   A significant and increasing  source  of  gun cleaning
solvent results from the  in-house distillation of waste paint and
solvent materials.  To count this recycled  solvent in an emissions
baseline would be redundant.  Likewise, the cost  savings shown by
EPA  for gun  washers is  also  erroneous in  light of the use of
recycled gun wash solvent.

     It is also inappropriate for EPA to assume that all the  spent
solvent used to clean guns is fully evaporated  in those shops  which
do not use gun cleaners.  Whether destined for on-site distillation
or  off-site management,  spent  gun wash  is not  left  to totally
-------
evaporate in the typical automotive refinishing facility.

D.   Add-On Controls
     NAOA strongly objects to the inclusion of add-on controls in
the proposed CTG.  EPA's impact analysis shows that add-on controls
are  not  currently  available  for  the  automotive  refinishing
industry.  In addition,  EPA's data show add-on controls to be from
six  (carbon  adsorption)  to over fourteen  (incinerator)  times as
expensive as surface coating system solvent control alternatives.
On  the  other hand,  add-on controls result  in,  at best,  only a
marginally superior reduction in VOC emissions.

     EPA's  suggestion  that  states require multiple  shops  to
refinish in a single  add-on control equipped facility verges on the
ludicrous.  While this creative concept might conceivably make the
capital and operating costs more "reasonable," theoretical savings
would   be  overshadowed   by   transportation  costs,   scheduling
nightmares, competition concerns, etc.

     Again, all references to add-on controls must be deleted from
the  proposed CTG as they  are clearly not  "reasonably available
control technologies" for  this industry.

E.   Other
     a.   Housekeeping Practices
          NADA  has  long supported  good  refinishing housekeeping
-------
practices.  Keeping containers closed and minimizing the amount of



materials used is good for business as well as for the environment.







          Throughout  its proposed  document,  EPA refers  to the



proper  management of  waste  paint and  solvent  materials.   NADA



objects to  EPA's repeated  reference  to off-site waste  management



options as somehow being important to the CTG.  Instead,  EPA should



include a  suggested prohibition against  the intentional on-site



disposal-through-evaporation of waste paint and solvent  materials.



Furthermore, there  is  no reason to believe that waste  sludges or



distillation  residues  pose  any  VOC emission  concerns.     The



discussion of waste management,  including recordkeeping, should be



dropped from the CTG as  these materials are already  covered under



applicable  federal   and  state  solid  and/or  hazardous  waste



regulations.







     b.   Reporting and  Recordkeeping



          NADA  strongly objects to EPA's suggested  recordkeeping



and  reporting  requirements  as having  no  relationship  to  VOC



control.  Daily logs  or records would be terribly burdensome for



the  small  business automotive  refinishing  community.   In the



alternative,  EPA should  simply  suggest  that states require



refinishers to keep copies of their preparation, paint system, and



solvent purchase  invoices,  and the  repair  order  documentation



normally kept  in the  ordinary  course of  business.   Analysis of



these normal business records would provide regulatory authorities
                            1034
-------
with more  than adequate information  for  both administrative and
enforcement purposes.

     c.   Miscellaneous
          NADA urges EPA to edit its draft CTG document to remove
a  number  of  irrelevant discussions  including the  reference to
reducing the number and severity of collisions, and the discussion
of electrostatic spray equipment.

          EPA's model  regulation has  a reference to "aftermarket
automobiles."  This  term is  certainly not commonly understood in
the industry and its purpose  is unclear.  While there may be a need
to  distinguish between  OEM painting operations  and  automotive
refinishing,  it makes  no sense to try to  define coverage of the
rule based on where vehicles were purchased.

          EPA's  model  regulation  should  apply to  light  duty
vehicles as  defined in its mobile source  regulations  and should
exclude heavy  duty  vehicles.   The  reference to and definition of
light and medium duty trucks is  inconsistent with other Clean Air
Act definitions.

          On  behalf of NADA  I would  like  to thank you  for the
opportunity  to comment on this matter.    At this  time,  I would
welcome any questions you might  have.
                                8
                             1035
-------
COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

Douglas Greenhaus. National Automobile Dealers Association fNADA]
(see attached Presentation #4)

     Mr. Hise asked how common is distillation of waste/spent
solvent.  Mr. Greenhaus said it is not that common, but it is
increasing.  The use of distillation units avoids off-site
liability disposal and reduces hazardous waste disposal costs.
Distilled solvent can be used in gun cleaners (but it is not pure
enough to mix in paint).  Mr. Hise asked if these units are
readily available to shops.  Mr. Greenhaus said they are; there
are at least 12 distributors, and some facilities share them.
     Dr. Atkins asked if NADA completely supports the California
regulation.  Mr. Greenhouse responded NADA does not support the
regulation for recordkeeping or TE.  In color match issues, they
defer to the coating manufacturers.
     Mr. Dennison recommended that NADA explore the possibility
of multiple shops sharing an add-on control device.
Mr. Greenhaus said they would, but that this practice is not done
at all, and is not "reasonable" for consideration as RACT.  He
was not aware of any NADA members that have add-on control
devices, and NADA would not support the use of add-on controls
for any size shop because the costs are just too high.
     Dr. Atkins asked if Mr. Greenhaus was aware of many odor
complaints.  Mr. Greenhaus replied that they occasionally hear of
shops getting inspected because of odor complaints but most
dealerships are located in non-residential areas.  Mr. Berry
noted that non-dealership facilities could be located in
residential areas.  Mr. Greenhaus agreed that smaller,
independent shops are more likely to be located in residential
areas.
-------
Industry Presentation #5
                              PRESENTATION/COMMENTS OF




                     PPG INDUSTRIES AUTO REFINISH COATINGS GROUP




                      CONCERNING AUTOBODY REFINISHING CTG DRAFT
                                         BY




                                   R.  T.  HILOVSKY




                             MANAGER,  REGULATORY AFFAIRS




                        AUTOMOTIVE,  AIRCRAFT & FLEET FINISHES
                                     1037
-------
- NAPCTAC Meeting - November 21, 1991

- Automotive Refinish CTG Draft


Thank you for the opportunity to address this subject today.

As a supplier of coatings systems, information and training to the
Auto Refinish Industry and an active participant in the NPCA Auto
Refinish Coalition, PPG Industries strongly supports the positions,
objectives, and recommendations of the NPCA Coalition position paper.

    -Objective:  Development of national consistent VOC regulations
    with real, effective, achievable VOC emission reductions.

    -Recognition & incorporation of industry practice and operating
    realities into effective regulations.

    -Selection of the RACT VOC limits of the California Clean Air
    Act Guidance for the Refinish Industry as the RACT limits for
    the CTG.

    -Topcoat limits recognizing multi-stage basecoat/clearcoat or
    tri-coat averaging as necessary to achievable VOC systems
    reductions.

    -The recognition of the systems nature of Refinish products and
    processes.

    -Acknowledgement of the necessity and utility of low-volume usage
    speciality coatings.

    -The effective reductions achievable through the trained use of
    improved transfer efficient application equipment and techniques.


-Systems Nature of Auto Refinish Coatings Operations

    -Product chemistries as they develop require constant testing
    to determine over and under what other coating components and
    substrates these products are compatible

**[Attached overhead transparencies here to demonstrate systems]

    -New material developments and raw material substitutions for
    supply/economic reasons as well as regulation mandates require
    retesting and qualification within the individual manufacturer's
    total system.
         -Knowledge of competitive changes is not available as to
         type or timing.
-------
    -Use of total product systems with their background testing
    history allows consistent use,  application,  and productivity
    recommendations to be made and trained.

    -Total  systems allow thorough technical  service support,
    complaint handling,  and approved application warranties.   This
    better  assures that recommended reductions,  blends and
    application techniques are consistently  followed,  to maintain
    and assure the guarantee and minimize job re-do's  or come backs.


-Training

    Achievement of the desired VOC reductions from any regulation
    is best attained by the consistent,  trained  usage  of compliant
    materials and methods by an applicator confident in the products,
    equipment and achievement of the desired end result in system
    appearance, performance and productivity.

    Auto Refinish systems manufacturer/suppliers are the primary,
    consistent and continuing source of training to the industry.

         -Product Systems Introduction and Training

         -Coating Systems Application Options
              -Printed recommendations and hands-on training

         -Regulatory Requirements
              -OSHA safety and right to know
              -Hazardous waste disposal guidelines
              -VOC emission reduction

         -Product/Process Productivity


CA Guidance RACT is fully accepted,  trainable and in training now.

Thank you for your time and attention,  and I would welcome any
questions you may have.

A final comment before I conclude,  the conclusion that transfer
efficiency  is not easily quantifiable due to product,  part and
process variability,  and thus cannot be assigned a baseline % value,
seriously contrasts with the assigned 35% T.E. value for conventional
air spray used in calculations in the draft  CTG.   35%  T.E. is the
maximum achievable for air spray,  which is certainly subject to all
the same variables.   A reasonable improved T.E.  baseline average can
be established from product usage/purchase records.
                            1039
-------
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-------
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                                                                    15
-------
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       18
                                                                                             19
-------
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      16
                                                                                             17
-------
COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

Ron Hilovsky. PPG Industries (see attached Presentation #5)

     Mr. Hise asked whether the EPA's assumed TE of 35 percent
was accurate for the industry today as an average.   Mr. Hilovsky
responded that conventional spray equipment has a TE of 25-35
percent, while the CTG gives 35 percent as an average for
conventional spray equipment.
                            1G44
                                i
-------
                 Industry Presentation I6
The Sherwin-Williams Company
101 Prospect Avenue, N.W.
Cleveland, Ohio 44115-1075

 •National Air Pollution Control Techniques Advisory Committee Meeting
  November 21, 1991  at Durham, NC
 •Guidance document for Automotive Refinishing CTG


 NAPTAC Committee  Members:


 I appreciate the opportunity to address this committee today.

 We recognize the need to reduce VOC emissions to improve air quality due to not
 only the need to comply to the Clean Air Act but to create a healthy environment for
 all of us.   In doing so you take into consideration environmental and economic
 impacts.   In this  regard  I would like to tell some background information on the
 automotive refinish industry.

 The industry is responsible for the repair and refinish of the average person's second
 largest asset - his  car. (This follows only the home as a person's single largest asset.)

 The industry represents the classic small business profile for the United States.  The
 following facts from  the "Market Profile  1991" Body Shop Business (a widely read and
 highly regarded trade publication) represent the industry:

            • 77.2% of body shops are family owned
             (20.2%  of those are second generation),
            • Currently 2 family members work full time in the body shop,
            • The average body shop has approximately 7 employees,
            • 45.5% of workers refinishing automobiles are paid hourly,
            • 53.4% of body shops generate less than $250,000 in annual sales,
            • Average gross profit margin is 25.0%
             (This translates to less than $62,500 in gross profit per year).

 The reason I bring your attention to these facts is that we take great care in our
  recommendations for PACT. And for how we design new technology for the future.

  I would also like to bring to your attention the heart of the refinish industry - color. The
  ability to restore  a vehicle to its "pre-collision condition" is absolutely  essential. The
  restoring  of a vehicle to OEM specification for quality and performance is necessary
  and expected.  But the  color match  dictates whether a customer  will accept a
  repair. If the repair  is evident to color  mismatch, the vehicle has to be done again
  and at a loss. To give you a feel for the complexity of todays colors I have brought
  the following.

            • '92  Domestic Car Color Chip Book,
            • Alternate color formulas program,
            • Repaired panels
            • Blending - visual demonstration

                                   1045
-------
As you can see, there are literally thousands of colors required to refinish all of todays
vehicles.  And complex color matching is required for today's colors.  We are
sensitive to their needs of providing a quality and warranteed system that they can
use right the first time. Again this impacts our recommendation for PACT.

The draft document for the automotive refinish CTG does not take into account the
use of  a composite VOC for basecoat/clearcoat  colors.   Attached to my
presentation is our company's documentation where the composite calculation of

                     VOC BB/CC = VOC BC + 2 VOC Cc
is derived from. In our test we simulated a medium size repair (replace fender and
blend door) and large repair (replace front fenders  and hood, blend into doors).
We also used a Low Volume Low Pressure gun, a high solids clearcoat, and a high
VOC basecoat color.  This combination represents a worst case scenario (ie - low
amount and VOC of clearcoat, high VOC  basecoat color, and low volume of
material due to high transfer efficient application equipment). The results are still within
the composite VOC calculation. To sum up the results (details are attached):

           • The  ratio  of 2:1 for clearcoat to basecoat  is based in  material by
            volume not dry film thickness. Actual is 2.4:1 for a medium repair and
            2.6:1 for a large repair.

           • The predicted VOC for the composite VOC calculation is understated
            by 2.2% of actual VOC emissions for a medium repair and understated
            by 0.6% of actual VOC emissions for a large repair.

The calculation  is  accurate  and  represents  the  VOC  emissions  of a
basecoat/clearcoat system. With the flexibility to use this composite VOC calculation
we are free to turn loose our Research and Development department to lower VOC
emissions of a basecoat and/or clearcoat. This will encourage innovative solutions
to reduce  VOC emissions at the  lowest cost.   Without this flexibility the VOC limits
proposed (contained within the draft CTG) are not RACT. No system, to the best of
my knowledge, exists that can commercially meet the proposed VOC limits.

RACT is defined as "the lowest emission limitation that a particular source is capable
of meeting by the application of central technology that is  reasonably available
considering technological and economic feasibility".  And it takes into account a
particular  source's "technological and economic circumstances". In your RACT
determination we ask you to recognize our efforts to think and act as an industry:
refinishers  and shop  managers/owners, distributors,  equipment suppliers  and
coatings manufacturers. Our efforts are designed to move our industry to lower their
VOC emissions but  yet preserve the integrity and complexion of the industry by
keeping costs low.


                                 1046
-------
In our considerations we  as  an industry  have been required to weather the
technological advances of the Unibody,on board computer equipment, increased
OEM warranty  periods,  and  basecoat/clearcoat/three stage finishes.   These
advances required new technology and training, as well as capital investment for
new equipment. All at a time of decreased amount of issuance dollars.

The RACT recommendations we make are sensitive to the small  business in the
aftermarket collision repair industry. We have worked together to draft reasonable
rules. We make the recommendation to use California's Technical  Review Group's
recommendation for RACT.  It encompasses the goals of industry and regulators into
a common target. Our focus in not to stop at  RACT.  We have set our ambitious
program to go further.

I would like to make an additional comment.  Hercules approached me about how
their gun  cleaner fit into the CTG.  I believe the attached document should be
reviewed as its results are contrary to some of the information in the draft CTG.

Again I appreciate your time and the hard work of many here to get to where we
are today. The incorporation of our suggestions ensures a workable document for
the United States and tomorrow.
                                    047
-------
                           Basecoat/Clearcoat VOC Calculation

   VOC BC/CC Premise:  The VOC emissions from a repair of an OEM basecoat/clearcoat by an
   aftermarket refmish basecoat/clearcoat can be accurately represented by the following calculation:
                    VOC BC/CC = VOC BC + 2 VOC Cc
   This premise is based on allowing a basecoat with accurate color match capability that will allow
   smaller blends, prevent "re-do's" due to inaccurate color match, and that the volume of the clearcoat to
   basecoat is a minimum of 2:1.

•  Test  Protocol:
   —Test
      Spray two repairs that represent an  "average1" (1-2 panel) and large2 repair (2 or more panels)
      (Small repairs3 - a panel or less represents the lowest VOC emission and consequently will not be
      done). See attached diagram.
   —Equipment:
      Iwata LPS (Low Volume Low Pressure restricted to maximum 10.0 psi at tip).
   —Topcoat System:
      BC)—UltraBase 7® Basecoat Color with BCS-600V (Test Colon '91 General Motors Code 22
            Light Sapphire Blue Metallic UB-35879).
      CC)—Ultra 7000® High Solids Urethane Booth Clearcoat CC-850.

1  Average—Involves up to replacement of 1 panel (such as a fender), applying basecoat to fender and
   blending color into clear to hide any potential color mismatch. This is followed by applying clearcoat
   to fender and door.

2 - Large repair—Involves up to replacement of front end (such as a severe front end collision), applying
   basecoat to both fenders, hood, and blending into doors (to hide any potential color mismatches). This
   is followed by applying clearcoat to two fenders, hood, and both doors.

3 - Small repair—Involves applying basecoat to small spot (usually less than 1 panel) and blending out into
   rest of panel. This is followed by applying clearcoat to entire panel. If color match is good, generally
   the amount of basecoat color used is small compared to clearcoat usage.

•  RESULTS

                               Basecoat                    Clearcoat
   —Mixing Ratio              1:1 UB-35879:BCS-600V     4:2:1 CC-850:CC-R854:CC-H858
   —VOC (Sprayable)          6.07 #/gal                   4.38 #/gal
   —Wt/Gal (Sprayable)        7.66 #/gal                   8.13 #/gal
   —UsageJ Medium repair     3.4 oz.                      8.2 oz.          Ratio: 1:2.4
   —Usage! Large repair       12.1 oz.                    31.6 oz.         Ratio: 1:2.6
   —Actual VOC emissions
       Medium repair            0.16#                      0.28 #           Total: 0.44 #
       Large repair              0.58 #                       1.08 #           Total:!. 66 #
   —Predicted VOC emissions 2
       Medium repair            —                         —               Total: 0.45 #
       Large repair              —                         —               Total: 1.67 #


              1  Usage—      Medium Repair (~ 14 sq. ft.)    Large Repair (~ 44 sq. ft.)
                         BC       92.3g (3.4 oz.)               329.5g (12.1  oz.)
                         CC       234.8g (8.2 oz)              909.3g (31.6 oz.)
-------
COMMITTEE DISCUSSION ON INDUSTRY PRESENTATION

Grea Ocampo.  Sherwin Williams (see attached Presentation #6)
[Note:   There was no committee discussion of attachment to
Presentation  #6]

     In response  to a question by Dr.  Atkins about the 1992
California limits, Mr. Ocampo said they would be hard to meet in
a shop that did not have a heated spray booth because the
clearcoat would dry very slowly-  Some coatings that can meet the
1992 limits are not currently "reasonably available," but may be
in a few years.  Mr. Ocampo stated that he supports the GARB 1990
limits as RACT.
     Mr. Hise asked how the right color is selected.  Mr. Ocampo
replied that  spectrophotometers work for solid lighter colors.
However, even then they are only used for guidance; all color
matches are done  by eye.
     In response  to another speaker's comment that color match
would only be hard with the Option 2 topcoats, Mr. Ocampo said
that all coating  manufacturers agree that without being able to
use the basecoat/clearcoat averaging equation, metallic topcoats
could not meet either option.
                            104!
                                i
-------
           Atxacnment  to
           Industry Presentation  #6
Iterlmlec
                                                                             Phone. 313-363-8882
                                                                             WATS. 1-800-444-4351

                   Hcrkulcs Equipment Corporation                          reiex     '

                   8230 GOLDIE ST.  •  WALLED LAKE, Ml 48390-4108

                                           November 13,  1991
    United States Environment  Protection Agency
    Office of Air Quality  Standards'Division
    Research Triangle  Park, N.C.    27711
    Attention:   Mr.  Bruce C. Jordan
                Director Emission Standards Division

        Subject:   Draft Sept. 27, 1991
                  Automobile Refinishing
                  Control Techniques Guideline
                  (Gun Cleaning)

    Dear Mr.  Jordan,

    Our copy  of  the  draft was delayed in being received  due  to a zip code change
    and was only  reviewed this past weekend,  hence we  are  too late  to obtain time
    for a presentation.  According to Mary Jane Clark, you can distribute copies
    of this letter to the committee.

    Our firm  holds the basic patents on the predominate  type of enclosed gun
    washers found  in body shops both here in  the USA as  well as in  most countries
    abroad identified in your draft in Section 2.6 on  page 2-15 and pictured in
    Figure 2-3 which is commonly referred to  as an Automatic-Enclosed Gun Cleaner.
    To help NAPCTAC  we would like to place before the  committee some additional
    information which is related to paint gun washing  and  "latest applicable
    technology"  for  cleaning of paint guns and related equipment.   To accomplish
    this objective,  a distinct differentiation is made between Automatic-Enclosed
    Gun Cleaners  (Figure 2-3) and the "typical open gun  cleaner" described in
    Section 2.6 page 2-17 and pictured in Figure 2-4 also  known as  a Manual-Open
    Gun Cleaner.   The major differences are compared below:
-------
        Differences             Automatic-Enclosed              Manual-Open

     1.  Closed  during               yes                             no
        cleaning

     2.  Cleans  guns without          yes                             no
        worker  direct
        participation

     3.  Cleans  multiple  guns,        yes                             no
        cups, stirrers,
        strainers  and other
        paint related equipment
        simultaneously

     4.  Cleans  inside and           yes                             no
        outside of guns
        simultaneously

     5.  Workers are exposed          no                              yes
        to solvents during
        cleaning cycle
Much of  the  draft  seems  to paint both Automatic-Closed and Manual-Open Gun
Cleaners with  the  same brush.   This overlooks key issues such as solvent.
consumption, worker  exposure,  cleaning cycle time,  other items which must
constantly be  cleaned  along with the paint gun and  simultaneous multiple gun
cleaning all of  which  impact on the VOC emission and worker exposure.

As a part of the "improved housekeeping practices"  referred to in Section 3.1
page 3-1, Automatic  Enclosed Gun Cleaners can play  an important role.  They
affect radically the amount of time required for cleaning guns, cups,
stirrers, strainers,  etc.   reducing worker direct exposure to solvents while
limiting potential  escape  of V.O.C.  Over the old methods of cleaning, they
significantly  reduce solvent usage and the amount of solvent which must be
maintained at  the  shop.  Virtually all of the tools and related items which
need constant  cleaning including strainers,  stirrers, and mixing vessels can
be cleaned in  the  automatic gun cleaner at the same time the guns are being
cleaned  eliminating  the  need for multiple open containers for various cleaning
functions.

We take  issue  with  the final paragraph in section 3.4 page 3-10 implying that
"Open Gun Cleaners  emit  no more VOC than Enclosed Gun Cleaners." The report
referred to  was  submitted  to SCAQMD in order to obtain a variance allowing
manual-open  gun  washers  to be used in Southern California.  The report was
paid for by  the  waste  hauler owning the rental equipment;  the test  itself
varied from  the  testing  procedure recommended by the SCAQMD, and did not
reflect  knowledgeable  usage of the competitive units, totally ignored multiple
equipment cleaning  which is essential and used antiquated competitive models.
-------
With reference to Section 4.3.1.  page 4-14, it is possible  that minimal
solvent could be emitted from closed gun cleaners, but this  possibility was
virtually eliminated long ago by a redesign of the lid.   (See Attachment No.
1).  All Herkules manufactured or licensed units have or  will have soon
incorporated this feature.

The issue of escaping V.O.C., 4.3.1 page 4-14, during the loading (no hose
connections are required in our standard automotive Automatic-Enclosed Gun
Cleaners) is a valid concern and can be addressed two ways.  The first way is
through education and the second way is through the use of a speed controlled
lid opener and closer.

Proper opening of the lid on-any solvent container requires education.  The
worker does not want to create any more suction during opening and no more
fanning of fumes during closing than necessary.  Hence the industry needs
instruction.  A sample of such instruction for any vessel containing solvent
could read as follows:

                                  CAUTION:
                             READ BEFORE OPENING

    Solvent fumes are normally heavier than air and if not disturbed
    will remain in the container.  To prevent fumes from escaping,
    open and close lid slowly.

        I.  Open lid about one inch to equalize the pressure inside
            and outside.  Then open slowly, this mimimizes the escape
            of fumes through suction.

        2.  Do not slam lid during closing, lower lid slowly to prevent
            fanning which can cause fumes to escape.

In the Definitions Section 6.2 page 6-3 under the heading Gun Cleaner,
reference is made to being "vapor tight";  no gun cleaners in common use are
100% vapor tight.  In fact, if they were vapor tight chances of fume emission
would be increased during loading and the cleaner could become dangerous under
pressure as the content in most cases are extremely volatile.  For this
reason, we believe Sections 6.2 page 6-3, 6.6.2 page 6-10 and Appendix D, page
D-3 Gun Cleaners and Appendix D page D-5 Equipment Standards (d)  (1)  (iii)
need modification to read "reasonably vapor tight" not "vapor tight."

We are continuously trying to improve the design and application of cleaning
equipment to provide both the autobody repair and industrial paint industries
with "state of the art" equipment.  The draft does not take into
consideration the latest models of automatic-enclosed cleaning equipment which
have solved many of the VOC emission problems, for example:
                                  1052
-------
       Features

   1.  Double barrier lid
       design.
       Speed controlled lid
       opener and closer.
       Hose cleaning for
       pressure gun fluid
       lines.
    4.  Paint can and paint
       lid cleaning.
    5.  Combination gun and
       paint can washing.
Herkules Models
Containing Features

All Herkules models
GWR-100-SS
GWR-3-100-SS
CWR-4-100-SS

GWR-3
GWR-3-100-SS
CWR-31
CWR-31-100-SS
CWR
CWR-1
CWR-31
CWR-31-100-SS
CWR-4
CWR-4-100-SS
CWR
CWR-1
CWR-31
CWR-31-100-SS
Result

Reduction of VOC emissions
during both active and
passive states.

Reduction of VOC emissions
during loading and un-
loading.

Reduces solvent needed for
fluid line cleaning, VOC
emission and the need for
open solvent containers
during cleaning.

Allows paint cans to be
reused as mixing or
storage containers,
reducing solid waste
generated in the form
of paint sludge.  Converts
quart, gallon and 5 gallon
cans considered hazardous
to non-hazardous reducing
disposal costs and re-
ducing the amount of
paint which is sent to
hazardous dump sites,
inside cans.

One cleaner cleans
both guns, cups,
stirrers, strainers, etc
and paint cans/lids.
In a  world of constant change, obviously  it is  impossible  to  take  all
available technology into consideration before  approving the  guidelines.
With  minor adjustments to the draft including more specific wording on
Automatic-Enclosed versus Manual-Open Gun Washers and changing  the concept  of
"vapor  tight" to "reasonably vapor tight" the document  should become an
acceptable guideline.
                                       Yours  very  truly,
                                        Richard  A.  Robb
                                        President
RAR/lw
                                *i ° r n>
                                I.» 3 3
-------
ATTACHMENT No.  1
   ORIGINAL
   ALUUIHUM
     LID
ALUMINUM
 FRAMf
    ORIGINAL
     PLASTIC
       TUB
                 HEW
              ALUMINUM
                 LID
VAPQR
SCAL
                                                  GWR  LID/TUB  FIT
                                                   PLASTIC TUB

                                                 HCKKULCS fQUIPMCUr CORP
                                                 Bf LG         PAr.- l-ir-91
                                                               LIO Oe<~l
                                                   STAINLSC? STfCL TUB
                                                   HY LG
-------
         Comments & Observations Of
    Automotive Refinishing CTG Document
en
                                 GRACO INC.
GRAC01"1                             MINNEAPOLIS, MN
-------
     Total Paint Thickness Applied by OEM
    Total

    Paint
  Thickness

   3.5 MILS
          i
                                             Clearcoat
                                             50% of Total Thickness
Basecoat
20% of Total Thickness


Primer
30% of Total Thickness
GRACO 1991
-------
     OEM Prefers Electrostatic Application
M
GR AGO 1991
                 75-80% of all coatings currently
                 applied are electrostatic
                 Including:
                          80% of all primers

                          95% of all clearcoat
                        / 40% of all basecoat
-------
   Graco Test Comparisons of T.E. in Spray
     Forms Show That in Refinish Industry
 C©
        Electrostatic
       Hits the target with
        75% efficiency
   HVLP
Hits the target with
 65% efficiency
  Airspray
Hits the target with
 40% efficiency
            ...Because of very low flowrates
GRACO 1991
-------
              When Using Electrostatic

            Application Throughout the

           Automotive Refinish Process


           •  Basecoat color match is more accurate
             and readily achieved
           •  Application is easier
           •  Greater efficiency results, which
             translates to faster payback of
             electrostatic gun
              EXAMPLE: 10 week payback of $4100 electrostatic unit
                    shop type E-H)

              1.92 Gallons/Day (savings) X $42.50/Gallon X 50 Days = $4080
GRACO1991
-------
fteffkulcc
                                                                               Phone: 313-363-8882
                                                                               WATS: 1-800-444-4351
                                                                               FAX:  313-363-7998
                    Herkulcs Equipment Corporation                            i.v.  231233

                    8230 GOLDIE ST.  •  WALLED LAKE, Ml 48390-4108

                                            November  11,  1991
    United States Environment Protection  Agency
    Office of Air Quality Standards Division
    Research Triangle Park,  N.C.    27711
    Attention:  Mr. Bruce C.  Jordan
                Director Emission Standards Division

        Subject:  Draft Sept.  27, 1991
                  Automobile  Refinishing
                  Control Techniques  Guideline
                   (Gun Cleaning)

    Dear Mr. Jordan,

    Our copy of the draft was  delayed in being received due to a zip code change
    and was only reviewed this past weekend, hence we are too late to obtain time
    for a presentation.  According to Mary Jane Clark, you can distribute copies
    of this letter to the committee.

    Our firm holds the basic  patents  on the predominate type of enclosed gun
    washers found in  body shops both  here in the USA as well as in most countries
    abroad identified in your  draft in Section 2.6 on page 2-15 and pictured in
    Figure 2-3 which  is commonly referred to as an Automatic-Enclosed Gun Cleaner.
    To help NAPCTAC we would  like to  place before the committee some additional
    information which is related to paint gun washing and "latest applicable
    technology" for cleaning  of paint guns and related equipment.  To accomplish
    this objective, a distinct differentiation is made between Automatic-Enclosed
    Gun Cleaners (Figure 2-3)  and the "typical open gun cleaner" described in
    Section 2.6 page  2-17 and  pictured in Figure 2-4 also known as a Manual-Open
    Gun Cleaner.  The major differences are compared below:
-------
        Differences             Automatic-Enclosed              Manual-Open

     1.  Closed  during               yes                             no
        cleaning

     2.  Cleans  guns without         yes                             no
        worker  direct
        participation

     3.  Cleans  multiple guns,        yes                             no
        cups, stirrers,
        strainers  and other
        paint related equipment
        simultaneously

     4.  Cleans  inside and           yes                             no
        outside of guns
        simultaneously

     5.  Workers are exposed         no                              yes
        to solvents during
        cleaning cycle


Much of  the draft  seems to paint both Automatic-Closed and Manual-Open Gun
Cleaners with the  same brush.   This overlooks key issues such as solvent
consumption, worker exposure,  cleaning cycle time, other items which must
constantly be cleaned along with the paint gun and simultaneous mult.iple gun
cleaning all of which impact on the VOC emission and worker exposure.

As a part, of the "improved housekeeping practices" referred to in Section 3.1
page 3-1, Automatic Enclosed Gun Cleaners can play an important role.  They
affect radically the amount of time required for cleaning guns, cups,
stirrers, strainers, etc.   reducing worker direct exposure to solvents while
limiting potential escape of V.O.C.  Over the old methods of cleaning, they
significantly reduce solvent usage and the amount of solvent which must be
maintained at the  shop.  Virtually all of the tools and related items which
need constant cleaning including strainers,  stirrers, and mixing vessels can
be cleaned in the  automatic gun cleaner at the same time the guns are being
cleaned  eliminating the need for multiple open containers for various cleaning
functions.

We take  issue with the final paragraph in section 3.4 page 3-10 implying that
"Open Gun Cleaners emit no more VOC than Enclosed Gun Cleaners." The report
referred to was submitted to SCAQMD in order to obtain a variance allowing
manual-open gun washers to be used in Southern California.  The report was
paid for by the waste hauler owning the rental equipment;  the test itself
varied from the testing procedure recommended by the SCAQMD, and did not
reflect  knowledgeable usage of the competitive units, totally ignored multiple
equipment cleaning which is essential  and used antiquated competitive models.
                                     1061
-------
With reference to Section 4.3.1.  page 4-14, it is possible that minimal
solvent could be emitted from closed gun cleaners, but this possibility was
virtually eliminated long ago by a redesign of the lid.   (See Attachment No.
1).  All Herkules manufactured or licensed units have or  will have soon
incorporated this feature.

The issue of escaping V.O.C., 4.3.1 page 4-14, during the loading (no hose
connections are required in our standard automotive Automatic-Enclosed Gun
Cleaners) is a valid concern and can be addressed two ways.  The first, way is
through education and the second way is through the use of a speed controlled
lid opener and closer.

Proper opening of the lid on any solvent container requires education.  The
worker does not want to create any more suction during opening and no more
fanning of fumes during closing than necessary.  Hence the industry needs
instruction.  A sample of such instruction for any vessel containing solvent
could read as follows:

                                  CAUTION:
                             READ BEFORE OPENING

    Solvent fumes are normally heavier than air and if not disturbed
    will remain in the container.  To prevent fumes from escaping,
    open and close lid slowly.

        1.  Open lid about one inch to equalize the pressure inside
            and outside.  Then open slowly, this mimimizes the escape
            of fumes through suction.

        2.  Do not slam lid during closing, lower lid slowly to prevent
            fanning which can cause fumes to escape.

In the Definitions Section 6.2 page 6-3 under the heading Gun Cleaner,
reference is made to being "vapor tight";  no gun cleaners in common use are
100% vapor tight.  In fact, if they were vapor tight chances of fume emission
would be increased during loading and the cleaner could become dangerous under
pressure as the content in most cases are extremely volatile.  For this
reason, we believe Sections 6.2 page 6-3, 6.6.2 page 6-10 and Appendix D, page
D-3 Gun Cleaners and Appendix D page D-5 Equipment Standards (d)  (1)  (iii)
need modification to read "reasonably vapor tight" not "vapor tight."

We are continuously trying to improve the design and application of cleaning
equipment to provide both the autobody repair and industrial paint industries
with "state of the art" equipment.  The draft does not take into
consideration the latest models of automatic-enclosed cleaning equipment which
have solved many of the VOC emission problems, for example:
                                     1062
-------
       Features

    1.  Double barrier lid
       design.
    2.  Speed controlled lid
       opener and closer.
    3.  Hose cleaning for
       pressure gun fluid
       lines.
    4.  Paint can and paint
       lid cleaning.
    5.  Combination gun and
       paint can washing.
Herkules Models
Containing Features

All Herkules models
GWR-lOO-vSS
GWR-3-100-SS
CWR-4-100-SS

GWR-3
GWR-3-100-SS
CWR-31
CWR-31-100-SS
CWR
CWR-1
CWR-31
CWR-31-100-SS
CWR-4
CWR-4-100-SS
CWR
CWR-1
CWR-31
CWR-31-100-SS
Result

Reduction of VOC emissions
during both active and
passive states.

Reduction of VOC emissions
during loading and un-
loading.

Reduces solvent needed for
fluid line cleaning, VOC
emission and the need for
open solvent containers
during cleaning.

Allows paint cans to be
reused as mixing or
storage containers,
reducing solid waste
generated in the form
of paint sludge.  Converts
quart, gallon and 5 gallon
cans considered hazardous
to non-hazardous reducing
disposal costs and re-
ducing the amount of
paint which is sent to
hazardous dump sites,
inside cans.

One cleaner cleans
both guns, cups,
stirrers, strainers, etc
and paint cans/lids.
In a  world of constant change, obviously it is impossible  to  take  all
available technology into consideration before approving the  guidelines.
With  minor adjustments to the draft including more specific wording  on
Automatic-Enclosed versus Manual-Open Gun Washers and changing  the concept  of
"vapor tight" to "reasonably vapor tight" the document should become an
acceptable guideline.
                                       Youxsvery truly,
                                       Richard A. Robb
                                       President
RAR/lw
-------
ATTACHMENT No.  1
   ORIGINAL
   ALUMIHUM
     LID
ALUMINUM
 FRkME
                HEW
              JILUM/NUM
                LID
VAPOR
SfAL
                                                              PL AST IO
                                                             \   TUB
                                                  GWf? LID /TUB FIT
                                                  PLASTIC TUB     "
                                                                  CORP
                                                BY LG
                                                    DOUKICSEAL LID
                                                   STMHLEZS 5TCCL TUB
-------
AUTOMOTIVE PRODUCTS
Technology and Planning
Wilmington, Delaware 19898
                                 November 14, 1991
   Mr.  Bruce C.  Jordan
   Director, Emission Standards Division  (MD-13)
   Office of Air Quality Planning and Standards
   U.S.  Environmental Protection Agency
   Research Triangle Park, NC  27711

   Dear Mr. Jordan:

                    COMMENTS ON THE AUTOMOBILE
             REFINISHING CONTROL TECHNIQUES GUIDELINE
               DRAFT FOR NAPCTAC REVIEW ON 11/21/91
             It is recognized that the subject draft guidance
   is in its early stages of development and therefore  subject
   to various changes.  Once it is completed and acted  on  by
   the various states, it will forever change how the
   refinishing industry does business and the kind of quality
   product and costs it can deliver to the ultimate customer,
   the consumer.   It is therefore very important that EPA's
   guidance document accurately describes the industry, what
   VOC reductions can be reasonably achieved, and that  it  is
   factual.  These comments are given in the hope that  what is
   presented here will help in that regard.

             In general, the draft guidance document as a  whole
   makes a good descriptive representation of the industry.
   The analysis given is quite complete and substantially
   correct.  Some treatments, however, have to be questioned
   and should be modified, corrected, changed, or described
   more fully.  First some comments of a general nature that
   will be followed by specific comments on the various
   sections in the document.

             EPA is aware of the Suggested Control Measure
   (SCM)  that has been developed by the California Air
   Resources Board (CARB) for the refinish industry for the
   more stringent requirements for ozone attainment under  the
   California CAA.  The SCM establishes RACT and BARCT  guidance
   after a long process of evaluation and interactions  with the
   industry.  Du Pont supports the SCM and has developed
   refinish systems to meet the RACT guidance.  As the  BARCT
   requirements are technology forcing, we are expending all  of
                         Better Things for Better Living
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our R&D efforts to satisfy the BARCT guidance for refinish
repair systems.  The refinish industry is a highly
distribution intensive industry with the added
responsibility of the paint suppliers having to train body
shop operations in the use of new, lower VOC repair systems
required for SCM based regulations in California.  It is
only logical and cost effective to have equal requirements
established in other jurisdictions.  It is readily apparent
that 30 or 50 different VOC requirements across the nation
requiring different technologies for each VOC level of
repair systems, and the thousands of color match
developments, would be beyond the capability of any paint
supplier, no matter how large.  It is therefore very
surprising to find the draft CTG document not acknowledging
the work done by CARB or the existence of the SCM.  It is
our belief that RACT established in the SCM is in fact
appropriate to be RACT for the CTG applied nationally.  The
BARCT standards in the SCM are technology forcing and
therefore do not constitute RACT for the proposed CTG.

          It is true that Du Pont, as well as our
competitors, are supporting the SCM standards and R&D work
is currently in place to deliver repair paint systems with
the specified VOC limits.  Whether they can be achieved by
us, or anybody else, only time will tell.  Inventions cannot
be mandated by a certain date.  Should EPA consider using
BARCT standards as an option for a possible RACT standard,
there are two difficulties.  By definition, BARCT is not
RACT.  Secondly, were state agencies or air districts to
adopt such standards into their SIPS, they become law and
cannot be relaxed.  Should industry fail to achieve these
technology forcing standards by a certain date mandated,
what then?  Do body shops cease to operate in that
jurisdiction?  For this scenario, it is necessary that the
CTG provide for some mechanism of alternatives until such
technology can be demonstrated.

          The subject draft guidance assumes that technology
transfers (from high VOC systems to lower VOC systems, to
waterborne systems, etc.) can be readily made without
extensive operator training, process changes, change in
productivity, change in quality, color match capability,
more frequent re-repair, or the cost structure beyond the
change in price for a gallon of paint purchased.  Such
uneven treatment is very unfair and very misleading and
should be corrected.  In fact, a lot of these effects will
force a lov. of the marginal shops to go out of business.
This will cause a realignment of body shop numbers, size and
type.  Competitive pressures will drop for the surviving
shops and costs will skyrocket for the consumer to get his
vehicle repaired.  Insurance rates will rise significantly
as well.  As an example of one effect:  In the proposed
Option 2 level controls in the draft guidance the suggested
limits for certain categories of coatings will dictate the

                          - 0
                          JL 0
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use of waterborne technology.  For primer surfacer
waterborne types have been recently introduced into Los
Angeles because of technology forcing regulations.  Topcoats
have not been demonstrated in this industry to date,
contrary to the implied availability in the draft document.
In any event, it can already be shown that waterborne
primers require 2 to 3 times the time to process; that is,
to apply, to dry, to sand, and time to topcoat than solvent
borne coatings.  The quality of the finish also changes.
Only time will tell whether such repairs will hold up to
expected performance standards, or more re-repairs will not
be necessary.  This situation is already causing a
realignment of body shops in the LA area.  Even if
waterborne topcoats were to be available, the same impacts
would also apply.  One would have to add the questions of
color match, aluminum flake gassing tendencies, and
performance properties.  It is obvious that this draft
guidance does not develop these issues and therefore does
not caution agencies as to the inherent difficulties that
technology forcing standards could present for the industry
as well as the agency's ability to achieve claimed VOC
reductions.

          Dividing the industry into eight arbitrary model
body shop segments pigeonholes the industry to a degree that
might not apply in actual fact.  (It is difficult to say
that a particular shop size uses 25% lacquer or 75% lacquer.
A lot of times his customer base dictates what he will use.)
Such categorization could mislead state agencies into making
misguided assumptions about emission inventories, reductions
that can be achieved, or the regulatory levels that should
be set.

          The draft guidance make a good case for the
effectiveness of using high transfer efficiency (TE) to
achieve VOC reduction.  In fact, they could be substantial,
far beyond reductions that can be achieved through coating
reformulations, and in combination could provide drastic
reductions of VOC from this industry.  Use of high T.E.
equipment is also very cost effective as the draft points
out.  However, then the draft backs out because its use is
not readily verifiable.  This position should be
reconsidered by EPA.  It is just as verifiable as running an
incinerator, absorption unit, or biodegradation unit.  They
all have variability that must be accounted for.  Some
procedure must be provided, if only through mass balance
accounting, to allow for T.E. credit.  EPA allows this
procedure for large sources, then why not for these small
sources. (See also comments below for Section 3.3.2.)

          Add-on controls, as Option 3, are dealt with quite
evenly in the draft guidance.  Whether the cost estimates
are low, high or about right is not at issue.  The analysis
plainly shows that they are prohibitive for this industry.

                          JL .' 3 8 7
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Adoption of Option 3 as the control method would drive 3/4
of the body shops out of business.  Option 3 should be kept,
however, as an alternate means of compliance for future
situations.  As the body shop population changes, or add-on
technology gets refined, add-on controls could become a
viable option for body shops.  Other than costs, this draft
implies that add-on controls are easy and viable for this
industry.  What the guidance does not point out is that it
has never been demonstrated in a commercial situation.  The
difficulty with this approach is that for technical reasons
it will not work for intermittent sources of emissions as
body shops invariably are.  It becomes virtually a nightmare
to effectively manipulate and manage the variables involved
for intermittent sources.

          It is critical that the document more clearly
shows that the composite calculations for multi-stage
topcoat  (basecoat-clearcoat and basecoat-midcoat-clearcoat)
are critical to allow setting of VOC limits for both Option
1 and Option 2.  Since any such limits are technology
forcing, this treatment of topcoat VOC will give coating
suppliers a good chance to achieving such reductions.
Failure to do so reduces such chances drastically.  EPA has
documentation in hand from the Bay Area and CARB when those
regulations and guidance were developed that show this to be
a critical component when setting VOC limits for topcoats.
Actual source data also supports this treatment when applied
in practice.

Specific Items Needing Attention

Sec. 2.1       Document states that industry does not deal
(Pg. 2-1)      with heavy trucks but is covered in another
               CTG document.  This is not true as that CTG
               deals with OEM situations not refinishing
               (repairing).  Thus, mobile equipment such as
               farm machinery, construction equipment and
               heavy duty trucks are not covered by the OEM
               CTG or this refinishing CTG.

Sec. 2.3.2     It is true that hardeners promote curing but
(Pg. 2-8)      are also used to increase gloss and/or
               durability.

Sec. 2.3.4     It is true that waterborne primers have been
               introduced in the SCAQMD and Texas Dallas/Ft.
               Worth area to meet the regulatory
               requirements there.  No waterborne basecoats
               are yet anywhere in commerce as this section
               implies.   (A non-coalition member advertises
               that such a product exists in SCAQMD.  It  is
               not found in any shops known to Du Pont.)   It
               is one thing to claim, but another whether
               reasonably available.
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Sec.  2.2.5     "Gun blending" as described does work when
(Pg.  2-4)       using high VOC coatings and conventional
               spray.  It becomes far more difficult to use
               this procedure effectively when dealing with
               low VOC coatings especially when coupled with
               higher T.E. spray equipment.  Even after
               extensive operator training this still
               remains a complicated task and leads to
               likely redo's.  See also Sec. 2.5.2 last two
               paragraphs to reflect the above reality.

Sec.  2.5       Airless spray guns should be air atomizing
(Pg.  2-11)     spray guns.

Sec.  2.5.1     Airless should be changed to air atomizing.
(Pg.  2-12)

Sec.  2.6       The guidance shows that some companies
(Pg.  2-17)     provide solvent recycling only to shops that
               rent their gun cleaning systems.  In our
               view, this is anti-competitive and strictly
               based on profit motive, and not very
               environmentally friendly.  It should not be
               sanctioned in a guidance document.

Sec.  2.7       Document implies that coatings manufacturers
(Pg.  2-20)     do not have the resources or time to devote
               testing product compatibility with
               competitors' coating.  That might be true,
               but the document should also show that such
               cross competitors combination testing becomes
               astronomical in scope, and if even possible,
               could confuse the user and produce many
               failures that would have to be re-done.

Sec.  2.7       Study implies OEM color usage could be
(Pg.  2-19)     restricted, or return to single stage
               coatings, would reduce VOC emissions.  That
               is not quite true.  Use of few colors will
               reduce complexity but use of single stage
               coatings over multi-stage will not reduce
               coatings usage as they are applied, at about
               equal film thicknesses.  Even if it were
               true, then at what costs?  Study should also
               point out that this approach would leave no
               domestic automobile industry in place!

Sec.  3.3.1     The assumption that twice as much clearcoat
(Pg.  3-8)       would not be needed might be true
               theoretically if solids content is the only
               criteria.  In practice, however, this does
               not hold, based on cost as well as how the
               two components get used.  Clearcoat in all
               spot repair and panel repair always gets used
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               over a larger area.  This is 90% of all
               repairs being done.  Basecoat, being the more
               expensive, always gets used as a minimum to
               get the job done.  Actual industry studies
               have validated this ratio consumption.  In
               fact, the ratio understates what it is in
               practice.

Sec. 3.3.1     Document states that Option 2 coatings are
(Pg. 3-5)      currently available, can achieve color match,
               but are not as widely used.  As already
               stated elsewhere, Option 2 coatings are not
               readily available, hence no color match
               predictions can be made.  All VOC levels in
               Option 2 are technology forcing.

Sec. 3.3.2     We agree that transfer efficiency is diffi-
(Pg. 3-9)      cult to verify.  However, the benefits of
               using such approach to control VOC emissions
               must not be ignored.  It can be documented
               that shops changing from conventional spray
               to HVLP, for example, cut their coatings
               purchases roughly in half.  This method of
               control reduces VOC emissions far more
               drastically than product VOC reductions
               alone.  In combination the VOC reductions
               that can be achieved can be over 80%.  EPA
               must find a way to deal with this issue.
               Past experience by EPA is for large source
               control, where testing procedures could be
               required to verify T.E..  Body shops are
               quite different sources, small and
               unsophisticated.  A method should be found,
               if no more than mass balance accounting, to
               arrive at some T.E. credit for VOC controls.
               In fact, the economic gain by shops could
               off-set some of the other costs accrued
               through regulations.

Sec. 3.3.3     This technology, use of supercritical gases
               as the solvent component in spray application
               is in the quite distant future and not as
               implied.  It is one thing to paint a
               recurring, monotonous article than to re-
               paint the ever changing repair of differently
               configured vehicles, especially for the many
               small color changes required.

Sec. 3.5.1     As stated in the general section, add-on
               control devices should be acknowledged that
               they are not feasible for intermittent
               sources.
                          1070
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Sec. 3.5.3.    Biofiltration might be an effective means for
               add-on control for emission streams that are
               constant and predictable.  In a body shop
               configuration the VOC emitted is intermittent
               and also varies from product to product used.
               It is questionable whether a given bacteria
               colony will digest the various VOC's
               uniformly.  This technology needs to be
               demonstrated for the body shop setting first
               before the guidance document should imply
               that it is or might be viable.

Sec. 3.7       Document states that waterborne basecoats are
(Pg. 3-17)     available.  This is disputed as presented in
               the general comments.

Sec. 4.2.1     The film thickness required for each
(Pg. 4-5)      coating shown have to be questioned.  For
               pretreatment wash primer (precoat) 0.1 to 0.5
               mil thickness is more likely than the 1.0 mil
               shown.  For primer surfacer a 1.5 to 2.0 mil
               is more representative than the 2.25 mils
               shown.  For primer sealer a 0.75 to 1.25 mil
               film is more representative than the 1.75
               mils shown.  For topcoats a 2.0 to 2.5 mil
               thickness is more representative than the 3.5
               mils shown.  In the case of topcoats the
               thickness represented can occur when highly
               transparent colors are used and extra film
               thickness is needed to get hiding.  EPA's
               information source should be checked to
               determine if information is average film
               build or maximum.

Sec 4.2.1      Assigns 35% T.E. to conventional spray.  It
(Pg. 4-7)      is more like 25-30% T.E. in practice.

Sec. 5         Table does not account for regeneration and
(Table 5.5)    disposal costs in the carbon adsorption
               column.  They could be significant even if
               such a service were available.

Sec. 5.5.2     In use of waterborne coatings, there is the
(Pg. 5-13)     potential to contaminate water discharges
               that the document does not point out.

Sec. 5.5.3     The disposal costs are not acknowledged for
(Pg. 5-14)     waterborne coatings which can be significant.
               Costs can be 6 times as high as solventborne
               wastes.

Sec. 5.6       It is interesting to note that the costs for
(Pg. 5-17)     the industry are not presented, only by model
               stages.  A quick calculation shows that for
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               Option 2 the industry costs are close to $600
               million as an average.  And this does not
               account for some of the productivity cost
               changes and insurance premium costs changes
               that need to be added as these comments have
               pointed out.

Sec. 6.2       Gun cleaners to be vapor tight needs to be
(Pg. 6-3)      fuller defined.  It should specify that it
               can't exceed x grams/hours of active losses
               and y grams/hour of passive losses or at
               least state "reasonably" vapor tight.

Sec. 6.2       Topcoat definition needs to define these
(Pg. 6-4)      multi-stage coatings to be controlled by a
               composite number arrived on the basis shown
               in Sec. 3.3.1 (Pg. 3-7).

Sec. 6.4.1     As pointed out earlier. Option 2 coatings are
(Pg. 6-6)      not readily available.

Sec. 6.4.2     We disagree with the finding that body shops
(Pg. 6-7)      could be required to use shared painting
               facilities.  This is blatant social
               engineering and goes against free trade
               practices and anti-trust principles.  It is
               one thing to let the free market produce such
               alignments, and quite another when it is
               commanded.  Also, the desire that is laid out
               for biofiltration in this section must be
               tempered with the comments made for Sec.
               3.5.3.
Sec. 6.5.3     It is important to state that the equations
               presented in Sec. 3.3 must be applied, not
               if, in order for industry to have a chance to
               achieve the VOC requirements recommended.

Sec. 6.6.2     Vapor tight needs to be defined as commented
               earlier.  (See Sec. 6.2 comment.)

App. D         Appendix, as currently drafted, is
               incomplete.  This should be redrafted to
               include all the findings of the document and
               the corrective comments provided.  This is
               critical as this is the output of a CTG that
               will be used by agencies to place into
               regulations.

App. D,a       Topcoat definition should contain the
               equations as laid out in Sec. 3.3.1.

App. D,d,l(iii)Vapor tight must be defined as explained
               above.
                              •n,
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App. D,c,3,(i) Topcoat VOC limits must include per
               definition given composite formula as in Sec.
               3.3.1.

Table 3-1      This table apparently represents in concise
(Pg. 3-6)      form the findings of the draft document.
               There are a number of difficulties here and
               might mislead state agencies in a number of
               ways.  First, the baseline VOC ranges given
               represents controlled areas' VOC emissions
               (California) not the uncontrolled emissions
               in the rest of the nation.  Our industry
               survey data to EPA clearly show the
               difference.  This will lead to agencies
               calculating wrong baseline emissions for
               their jurisdiction.  Secondly, the VOC limits
               for Option 1 and Option 2 seem to be set
               quite arbitrarily and are not properly
               documented.  It seems the kind of assumptions
               that were made are, as an example:  Since
               urethane coatings generally are lower in VOC
               content than others, the limits can be set at
               that level.  What it doesn't account for is
               that urethane coatings work well for overall
               repairs, but do not work well at all for spot
               repair work (the majority of repairs).
               Urethane coatings also do not give good
               metallic appearance and are difficult to use
               in spot repair that will duplicate the
               original finish.  As argued in the general
               comment section, this table for Option 1 and
               Option 2 VOC levels should follow the SCM
               determinations for RACT and BART VOC limits.

          We are pleased to have offered this analysis for
the draft CTG for refinish.  I am available to expand on
these items if EPA so desires.  I look forward to working
with EPA to develop a workable and reasonable CTG for the
refinish industry.

                              Very truly yours,
                              Karl R. Schultz
                              Environmental Consultant
KRS/kle
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December 2, 1991
Mr. Bruce Jordan
Director, Emission  Standards  Division (MD-13)
Office of Air Quality  Planning and Standards
U.S. Environmental  Protection Agency
Research Triangle Park, NC  27711
Dear Mr. Jordan:

I am supplying some  additional  information along with  a copy of
the presentation that we  submitted at the November 21 NAPCTAC
meeting.

Most of it is self-explanatory.   The  CARB document was referred
to by us fairly extensively  in  the our presentation.   The article
from an automotive refinish  professional  magazine supports our
arguments concerning the  deep rooted  extent of the product
systems nature of the industry  today.   Also,  the material from Du
Pont compliments similar  instructional material that was referred
to by Ron Hilovsky of PPG.

Also you should be receiving separate comments from many of the
members of the Coalition.

It was good to meet  you at the  meeting.   I have to tell you, in
all honesty I do not believe that I would have been able to hold
up as well as you folks did  in  those  marathon sessions.

If you need additional information, please contact me.
                                                                  ,National
                                                                 , Paint&
                                                                 Coatings
                                                               Association
Sincerely
Senior
       Counsel, State Affairs
Secretary to the NPCA Automotive Refinish Coalition
1500 Rhode Island Avenue, N~W • Washington, DC 20005-5597 • 202/462-6272 • FAX 202/462-8549
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                                                                  National
                                                             ^  'Coatings
                          POSITION PAPER                      Association

            OF  THE  NPCA AUTOMOTIVE REFINISH COALITION

                            CONCERNING

     DRAFT AUTOMOBILE REFINISHING CONTROL TECHNIQUE GUIDELINE

                          **************

                           Introduction

 The NPCA Automotive Refinish Coalition;   The Automotive Refinish
 Coalition was formed in 1988 under the auspices of the NPCA to
 work  for effective  and nationally consistent VOC regulations for
 the automotive  refinish industry.

 The active participants in  the Coalition are the six national
 manufacturers of  automotive refinish paints and coatings:  AKZO
 Coatings, Inc.; BASF Corporation;  E.I.  du Pont de Nemours; Nason
 Automotive Coatings;  PPG Industries, Inc. ;  and the Sherwin
 Williams Company.   Collectively,  these companies account for the
 lion's share of the total volume  of automotive refinish products
 that  are sold in  the United States.   These  companies also provide
 the majority of the training that is taken  by individuals to
 become proficient in the use of automotive  refinish products.
 The six individuals who represent these companies on the
 Automotive Refinish Coalition collectively  possess over 150 years
 of experience in  the industry.  They therefore are in a
 particularly good position  to comment on the industry's products
 and the underlying  economics and   operational requirements of
 automotive refinish facilities.

 The Coalition also  has as adjunct members a number of trade
 associations that represent user  segments of the industry.  While
 the adjunct members generally support the positions taken by the
 six manufacturer  members of the Coalition,  they have not had an
 opportunity to  review this  position paper.   Consequently, the
 positions taken should be seen as  representing only those of the
 six manufacturers.

 Objective of the  Coalition;   The  objective  of the Coalition is
 the development   of nationally consistent VOC regulations that
 achieve significant,  real and effective reductions in VOC
 emissions from  automotive refinish facilities while not imposing
 unnecessary additional  costs  or losses  in productivity on the
 automotive refinish facilities.

 Moving to lower VOC containing products  will create enormous
 productivity problems for automotive refinish facilities.  Our
1500 Rhode Island Avenue, NW • Washington, DC 20005-5597 • 202/462-6272 • FAX 202/462-8549
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concerns on this  score are particularly strong because the
industry has a  large population of small businesses.
Approximately 40% of the shops employ less than five individuals
and have sales  volume of under $150,000 annually, according to a
1988 EPA study  of the industry.

           Effective VOC Regulations  Must Recognize  and
    Incorporate Industry's Practices  and Operational Realities

To achieve the  objectives of significant reductions in VOC
emissions from  automotive refinish facilities at the least amount
of unnecessary  economic disruption to the industry,  a regulatory
program must incorporate fundamental technical, operational, and
economic features of the industry.

Achieving Adequate Matching of Repair to OEM Finish:  Achieving
an adequate repair that matches the existing coat so that the
repaired area is  imperceptible is the central requirement of the
industry.  Thousands of colors and coatings must be available for
all model years of the various car manufacturers to match the
many different  features of thousands of original coatings, such
as their color, gloss, and durability,  as well as the effects
that time and the elements have had on the OEM color and finish.
All of this must  be accomplished at facilities with far less
sophisticated equipment, under much more difficult and
uncontrolled circumstances than exist at the original equipment
manufacturers'  facilities.

Systems Nature  of Today's Products;  Today's products are
provided by individual manufacturers in the form of chemically
complex interrelated components to a single system.   The
components of a particular repair system must be used only within
the system of the particular manufacturer and pursuant to the
manufacturer's  instructions to ensure that the refinish job will
not fail.

Composite Calculation for Multiple Coat Topcoats is Essential;
The use of multiple coats involving a base coat for color and
clear coats for appearance and protection  as well as in some
cases a midcoat  is the predominate  original equipment
manufacturer (OEM) topcoat system.  The appearance of these OEM
topcoats must be  matched by the automotive refinish industry  and
consequently, the industry must use multiple coats in a topcoat
system.
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            Comments Concerning Regulatory Approaches

The RACT VOC Limits of the California Guideline for the Industry
Should be Selected as the RACT Limits for the CTG

The purpose of the CTG is to establish  technology that is the
presumptive norm for "reasonably available control technology"
(RACT) which must be implemented by states in their ozone
nonattainment areas.  EPA has defined (and Congress has accepted)
RACT to mean: "The lowest emission limitation that a particular
source is capable of meeting by the application of control
technology that is reasonably available considering technological
and economic feasibility.  RACT for a particular source is
determined on a case-by-case basis, considering the technological
and economic circumstances of the individual source.  (44 Federal
Register 53761, 53762 (September 17, 1979))

On the basis of this standard — a standard that emphasizes the
economic and technological feasibility of control technologies in
light of technological and economic circumstances of the
sources — the VOC limits that have been established by
California's Air Resources Board's  Automotive Refinish Guideline
for RACT under California's Clean Air Act (which has a much
tougher standard and program for ozone attainment than the
federal law) should be RACT for the national program.  (See
attached chart for the California Guideline RACT limits.)

While the terms "reasonably available" and "feasibility" are not
defined by the EPA, an ordinary dictionary definition of
"feasible" is something that is "capable of being used or dealt
with successfully;"  "available" has been defined in a manner
especially relevant to this discussion as "present in such
chemical or physical form as to be usable;"  and "reasonably"
has among its ordinary meanings "moderate, fair, and
inexpensive."  When the meanings of these terms are coupled with
the requirements of "economic and technological feasibility" and
the additional requirement that the feasibility of the control
technology be ascertained on the basis of the "economic and
technological circumstances of particular sources,"  then
whatever else RACT means, it certainly cannot mean  the
imposition of technology-forcing standards on existing sources.

The California RACT limits have much to recommend them for
adoption in the CTG.

First, by actual implementation in automotive refinish
facilities,  they have been proven to be currently "reasonably
available" and "technologically and economically" feasible.
Second,  they have been established by the toughest clean air
program in the country.   In this connection,  we note that the
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California Clean Air Act has  a much more  stringent  ozone design
value of  .09 ppm  as compared to the  federal  standard of .12 ppm.

The attached chart represents a comparison  of VOC reductions that
could be  achieved by implementing the California Guideline's RACT
limits.

According to the Study's Own  Findings. Option 1 and Option 2
Limits Are Technology-Forcing Standards;  They. Therefore. Are
Completely Inappropriate for  the CTG

By the study's own statements, Options 1  and  2 represent
"technology-forcing" VOC limits, requirements that  are not
currently "reasonably available" as that  term is defined by the
EPA.  Therefore, these options do not qualify as RACT.  Moreover,
if the base coat/clear coat composite calculation method is not
employed, then the limits specified for topcoats under both
Option 1  and Option 2 are not only  "technologically and
economically infeasible" for  the "particular  sources" of
automotive refinish facilities, they  are  absolutely impossible to
achieve with today's technology.

The study indicates that lacquer product  systems are still widely
used by many of the smaller shops that do not have  spray booths.
(See pages  2-7, 2-20 through 2-25 of the study.)   The study also
assumes that such shops constitute  approximately 30% of the
industry.  (See Table 2-1 at  page 2-22.)  Moving these shops away
from lacquer products to other more difficult to use and slower
drying products will be difficult and very  costly.  The
unmistakable implication of the topcoat limits of Options 1 and 2
is that a large number of the industry's  smaller shops will be
put out of business.  The study estimates that the  cost of a
spray booth would be approximately $30,000.   We believe that this
estimate  is low.  And most of these shops are currently grossing
at most $150,000 per year.  Few if any banks, especially in
today's economic climate, would lend  the  amounts needed for such
a capital outlay to the smaller shops.  Consequently, topcoat
limits of Options l and 2 which would prevent the use of any
lacquer system  do not represent a "currently"  "reasonably
available control technology" as judged on  the basis of
"technological and economic feasibility"  of these "particular
sources."

The study also states that, "Option 1 VOC limit had the reported
disadvantage of poorly matching OEM colors  (especially
metallics), indicating that they are  best suited for complete
vehicle refinishing jobs."  (See page 3-4.)   In view of the fact
that the  study also finds that the "..-. the OEMs use metallic and
*pearl' coatings on at least  50 percent of  all new  vehicles	",
it should be clear that the Option 1  VOC  limits do  not constitute
"reasonably available control technology" for this  industry.
Establishing the Option 1 or  2 limits, according to the study's
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own findings and conclusions, would in effect mandate that a
larger proportion of the repairs be accomplished by complete
refinish jobs.   This would necessarily result in the emissions of
more,  not less,  VOCs and would fail to achieve the fundamental
objective of RACT — achieving reasonable further progress
towards attainment.   Additionally, there is the question of
whether establishing VOC limits that "poorly match OEM colors"
for 50% of the vehicles the industry repairs constitutes a
"technologically and economically feasible" control technology
for an industry  that has as its sole reason for being the ability
to make repairs  so that the repair is imperceptible.
The study also contains a number of misleading assumptions
concerning the VOC emissions that should be associated with the
industry's products and operations.  The first of these involves
assuming that the VOC content of products that are supplied to
areas which currently have regulations constitute the baseline
"current technology" of the industry's products that are
generally used in the United States.  (See Table 3-1 at page
3-6.)   In fact,  the majority of the products supplied by the
manufacturers are to areas for which no VOC limits for their
products exist,  including the vast majority of current ozone
nonattainment areas.  Defining baseline technology as the study
does would lead  to  a gross understatement of the contributions
in VOC reductions that properly should be attributed to this
industry introducing lower VOC containing products to areas that
heretofore have  not required  lower VOC containing products.  The
Act's new requirement for reducing by 15% overall VOC emissions
in the top four  categories of ozone nonattainment areas by 1996
will place extraordinary pressures upon all sources to reduce
their fair share of VOC emissions.  Thus it is essential that the
CTG accurately characterize the existing VOC emissions from this
industry in these areas to ensure that it is not tasked with
regulations that exact an unreasonable contribution in VOC
emissions reductions.

Additional misleading statements and assumptions in the study
concern the following subjects:  the statement concerning current
usage of coatings that implies that all coatings material
supplied to refinishers are in fact applied, when approximately
20% — 25% in practice is wastage and is disposed of by
incineration in  which there is no release of VOCs; overstatements
of the required  or recommended film thicknesses; and
overstatements of the paint consumption in each of the coatings
categories.  These are more fully discussed in the submission
from BASF.

We anticipate the argument that since the  California Guideline
1992 limits are  just around the corner and that since some of
these limits are more stringent than comparable limits in Option
1,  the manufacturers should be able to meet the limits of Option
1 nationwide if  they can meet the California 1992 VOC limits in
California.  In  answer to such an argument, we point out that the
                                 701
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products that are needed  to meet  some  of  these limits,  especially
the topcoat limit,  are  still not  yet at a stage of development
that would allow the manufacturers to  introduce them  into
facilities without  substantial expenditures  in time and
resources.  These products will require the  use of spray booths,
which the study itself  notes are  not widely  used by  the smaller
shops which makes up about 30% of the  industry.  Moreover they
will require the use of drying equipment,  because  the products
will be mostly waterborne products with substantially longer
drying times.  In order to maintain today's  levels of
productivity in terms of  the number of vehicles that  are
completed substantial expenditures for drying  equipment will be
required.

Finally there is a  question of scale involved  here.   It should be
noted that the California 1992 limits  will be  confined  only to
certain air quality districts in  California.   While the
manufacturers may have  sufficient resources  to weather  the
problems and expenditures that will be associated  with
introducing these products into   a limited number  of  areas in
California, imposing similar requirements  nationwide  results in
an effect on the manufacturers that certainly  qualifies as
"economically infeasible."

We realize that the EPA is interested  in crafting  a CTG that
accurately reflects what  can  be  accomplished  by the  industry at
the time the CTG is published and that it  is confronted with the
difficulty of a moving  target in  the technologies.  The six
manufacturers have  expended literally  tens of  millions  of dollars
thus far in efforts to  develop lower VOC products  and the EPA is
right to anticipate that  these efforts will  continue.   But this
problem  of RACT being  overtaken  by new developments  is addressed
in the newly amended federal Clean Air Act. which now  requires
that the EPA periodically revisit CTGs to  determine if  technology
has moved ahead of  existing CTG standards.   We suggest  that this
is the only appropriate process recognized by  the  Act for
introducing technology-forcing factors into  developing  CTGs.
Requiring technology-forcing limits in the CTG itself is
completely at variance  with the essential  "reasonably available"
nature of a RACT standard.

We have another suggestion by which this current effort to
determine an automotive refinish  CTG could avail itself of new
technologies that might be available at the  time this CTG is
finalized.  If this CTG development process  takes  until 1993 to
be finalized, it is possible that the  experience gained in
meeting the California  Guideline's 1992 limits in  California will
demonstrate by then that  the Option 1  limits  and  perhaps some of
the California 1992 limits are in fact "reasonably available" in
terms of their "economic  and technological feasibility" for
national implementation.  We note, however,  that,  with  respect to
the California 1992 limits, the industry at  the present time
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does not have a sealer that would meet the limit specified for
this coating.  Because of this and other potential problems of
introducing such advanced systems nationwide, at the present we
believe that a lead time for implementing such limits would be
needed, e.g., implementation in 1994 or 1995.

The Necessity of Base Coat/Clear Coat Averaging For Determining
the Topcoat Limits

The multiple coat system of topcoats is the current predominate
topcoat technology of the automotive manufacturing industry and
the refinish industry must be able to match these topcoats.
Using a composite calculation for the VOC content of the base
coat and clear coat in a topcoat system to determine compliance
with the topcoat VOC limit is dictated by the actual day-to-day
"technological and economic circumstances11 and practices of the
industry.

A statement of the study which may account for the failure of the
CTG Model Rule to include  a base coat/clear coat composite
calculation method is an apparent misunderstanding  of the basis
for weighting base coats and clear coats at a ratio of 1 for base
coats to 2 for clear coats.  The ratio is based upon the actual
usage of the industry.  It is the industry experience that the
volume of base coat paint that is used for any given repair is
approximately on half the volume of clear coat that is used.   In
this connection we refer you to the information that has been
provided by the BASF Corporation which is based upon the actual
usages at an automotive refinish type of operation at the Saturn
General Motors plant and by the Sherwin Williams Company.   In
fact that experience indicates that the ratio is higher, e.g.,
for 1 gallon of base coat, 2.3 gallons of clear coat are used.
The study assumes that because clear coats are a higher solids
product than are base coats, then the volume of clear coat
material that is needed to repair the are covered by the base
coat should be twice  the volume of base coat material.  The
major reason  that the industry generally uses twice the amount
of clear coat material as it does base coat material is the need
to achieve adequate color and finish match for spot repairs that
requires that the clear coat in general be extended far beyond
the area covered by the base coat.   About 90% of the automotive
refinish work that is done is spot repair.

The Systems Nature of the Industry's Products

Because the chemistry of the individual components of a repair
system is highly interdependent,  the components of a particular
manufacturer's system must be used according to its instructions
and cannot be interchanged with the products of another
manufacturer.  The systems nature of today's repair products has
two very important implications for a regulatory system that
limits the VOC content of the products.  First, regulators can
                             If;81
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have a great deal  of  confidence that  refinishers will not attempt
to match relatively higher VOC components of one manufacturer's
repair systems with those from another and that therefore the VOC
levels associated  with  a particular system will be complied with.
Secondly, the regulations cannot simply select the lowest VOC
components of the  available repair systems and dictate that these
components be incorporated into every repair system.
and in the right amounts.  As a recent article from an automotive
refinishers professional magazine points out:

     [T]here is no margin for error in applying or mixing today's
     products.  The paint company chemist was able to create a
     product to suit, but only if you do exactly as he says.  Not
     only must the painter combine the correct solvent, catalyst
     and topcoat in the correct percentages, but it must be
     applied over  the correctly mixed undercoats at the correct
     time... There is only one  right way to use today's
     finishes; exactly  according to directions and using only one
     brand.

Auto refinishers will not act as their own chemists; they will
follow the manufacturers' instructions or risk a failed job
without the protection  of a warranty.

Another feature of the  industry that  supports the conclusion that
automotive refinishers  will comply with the VOC limits specified
for products is the VOC compliance instruction material and the
training that is supplied by the manufacturers to users of their
products.

The Need for Specialty  Coatings

It also is essential  to recognize the need for relatively higher
VOC containing specialty coatings.  These products constitute a
very small percentage of the products used by the industry but
they are essential to effectively accomplishing certain repairs.
An important example  of these are  "uniform finish blender"
specialty coatings to make spot repairs.  This specialty coating
blends the repaired area in with the  surrounding original finish
to match all facets of  its appearance, including color, metallic
orientation, texture, and appearance.  Greater VOC emissions
would occur if refinishers do not have the ability to perform
spot repairs because  they would be required to paint an entire
panel of the vehicle  or the entire vehicle itself in order to
achieve acceptable results.

We recognize that  the model CTG includes the category of
"specialty coatings."   But its characterizing them as being
"reportedly" needed for unusual job performance requirements,
however, concerns  us  because that implies that the need of these
products is debatable.  The special role of specialty coatings
should be emphasized  by the CTG.  It  should not be implicitly

                                8
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questioned by the CTG which might invite states to modify the CTG
by removing the category.

We also recommend that the California Guideline's definition of
specialty coatings should be adopted.  The definition does not
limit the type of coatings that can fall into this category but
restricts the coatings to 5% the total volume of coatings applied
by an automotive refinish facility.  This approach allows for the
development of additional specialty coatings and the 5%
restrictions ensures that the category will not be abused.

The Gerieral Use of HVLP Spray Guns Results in Significant
Reductions of VOC Emissions and Should be Encouraged

The efficiency of transferring coatings to the vehicles has been
greatly improved by the use of high volume, low pressure (HVLP)
spray guns.  The resulting VOC reductions that accompany the
reduced amount of coatings material that is required because of
the improved transfer efficiency should be explicitly recognized
by the regulations.  To do otherwise deprives this industry of
having credited to it significant VOC reductions that in fact
result from the use of HVLP spray guns.  The unwillingness of the
EPA to explicitly recognize and to credit VOC reductions
associated with the use of the equipment is a hidebound adherence
to notions concerning "quantification" and "replicability" of VOC
emission reductions.  These principles were established for a
regulatory regime that focused on well-heeled and richly staffed
large stationary sources which lent themselves to such precise
demands for crediting VOC reductions.  The 1990 amendments to the
law, however, require the regulation of much smaller sources and
therefore the EPA's  VOC emissions reduction accreditation
principles must be retailored to measure the effectiveness of
regulatory controls that are appropriate for the much smaller
sources.

As the study notes, appropriate training has a great deal to do
with the efficacy of HVLP use.  In this connection,  it should be
recognized that extensive training is provided in this area by
the manufacturers of automotive refinish coatings and others.
Further, aside from the regulatory requirement to use such
equipment, autorefinish facilities have a very strong economic
incentive to use the equipment to reduce their consumption of
coatings.

It also should be noted here that the study seems to assume a 35%
transfer efficiency for the conventional spray gun but is
unwilling to assume any transfer efficiency for the HVLP-  This
is anomalous in that any problems that are associated with
achieving effective transfer efficiency with the HVLP spray gun,
such as variability in operator use and the shape of the object
being coated, also apply to conventional spray guns.
                             1-83
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The experience of the Coalition is that the use of HVLP spray
guns results in reductions of 20% — 45% in materials usage and
some credit for the resultant VOC reductions should be given.

Add-On Controls

The various engineering add-on control technologies identified by
the study for facilities would be cost prohibitive and or
technologically infeasible for the great majority of automotive
refinish facilities to adopt at this time.  Nonetheless, the
regulations should recognize such controls as voluntary
alternative control techniques that could be used in lieu of
lower VOC containing products.  The technology of add-on controls
could improve in the near future, perhaps rapidly,  and they
could come to represent cost-effective alternative compliance
methods.
                           Conclusion

The objective of the CTG is to establish a guideline for what is
the presumptive norm for "reasonably available control
technology" (RACT) under the federal Clean Air Act.  In
developing such a guideline,  the "reasonableness" of the
technology is to be considered as well as both its
"technological" and "economic" feasibility-  On the basis of
these criteria and our knowledge of the industry — the available
coatings technology and the operational and economic requirements
of automotive refinish facilities — we believe that the VOC
limits specified for RACT in the California Guideline should be
the limits established by the CTG.  The adoption of these limits
from a program that is much tougher than the federal program will
ensure that the industry contributes more than its fair share of
VOC emissions reductions in the nation's ozone nonattainment
areas.  We also believe that specialty coatings must be
explicitly recognized as an essential technology for the industry
to achieve VOC emissions reductions.  Further,  it is absolutely
critical that the multiple coat composite calculation technique
for determining compliance with VOC topcoat limits be recognized.
This is the way the industry applies the topcoats and it is the
only way that VOC limits for increasingly waterborne topcoats can
be met.  The contributions made by HVLP spray guns should also be
recognized by the CTG.  Finally add-on controls should be
recognized as a voluntary alternative compliance method.

The possibility that the Option 1 or even some of the California
Guideline's 1992 VOC limits may be demonstrated to be "reasonably
available" by the time the CTG is finalized in 1993 is also worth
considering.  The six manufacturers would concur in such an
approach provided that before the limits are adopted as part of
the CTG, the technology has in fact been shown to be reasonably
available and that an appropriate lead time is afforded (e.g.,
until 1994 or 1995)  to ensure that the products in fact are
"reasonably available."

                                10
                                  O F
                                   '
-------
ON OF VOC EMISSIONS REDUCTIONS

                GARB'S GUIDELINE
% Of
Total Coatings
2 CTG GARB Coatina Cateaorv

31%
-
6%
9%
5%
-
9%
8%
0%
0%
•
2% . 1%
. 1%
12% . 12%
*
•
5% . 5%
»
58% . 17%
. 41%
•
8% . 8%
•
•
10% . 10%
•
5% . 5%
•
Pretreatment Wash
Primers
Precoats
Primer/Primer
Surfaces
Primer Sealers
Topcoats***
Metallic/
Iridescent***
Surface Cleaning
Enclosed Equipment
Cleaning
Specialty Coatings
Transfer Efficiency
Baseline GARB
VOC RACT

6.
6.
6.
6.
6.
6.
6.
6.
7.

7
7
7
7
7
8
7
7
0
25%

6
6
6
6
6
6
1

.5
.5
.0
.0
.0
.0
.7
88%
7
.0
45%1
•s

0.
0.
2.
2.
3.
8.
6.
0.
2.
0.
GARB'S
1992 Limits**

1%
1%
3%
3%
2%
7%
0%
8%
8%
0%

6.5
6.5
2.8
3.5
5.0
5.0
1.7
98%
7.0
45%1

0.
0.
12.
4.
22.
19.
6.
0.
2.
0.

1%
1%
6%
3%
8%
5%
0%
8%
8%
0%
0%
GARB GUIDELINE

Reductions Achieved    -0-
26.3%
69.0%
y data.  Should be based on uncontrolled emissions survey data.

n 1994 - 1995 once technology has been demonstrated in California in  1992
Calculations.
ies in column expect for enclosed equipment cleaning and surface cleaning.
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                                                                 National
                                                                'Paint&
December  2,  1991
                                                             Association

               NPCA Automotive Refinish Coalition's

                  Additional Comments Concerning

         Technical and Factual Issues Raised by "the Study

The  study is an attempt to  review and  analyze the  current
technologies,  economics, and  operations of the  automotive
refinish  industry to determine the reasonableness  and technical
and  economic feasibility  of  VOC emission reduction  technologies.

The  study,  in  our view, represents an  honest effort  to portray
the  industry accurately  and  demonstrates a sound  grasp of the
basic  features of the automotive refinish process.   Nonetheless,
it contains  a  number of implications,  statements,  and conclusion
that are  inaccurate or misleading.  Since the study  will be the
basis  for standards that will be adopted for this  industry
through a CTG, it is important that it accurately  reflect the
real world of  this industry.

The  following  are a number  of points of disagreements or areas in
which  we  believe a fuller picture is required than what is set
out  by the study-

General Overview of the Industry

We have reservations concerning the characteristics  that the
study  assigns  to various shops as model shops.  This is not to
say  that  we  disagree with all of the study's characterizations or
that we so not appreciate the difficulties associated with
efforts to get a handle on  an industry as diverse  as the
automotive refinish industry.  Nonetheless, we  urge  caution in
extrapolating  from these model shops  to real world  shops.  Some
shops  —  perhaps many — will not fit  neatly into  anyone of the
models.   This  is particularly true with respect to the types of
coatings  that  may be employed by various shops.

The  study also seems to fail  to grasp  the fact  that  coatings
reformulations are not easily accomplished.  Besides the very
difficult task of having to reformulate literally  thousands of
colors to match the diverse automotive population, these new
coatings  must  be transferred  effectively into the  production of
the  shops.   When the coatings become increasingly  waterborne,
they become  much more difficult to reformulate  and they become
even more difficult to train  the end user in how to  use them
effectively.   Lower solvent products are more difficult to use
and  are less forgiving of mistakes.  The transition  to waterborne
products  is  an extremely difficult task and should be recognized
as such.

                              1. -88
1500 Rhode Island Avenue, NW • Washington, DC 20005-5597 • 202/462-6272 • FAX 202/462-8549
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Coatings Issues

There are several statements in the study which misapprehend the
technologies of current or future coatings or the usage of such
coatings by the industry.

The most important misunderstanding concerns the base coat/clear
coat technology for topcoats.  Actual industry usage of these
coatings demonstrates that the coatings are in fact used at a
ratio of more than 2 clear coat materials for 1 base coat.  The
primary reason for this is that in applying the clear coat in
spot repairs, the material must be extended beyond the repaired
area to match the original finish.

The systems nature of the industry's coatings also is not fully
understood by the study.  The systems nature of today's coatings
is a fundamental fact of the industry and it applies to the
entire range of coatings, including undercoats and not just
topcoats.  The failure of the study to fully understand this
leads to a number of misleading assumptions.  An example of this
is the implication at page 2-8 that non-isocyanate hardeners are
generally available to replace isocyanate hardeners.  In fact
this is not true if the product system involved is based on
isocyanate products.  Also, the study's definition of coating
"system" at page 6-2 limits the systems to primer-topcoats.

The components of automotive refinish product systems are
designed to work together only within a particular manufacturer's
system.  At page 2-20, the study implies that the components
could be made interchangeable if the manufacturers spent
sufficient time and money on the effort.  As an abstract
statement, this comment is true.  But it fails to recognize the
tremendous costs of such an undertaking to the manufacturers and
to the shops and the public in the form of failed jobs.
Additionally, the product differentiation that accompanies the
systems approach is a valuable incentive for the manufacturers to
continually improve their products secure in the knowledge that
technological breakthroughs that for example lower the VOC
content of products will not be easily replicated by their
competitors.

The industry is moving to waterborne products.  That is a fact of
life and the manufacturers have spent tens of millions of dollars
to develop these type of coatings.  Nonetheless, these coatings
are not yet generally available as is implied by the study at
page 3-17.  Also the statement that waterborne higher solids
primer sealers are simply "lagging" is also misleading — they
are much further away from being practical coatings than
"lagging" implies.  Perhaps some of the confusion on this point
arises from the study's understanding of what constitutes a
waterborne coating.  On this score the study at page 2-8 implies
that waterborne systems have only 5%  water as their volatile
-------
fraction.  In fact, the industry considers a product waterborne
when it has 85% of its volatile fraction as water.  Also the
study fails to adequately address the additional  waste  water
disposal costs that will attend the wider use of such products.

On a related subject, at a couple of points the study indicates
that the key ratio for determining the VOC content of a product
is its solvent/solids ratio.  (See page 3-4.)  We agree with this
concept but believe that the  "less water" calculation technique
required by the EPA for determining the VOC content of products
is at variance with this fundamentally sound notion and should be
changed accordingly.

Also with respect to waterborne coatings the study fails to take
adequate account of the additional hazardous wastes that will be
generated by the wider use of such coatings and the attendant
disposal costs.  (See pages 5-13 and 5-14.)  Nor does it
adequately weigh the losses in shop productivity that will
accompany the wider use of the products. (See page 5-17.)  Drying
times will increase greatly and shops without drying booths will
be reduced to completing one half to one third of the vehicles
that they now can complete with solvent borne products.  The
ability to refinish vehicles at a reasonable cost will disappear
and the insurance premiums consumers have to pay for collision
insurance will increase dramatically.

The study also grossly overstates the current volume of products
that are used by the industry- (See the comments from  BASF.)  At
pages 2-3 and 2-4 the study wrongly suggests that a pretreatment
coating is exclusively used with solvent borne systems and a
precoat is exclusively used with  waterborne systems.  Further,
the discussion of adhesion promoters at page 6-2 should be
clarified to make clear that the material is also applied at the
edge of the unsanded area.  In a related point, the study fails
to recognize adequately that specialty coatings constitute  a
very small percentage, less than 5%, of a shop's total coatings
usage and that these products are critical to the shop's ability
to effect certain repairs.  While it is true that these coatings
are higher VOC products, they constitute such a small percentage
of usage that it makes no sense to focus on lowering their VOC
content when the R&D efforts could be better put to reducing VOC
levels in the larger volume products.


Technology Issues

The study contains  number of factual statements concerning
technology issues involving spray booths and HVLP and
conventional spray guns that are misleading.

As to the spray booths, the study at page 2-9 implies that all
coatings are applied in a spray booth.  In fact a number of
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coatings,  particularly undercoats, are generally not applied in a
spray booth.  The implication of this is that waterborne products
that are used for undercoats generally would not be accommodated
in a spray booth that could reduce drying times.  Hence, the
widespread introduction of the waterborne products would as
things now stand greatly reduce productivity at many facilities.
In this regard the study greatly understates the costs of
introducing the technology, by focusing exclusively on the costs
of the products and capital equipment.  In fact, significant
productivity losses will accompany the use of waterborne products
and these costs must be taken into account in evaluating any
regulation that would impose them.

As to spray guns, we address the need to recognize the efficacy
of HVLP guns in the body of our comments.  As we state there,
HVLP spray guns do reduce VOC emissions and should be properly
credited for doing so in the CTG.  The study acknowledges at
various points that transfer efficiency in the use of the HVLP
guns can be greatly enhanced through appropriate training and at
page 3-16 stresses the important role played by the manufacturers
of automotive refinish coatings in providing this training.  It
is ironic that much costlier and in our view questionable add-on
controls are considered as potentially effective by the study and
yet the efficacy of a reasonably priced piece of equipment like
HVLP spray guns receives such short shrift.  The study should
recognize the importance of this relationship and see the
manufacturers as more of a partner in assuring lower VOC
emissions from automotive refinish facilities.  In the same
connection, however, the study fails to recognize certain
inherent difficulties that are associated with the use of any
spray gun by implying at  page 2-4 that blending the edge of the
refinish area with the original topcoat could be achieved as
readily through use of the spray gun as it is achieved through
the current practice of employing more dilute blend coats.

The discussion at page 2-15 of the problems of introducing
electrostatic spray guns into automotive refinish shops  merit a
fuller treatment, especially the great risks of fire and of
electrocution that arise if this equipment is not used in
accordance with very strict operating procedures that will be
difficult for many shops to observe.

Add-On Controls

Add-on controls are dealt with fairly evenly by the study at
least in the conclusion that such controls are not presently
generally feasible for the majority of automotive refinish
facilities.  Whether the study's cost estimates for these
controls are accurate (and we believe that they understate the
costs greatly), in the end the study reaches the  appropriate
conclusion that such controls should not be imposed on automotive
refinish facilities as RACT.  We might add that in our opinion,
-------
imposing such controls on the facilities would drive 75% of the
existing shops out of business.  And some of the technological
assumptions concerning such controls are very misplaced.  For
example, it is inconceivable that with today's technology that a
biofiltration system would work at any automotive refinish
facility.  The VOC emissions are simply too varied for any body
of microbes to handle effectively.  Also, incineration is simply
not an effective control technology for automotive refinish
facilities because of the intermittent nature of the emissions.
As to carbon absorption, the study  fails to consider adequately
the costs associated with maintaining such a system, the
decreasing ability of the carbon filters to absorb pollutants
each time they are cleaned, and the hazardous waste that would be
generated by the use of the system.

Despite the admitted problems with add-on controls, we believe
that such technologies should be recognized in the CTG as a
voluntary alternative compliance option.  As the population of
automotive refinish facilities changes, in part due to the VOC
limits, and as the technology of add-on controls improves, this
technology could become more viable and we believe that the
technology should be recognized as a voluntary alternative
compliance method.  The modified version of the SCM which we are
suggesting as the model for the CTG contains such an alternative.

Discussions of Costs

The study's discussion of the additional costs that would be
associated with moving to more waterborne coatings do not address
what will perhaps be the greatest costs associated with their use
— losses in shop productivity.  For shops without drying
equipment the use of these products could well cut their ability
to refinish vehicles to one half or a third of what it is today.
Additionally, the costs of R&D  that are incurred by the
manufacturers of the coatings are not counted nor are the costs
that will be incurred in introducing these more difficult to use
products, including job failures that will inevitably accompany
the widespread use of the products initially.

Appendix D of the Study

Appendix D of the study, whether intended or not, represents the
distillation of a draft CTG that may be picked up by the states
before the CTG process is completed.  Our concerns here are
particularly strong because of the requirement of the federal
Clean Air Act Amendments of 1990 that call for the adoption of
RACT by many ozone nonattainment areas by 1992 — the so-called
"RACT Catch-Up" requirements.  In reconciling  this 1992
requirement with the 1993 due dates for new CTGs, including the
automotive refinish CTG, the EPA has stated that states may use
draft CTGs.  We have had some indication that the regulations set
out in Appendix D  will be substantially modified in the final
                             T w O |
                             JL ii J1
-------
CTG.   We strongly urge  that Appendix D be eliminated from the
study to avoid any confusion on the part of the states during the
interim.
-------
           OSfPDKD
    VOC DATA
EETS
Jr. 1

cs
ro
          RULE 1151
 H.17T.M
-------
The following VOC data is being provided to you to meet the requirements of the South Coast Air Quality
Management District'.1; Rule 1151. It /.v divided into the following pa gen for easy reference,
Page 1        An explanation of each category of the Du Pont COATINGS USAGE CHART used to record daily
             VOC emissions.

Pago 2       An example of a completed COATINGS USAGE CHART.

Page 3-6     VOC data for surface cleaner, precoal coating, primer, single stage, basecoat, and clear. This data is
             reported on maximum VOC and pounds per gallon less water and exempt solvents basis.

Pago 7       Calculation for LI3S of VOC' when divided by the amount actually sprayed.

Pago 
-------


' 1-l|e i'amier Name
or
Initials


7-1 John Doe



\- ''
gs
^
Ooalinps: Puini
Surface Prop, C
Manul. Type
&
Code

Example 1
B 8635A
Example 2
210S
Example 3
B8635K
Example 4
7500S
, Primer
,'lenmip Solvent
VOC VOC less
(g/1 or Waicr &
Ihs/gal) |less exempt

Solvent
i . .
5.2 r 5.2

0.6

5.9


1.9 1

5.9

5.3 5.3

Oil nly si /I liirdoiuT/Addilivc
Miiniil'iii'liiiei i VOC
& 1 (g/l or
Code


793S

-

-

7575S
Ihs/gal I


1.9

-

-

4.2
VOC' less
Water &
less exempt
Solvent

1.9

-

•-

4.2

Tli iniuT/R (Mincer Solvent
Manufacturer
&
Code


V-8096S

-

V-7I60S

-
VOC
(g/l or
Ihs/giil)


6.9

-

6,6


VOC less
witter &
ess exempt
Solvent

6.9

-

6.6

-

Total amount of
comings used



1qt.

1 qt.

2qts.

3qts.
Mix Ratio Gross VOC VOC "a- L.:^
Coaling/ Vehicular ";!•. applied" Applied" k"-< c'f VOC
Solvent Weight water & !e«
exempt solvent
i
8:1:2 : II 5.2 5.2 1.3
I
RTS i II - 1.9 .5
I
1:1 ; II 6.2 6.2 3,1
i
4:1 | II 5.1 5.1 3.8
-------

,m- I'niniL'i Njuno
"or
nilials
A B
Coatings: Paint, Primer
Surface Prep, Cleanup Solvent
Mamil. Typo VOC
& t.g/1 or
Code Ihs/pal)
C D
i
VOC less
Winer &
less exempt
Solvent

Cntnlyst/Hnrdcncr/Addilivc
Maiuifiieiurer
&
Code
F
VOC
(U/l or
llw/giil)
G
v(x: less
W.-iicr &
less cxempi
Solvent
H
Thinner/Reducer Solvent
Miimil'iieiuri:r
&
Code
1
voc:
(g/lor
Ihs/gal)
J
VOC less
wilier &
less exempt
Solvent
K

Total amounl of. Mix Ratio. Gross VOC VOC "a« l.r>v
coalings used ! Coaling/ '• Vehicular "as applied" Applied" lc« tn' VOC
(quarts or gal) | Solvent i Weight water & lc«
j : exempt solvent
L M ! N 0 P Q
i 	 '"! 	
                                                             Coatings Usage Chart Explanation
     ,J\
The date in which the material is sprayed.

I'hc name or initials of the painter actually spraying,

The formula or product number. (Include the total alpha-numeric formula.)

I hr m.minimi Vl)('  nl ihr individual i/oaliiu1, without ivdnirr in  eaialyM. as lislcd in
ihe On Pont VOC Data Sheet. (The ColorNet computer or microfiche lists VOC' of
each color coating.)

The VOC in this column is (lie same as "D"  *

This column is Cor hardeners or catalysts,

The VOC of (lie individual hardener or catalyst, obtained from VOC data sheet.

The VOC in this column is the same as "G" *

List the On Pont solvent number.

The VOC of Ihe thinner/reducer as stated on the VOC data sheet.

The VOC in this column is the same as "J".*

This column lists (lie amount of material actually sprayed.'

\li\ini; raiio of all components.  This information is listed on the  VOC ilaia sheet,
N.  There are two ealegories:

    "1" greater than or equal to 8500 Ibs. G.V.W. (> or = 8500 Ibs.)

    "II" less than 8500 tbs. G.V.W. (< 8500 Ibs.)

().  VOC' "as applied" means the ready to spray VOC of Ihe material applied in relation to
    the mixing ratio and VOC of the individual components. Also called "ready lo spray"
    or"RTS"

P   This column is the same as "0",*

Q.  This column represents the total pounds of VOC emitted, based on the "ready to
    spray", pounds per gallons of the coating and quantity actually sprayed.
    For example: the  ready to spray VOC of 7500S is 5.1.  Three quarts were actually
    sprayed, see example 4 on  page 2.
*  The column is different only when recording the following list of products which
   contain waier or exempt solvent:
   2! OS      225S        227S         616S         3929S        57 ITS
   224S      226S        244S         620S         5662S
-------
VOC DATA SHEET
    RULE 1151
SURFACE CLEANER
MAX. VOC loss
MANUFACTURER TYPE 4 CODE ^ ! ™p|
Ibs/gal) j Solvent
PREP-SOL' II
3929S 1.2 i 4.9
I
!
1
PRETREATMENT COATINGS
t '•
—-3
us
sr>
5717S 1.4 ' 3.7
224S . 0,0 i 0.0
225S .;..1.3.. 3.9.. .
226S i 0.0 " i 0.0
227S : 0.0 ! 0.6
244S ; 5.7 | 6.5
i
PRECOAT COATING
VARIPRIME'
615S j 5.2 , 5.2. ._
615S : 5.2 ! 5.2
; i
I
I
PRIMER
WATERBORNE
210S 0.6 ' 1.9
Cnliilyst/IInrdencr/Addilivc
M;inul';u.'iuivr
K
Code
VOC'
(i:/l or
Ins/gull
VOC less
Winer &
less exempt
Solvent
— | — i .—



. 	 ; 	 i
1 i
	
—
	 _
I
1
i
j
1
- - - - -i — ' -
61 6S
620S

6.5
6.2

— :
,

6,6
6.3

—
Tli in nor/Red ticcr Solvent
Mumil'iieliirer
K 1
Code
-

WATER
WATER
• ~

—

—
voc
tg/l or
Ihs/gnh
VOC loss
wmer &
less exempt
Solvent
— i
•

. ^ .
—








- •

Tdliil iimoiilil i)l Mix Riltio Clross VOC' VOC ";is l.hv
conlhi.us used i C'oiiUMi!/ Vehieuliir ";i* .ipphed" ApphoU" le^1- "!' VOC.'
(i|Uiirl.s or gut) ! Solvent Wei.ehi unier & loss
1 • excmpi solvent
RTS 1.2 4.9
j
1:1 3.7 37
RTS 0.0 0.0
1:2 3.9 3.9
RTS 0.0 0.0
. RTS 0.0 0.0
RTS 6.5 6 5
;
	 	 1:1 . .. 5.8 . 5.9
1M 57 57
1
RTS 06 19
-------
VOC DATA SHEET
    RULE 1151
"»
SURFACE CLEANER
i MAX.
! \jf \p
MANUFACTURER TYPE i CODE i (^f
Ibs/gitl)
PREP-SOL' II
3929S i 1.2
i
I
VOC less
Winer &
less exempt
Solvent
4.9

PRETREATMENT COATINGS
f*
r)
<*£>
.>. V()(' VOf'";is !>>..
ciKiliMji-i used i Gulling/ Vchii'iibr "n- .ipplietl" Applied" le^x pi' VOC
(((linns or gill) I Solvent Weijiht uuier A Ic^v
i . exempt solvent
RTS 1.2 4.9

1:1 3.7 37
RTS 0.0 00
1:2 3.9 3.9
, ,.-RTS °-° ° °
	 :'"RTS. ... 0.0 ^ 0,0
	 : RTS 6.5 "' 6.5
;
. 1:1 5.8 5.9
1 : ' "i 7 IS 7
I
RTS 0.6 1.9
-------
         ATTACHMENT B




Article from BodvShop Business
-------
                                PaintShop
         Common   Complaints,
                Specific  Solutions
                                 by Mark Clark
        n these days of fast-paced
        produce/deliver auto repaint-
        ing, it's haro^tp get a simple
 explanation for tne~cause of common
 painters' problems. In this series of ar-
 ticles, we are going look at some of the
 most common complaints and try to
 explain in simple terms (no degree in
 chemisty required) what went wrong
 and why. These discussions are as ge-
 neric as possible, and no one brand of
 paint is being promoted over another.
  And that leads us to the absolute
 quickest way to reduce all your paint
 problems, no matter what brand you're
 using or what part of the country you're in.
  You can reduce your painting related problems by —
 ready? — 50 percent. Sound like something you'd be
 interested in? Instead of  10 problems a week or 10
 problems a month, you can skip right down to only 5
 problems.
  How? It's easy, it's simple, and it's guaranteed to
 work. Use one brand all the way through, follow a sys-
 tem! When all the undercoats, solvents, topcoats and
 clears are guaranteed compatible, you'll have 50 per-
 cent fewer problems. Problems like adhesion, durabili-
 ty and re-coatability drop to the very minimum.
  The notion that any shop painter can don the chem-
 ical  engineer's hat and start mixing products and
 systems goes back to the days when this business was
 much simpler.
  Back in the days when most undercoats were a lac-
 quer base and most topcoats were either lacquer or a
 simple acrylic enamel, shop painters figured out that
 they could substitute a cheaper solvent from some oth-
 er manufacturer and then color with yet a third brand
 and seldom have problems.
             Like the paint reps say, one of the
            hardest guys to deal with is the paint-
            er who combined-several brands^nd
            didn't have a problem, once or twice or
            even ten times. Then, when his "sys-
            tem" doesn't work, he can't accept the
            fact that he was just lucky each of
            those other times.
             The reason that intermixing is such
            a tremendous risk these days can be
            traced back to the vehicle manufactur-
            er. The consumer keeps demanding a
            better looking, more durable, more
            corrosion-resistant finish. The manu-
            facturers have been able to deliver
OEM finishes hundreds of times better than just a feu-
years ago. Now here comes that super high-tech finish
into the body shop to be repaired "as good as new."
  The aftermarket paint companies have really had to
scramble to create air dry (no heat or electricity like
OEM) finishes durable enough to match original
equipment. This, as you might imagine, was quite a
trick.
  What this means to body shop painters is that there
is no margin for error in applying or mixing today's
products. The  paint company chemist was able to
create a product to suit, but only if you do exactly as
he says. Not only must the painter combine the correct
solvent, catalyst and topcoat in the correct percent-
ages, but it must be applied over the correctly mixed
and applied undercoats at the correct time.
  There is only one right way to use today's finishes:
exactly according to directions and using only one
brand. Besides reducing your paint problems 50 per-
cent, several other benefits also occur. You will have
fewer products  (read that — dollars) in your inventory,
                        (continued on pg. 82)
80 / June 1990 / BodyShop Business
-------
 /continued from pg. SOt
 and since the same system is used all the Lime, every-
 one gets good at it and more work is produced in less
 time. Knowing what one line will do under a variety
 of conditions is better than guessing what a vari-
 ety of products will do under the same  condition.
   Now. having solved one half of your paint problems,
 let's take a look at some of the other ones that are left.
        It's simple to  solve
  half your  paint problems.

   One of the most common and frustrating paint prob-
 lems is die-back. Die-back means that over time the
 paint job loses the gloss it once had. Only one thing
 causes die-back: trapped solvent. It is always at the
 root of an}' die-back. Well that was simple, right?
   The mystery comes up when you try to decide where
 the solvent was trapped. It could be in the primer, the
 primer-surfacer. the sealer, the color coats or the clear-
 coats. Choose one or two or more! All your paint pro-
 ducts have solvent in them, some you add more sol-
 vent to. If you rushed the flash off time on any of the
 products, (who. you?) there is still solvent that wants
 to escape into the air. When it does, it has the same
 effect on the finish as wiping the  car with a solvent-
 soaked rag.
   Maybe the most common die-back occurs when a
 complete paint job is shot late in the day because the
 dust in the shop is at a minimum.
   The painter is the last guy in the shop and after the
 third coat, cleans his equipment, shuts off the fan and
 the light and heads home. When he returns the next
 morning, his great looking, super glossy paint job has
 died back and dulled down.
   What happened was that the bulk of the solvent rose
 up out of the paint film into the air where it should
 have been swept away by the air movement created
 by the fan. With no  fan  running, (to keep the job
 cleaner he thought) the solvent rose to the top of the
 paint  film and just lay there — thus, die-back.
  The solution is to run the fan  for a good 45 - 60
 minutes after the last coat.  At the end of the hour, shut
 off the fan and open the booth doors. You're out of
dust by then, and the air  moving in the open doors
 will help the last of the solvent to evaporate off.
  Air movement plays a big role in die-back. Take this
example: You're painting a  car  in a  two-stall ga-
          rape with little or no air movement. The tempera-
          ture is 70 F  All you  need  is the correct solvent
          for 70 F and the correct .flash time  between coat^
            Now, the same car.  the same 70 F, but you're
          in a crossdraft spray booth with average air move-
          ment.  You need to choose a solvent as if it were
          10° warmer (80 F) because of the air's drying effect.
           Third time, same car. same 70 F, but in a downdraft
        .  booth  with lots of air movement. You now need a
          much  slower drying solvent; in fact, almost 20°
          warmer. You must reduce as if it were 90 F in the
          booth. All that air whistling past causes the surface
          of the paint film to skin over before all the solvent can
          evaporate out. That trapped solvent will eventually
          work its way out, causing extra work for you, and
         -distress for your customer.  Beat this problem by
          choosing the correct solvent for each of your under-
          coats and  topcoats. Equally important, wait the
          recommended flash time (or more) between  coats.
           Another common problem, solvent popping, is caus-
          ed by exactly the same trapped solvent that causes
          die-back. Only in this case, there is so much solvent
          trapped under the prematurely dried "skin" that it
          will Literally burst out of the paint film, leaving little
          craters with a hole on top.
           Solvent poppingis violent die-back. The solution is
          to immediately move to a slower drying solvent.
           When you must re-do something because of die-back
          or solvent popping, sand the finish as soon as you can
          and let it sit around the shop, sanded, for as long as
         possible. When you sand, you open up the paint film.
         giving  the solvent a hole to escape through.
           Another  common problem  is clearcoat  de-lam-
         inating (peeling)  off the color coat. There are two
         likely causes.  How soon the customer comes back
         gives you a good clue as to which one you've got.
           If the customer is back within 8-10 weeks, it is most
         likely a compatibib'ty problem. In other  words, the
         clearcoat never had  an intercoat bond with the
         basecoat and was just "sitting" on the base color.
           There are two kinds of adhesion: mechanical and
         chemical. Mechanical means that you have abraded
         (sanded) the surface to increase the area of contact
         with the next product (i.e., up one side of the sand-
         scratch and down the other means more surface area
         to meet the new coat). Chemical adhesion depends on
         putting a chemically compatible product over anoth-
         er in the correct time frame. You may have the cor-
         rect product, but let your base color dry too long and
         the clear can get  no bite into it.
           If it has been longer than 8 to 10 weeks before the
         customer is back with peeling, chances are the clear-
         coat wasn't applied thick enough.
           The main enemy of your paint  finish is the ultra
         violet rays of the sun. It's hard to put very many UV
                                   (continued  on /Jt
82 / June 1990 /  BodyShop Business
11.00
-------
(continued from p%. 82)
screeners in n clcarcont because then it. isn t clear any-
more. Some of j'our ciearcont's durability depends on
having o thick enough film to withstand the UV.
  What happens many times is that the clearcoat was
applied at an acceptable mil build but was later wet
sanded and buffed to get rid of dirt.
  If, for example, you had two mils of clear in two
coats, you'll take one mil off when you sand and-polish.
The one mil you have left will not stand up very long
to the sun. Now the U V rays come streaming through
the clearcoat and oxidize the base color. The sun's rays
destroy the binder in the color coat, leaving only the
chalky pigment to which the clear won't stick, and off
it comes! The solution is to put on more clear.
  If you know you're going to buff, add an extra coat
for the buffer to remove. This will leave enough clear
film behind to hold out against the sun. Don't worry
abou t getting your film so thick that it will crack, to-
                ri ay s urcthane enamel clears remain flexible up to a
                build of 20 mils or more. There is not, however, much
                to be gained in gloss by going past three to four coats.
                 Next time we'll look into the most common lifting
                problem, discuss a clever solution for blushing and
                examine some clues to where your fisheyes might be
                coming from.  •
                   BodyShop Business is'starting a question and~
                 answer forum for your painting questions. If you
                 have something that you 've always wanted to know
                 and can't seem to find an answer for, send us the
                 question. We can not answer questions about
                 specific brand-name products — address those to
                 your paint rep or jobber. Ask us the "how come"
                 kind of questions. Using a panel of experts, we 'II
                 answer in print the best questions. Thanks for your
                 interest!
                   Classified   Paae
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        WE HAVE BUYERS!
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      EQUIPMENT REGISTER
      30 N. Raymond Ave.. Suite 605,
         Pasadena, CA 91103
          818-796-8804
Circle 95 on Reader Service Card
 DISTRIBUTORS WANTED
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      Call (515) 262-4899
                                Circle 96 on Reader Service Card
    Classified Ad Space

 BodyShop Business classified
 advertising is available for $195
 per insertions. Six or more ads
 per year are $175 per insertion.

 Classifieds measure 2-1/8 x
 1-1/2.

 Ads can be purchased in double
 units (2-1/8 x 3") for S390 per
 insertion.

 Advertising deadline is the first
 of every month.

 Contact BodyShop Business Ad-
 vertising Department at
 216-535-6117.
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capital.
PRODUCTION CAR CARE PRODUCTS
 USA (800)331-7364   CA (209) S43-7337
    NEW IDEAS?

 Pull-It Corporation, manufacturers of
 the internationally known Mo-Clamp
 line of autobody clamps and access-
 ories, would like to help you bring your
 ideas to the marketplace. Several ol the
 products we currently offer were devel-
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 such as yourself. With our expertise in
 design, manufacture, and distribution,
 we can help turn your ideas into money.
 We welcome the opportunity to work
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 Manager at (503)  644-9167, or (800)'
 678-5548
                                                                  6920 S.W llllh Avenue • Beaverton. Oregon 97005
                                        1.101.
                          BodyShopBusiness / June 1990 / 105
-------
                                                      5SD DRAFT 11/7/90
                      DRAFT PROPOSED DETERMINATION OF
                  REASONABLY AVAILABLE CONTROL TECHNOLOGY
                                    AMD
                 BEST AVAILABLE RETROFIT CONTROL TECHNOLOGY
                                    FOR
                   i.  AUTOMOTIVE REFINISHIN6 OPERATIONS
I.    APPLICABILITY

     The provisions of the proposed determination shall  apply to all
     automobile refinishing operations that Include the  finishing or
     refinishing of motor vehicles, mobile equipment and their parts and
     components except as specified in Section IV A   This determination
     shall be considered RACT except where indicated as  BARCT.

II.  DEFINITIONS

     A.  Antiglare/Safety Coat 1 no means a  coating which  does not reflect
         light.

     B-  Basecoat/Clearcoat System means a topcoat system composed of a
         pigmented basecoat portion and a  transparent  clearcoat portion.
         Basecoat/clearcoat systems'  VOC content  shall be calculated
         according to the following formula:
         VOCT..   .      bc  *  2  VI>Ccc
              bc/cc   - - --
                              V

         Where:

         VOC Tbc/cc  1s the  sum of tne WC content as applied in the basecoat
                      (be)  and clearcoat (cc) system.

         VOCbc   is the V(:)C  content as applied of any given basecoat.
         2VOCcc  is two times the YOC content as applied of any given
                clearcoat.

    c-  Camouflage Coating means a coating applied on motor vehicles to
        conceal  such vehicles from detection,

    D.  Catalyst means a substance whose presence initiates the reaction
        between  chemical compounds.

    E.  Color Match means the ability of a repair coating to blend into an
        existing coating so that color difference is not visible.

    f.  Electrostatic Application means the application of charged atomized
        paint droplets which are deposited by electrostatic attraction.
                                   -.1-
-------
                                                          i i LI 11
6.  Executive Officer means th« Emotive  Officer or A1r Pollution
    Control Qfflctr. or his or her  dajftgate-  of  an air Quality
    manaement district O  an air   olltion  control district ,
H. "Extreme Performance Goat-Ing  means  any  coating used on the surface
    of a Group II vehicle,  mobile  equipment  or  their parts or
    components which during intended use  Is  exposed to any of the
    following conditions:

    (1)  Industrial grade detergents,  cleaners  or abrasive scouring
    (2)  Extreme environmental  conditions .as  determined by the APCO
         during the vehicle's  principal  use.

I.  final jtage Manufacture means  where  an  incomplete vehicle chassis
    is delivered to a manufacturer for  installation and paint of a
    truck body and/or components  to form a  completed vehicle.

J.  Grams of VQC Per Liter of  Coating  less  water  and Less Exempt
    Compounds means the weight  of  VOC  per combined volume of VOC and
    coating solids is calculated  by thVfollowing equation:


       Gvoc     •  («s  -   Ww -   W«s   >' 

    where:

    G     = Grams VOC per liter of coating  less water and exempt
            compounds

      W£  = weight of volatile  compounds in grdms
      ww  = weight of water in -grams
      wes - weight of exempt compounds in grams
      Vm  = volume of material  in  liters
      Vy  = volume of water  in  liters

      VfS-=  volume  of exempt compounds  (as  defined  in VOC definition,
            Section II GG)  in liters

-  Graphic  Design Application  meant the application of  logos,  letters,
   numbers  and graphics to a painted surface, with or without  the  use
   of a  template.

-   Ground Support, means vehicles  used  in support  of aircraft
   activities at airports.
                              -2-
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                                                 ;>;>u UKAM  11/7/90
 M.   Groug  I_Vflh.1des nuani pauenger cars, Urgt/heavy duty truck cabs
     and chassis,  light  and medium duty trucks and vans, and
     motorcycles.

 N.   Group  II Vehicles and Equipment; means public transit buses and
     mobile equipment.

 0.   Hioh-Volnmft.  low-Prcssurt fHVLPl Sorav means equipment used to
     apply  coatings by means of a gun which operates between 0.1 and 10
     psig air pressure and which operates at a maximum fluid delivery
     pressure of 50 psig.

 P-   large/Heavy Duty Trucks means any truck having a manufacturer's
     gross vehicle weight rating of over 10,000 pounds.

 Q.   LJoht and Medium Duty Trucks and Va/is means  any truck or van having
     a manufacturer's gross vehicle weight rating of 10,000 pounds or
     less.

 R.   Metallic/Iridescent Topcoat means any coating which contains more
     than 5 g/1 (.042 Ib/gal) of metal or iridescent particles, as
     applied, .where such particles are visible in the dried film.

 S.   Mobile Equipment means any equipment which may be drawn or is
     capable of being driven on a roadway, including, but  not limited
     to, truck bodies, truck trailers, utility bodies, camper shells,
    mobile cranes, bulldozers, street cleaners,  golf carts and
     implements of husbandry.

 T.  Precoat means any coating which is  applied to bare metal primarily
     to deactivate the metal surface for corrosion resistance to a
    subsequent water-base primer.

U.  Pretreatment Wash Primer means any coating which contains  a minimum
    of 0.5 percent acid by weight, is necessary  to provide surface
    etching and is applied directly to  bare metal surfaces to  provide
    corrosion resistance and adhesion.

V.  Primer means any coating applied prior to the application  of a
    topcoat for the purpose of corrosion resistance and adhesion of the
    topcoat.

W.  Primer Sealer means any coating applied prior to the application of
     a topcoat for the purpose of corrosion resistance, adhesion of  the
     topcoat, color uniformity, and to promote the ability of an
     undercoat to resist penetration by the topcoat.

 X.   Primer Surfacer means any coating applied prior to the  application
     of a topcoat for the purpose of corrosion resistance,  adhesion  ot
     the topcoat, and which promotes a uniform surface by  filling  in
     surface  imperfections.


                                -3-
                                 1104
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                                                      UKAH 11/7/90
 Y.   RtiULti moans tht solvent  usid  to  thin  en Aim 1.

 2.   Refim'shfng means any coating of vehicles, their parts and
     componentSj or mobile tqulpment, Including partial body collision
     repairs,  for the  purpose of protection or beautlHcation and which
  ..  is. subsequent to  UL^ original coating applied at an Original
     Tqulpment  Manufacturing (OEM) plant coating assembly line.

AA-  Specialty  Coatlngl means coatings which are necessary due to
     unusual job performance requirements.  Said coatings Include, but
     are  not limited to, adhesion promoters, uniform finish blenders,
     elastomerk materials, gloss flatteners, bright metal trim repair,
     and  anti-glare/safety coatings.

BB.  Spot/Panel  Repair means the non-assembly line process of  repairing
     and  restoring  a portion of a motor  vehicle  to predamaged  condition.

CC.  Three-Stage  Coating System means a  topcoat  system composed of a
     pigmented  basecoat portion, a semi-transparent midcoat portion, and
     a transparent  clearcoat portion.  Three-stage coating systems'  VOC
     content shall  be  calculated according to the  following formula:

                      VOCbc * YOCmc  + 2 VOCcc
     YOCT3-stage   '   - - - : - : -
    Where:

    VOC T,  f      is the sum of the VOC content  as  applied In the
         J-stage   basecoat, midcoat and clearcoat system.
    VOtL,    is the VOC content as applied of any  given  midcoat.
       me
    Z VOC     is two times the VOC content as applied of any given
          c   clearcoat.

DO. Topcoat means any coating applied over a primer  of  an original OEM
    finish for the purpose of protection or appearance.  For the
    purposes of this rule, base coat/clear coat systems and three-stage
    coating systems shall be considered jointly as a topcoat.

EE. Touch-uo Coatino means a coating applied by brush or hand  held,
    non-refi liable aerosol cans to repair minor surface damage and
    imperfections.

FF. Transfer Efficiency means the ratio of the 'amount of coating solids
    adhering to the object being coated to the total amount of coating
    solids used in the application process, expressed as a percentage.

GG. Volatile Organic Compounds mean any compound  containing at least
    one atom of carbon, except methane, carbon monoxide, carbon
    dioxide, carbonic acid, metallic carbides or  carbonates, ammonium


                               -4-
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                                                      ssi) UKAH  n///yu
          carbonate,  1. 1.1-trichloroethane, methylcne chloride,
                                 ( CFr~i n . (HchlorodlfluoroiTtcthana
          chlorodifluoromEthang  (CFC-221. trlf luoromethane (CFC-23),
          trichloroUifluoroethane(CFC-113),d1chlorotetrafluoroethane  (CFC-
          114),  chloropenUfluororethane  (CFC-115), dichlorotrlf luoroethanft
                                                   dlchlorof luorosthane
          (HCFC-141b).and  chlorodlf luorortthanc  (HCFC-H2M.
 III.  STANDARDS

      A.   Limits.   Effective  six months from the date of adoption except
          where dates  are  specified, any person.who appllts coatings to Group
          I  or  II  vehicles, mobile equipment, their parts and components,
          shall comply with Sections III A (1) or A (2) below:

          (1)   Group I Vehicles.  A person shall not refinlsh Group I
               vehicles, their parts and components, or Group II vehicles and
               mobile  equipment where color match is required, using any
               coating with a VOC content in excess of the following limits,
               expressed as grams of VOC per liter (or pounds per gallon) of
               coating applied, excluding water and exempt compounds (as
               defined in  VOC definition. Section II SS), unless emissions to
               the  atmosphere are controlled to an equivalent level by air
               pollution abatement equipment with an abatement device
               efficiency  of  at least 85 percent and which has been approved
               in writing  by  the Executive Officer.
                           RACT
                            VQC
                                             Januar  1.  1992
                                       •BAftCT-
                                                January 1. 1995
                                                     V_QC
Pretreatment Wash   780 g/1 (6.5 Ibs/gal)  780 g/1  (6.5  IbS/gal)  420 g/1 (3,5 Ibs/gal
     Primer
Precoat
Primer/primer
     Surface
Primer Sealer
Topcoat
Metallic/Iridescent
     Topcoat
780 g/1
720 g/1

720 g/1
720 g/1
720 g/1
(6.5 IbS/gal)
(6.0 Ibs/gal)

(6.0 Ibs/gal)
(6.0 IbS/gal)
(6.0 Ibs/gal)
780 g/1 (6.5 IbS/gal)
340 g/1 (2.8 Ibs/gal)

420 g/1 (3.5 Ibs/gal)
600 g/1 (5.0 Ibs/gal)
600 g/1 (5.0 Ibs/gal)
420 g/1 (3.5 Ibs/gal
250 g/1 (2.1 Ibs/gal

340 g/1 (2.8 Ibs/gal
460 g/1 (3.8 Ibs/gal
540 g/1 (4.5 Ibs/gal
         (2)  Group II Vehicles and Mobile Equipment.   A person shall not
              finish or refinish Group II vehicles and equipment or their
              parts and components where color match is not required, using
              any coating with a VOC content 1n excess of the following
              limits, expressed as grams of VOC per liter (or pounds per
              gallon) of coating applied, excluding water and exempt
              compounds (as defined in VOC definition, Section II GG).
                                    -S-
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              unless emljslonj to the at~osph«re are controlled to an
              equivalent level by «1r pollution abatement  equipment with tn
              abatement device efficiency of at least 85 percent and vhlch
              has byen approved 1n writing by the Executive Officer.
                           RACT
                            VOC
                                       -BARCT-
                                             Januar
                                    199?
                                        January 1. 1995
                              VQC
Pretreatment Wash
     Primer
Precoat
Primer
Topcoat
Metallic/Iridescent
     Topcoat
Extreme performance
Camouflage
780 g/1 ($.5 Ibs/gal)  780 g/1 (6.5 Ibs/gal)  420 g/1 (3.5 Ibs/gal
780 g/1
340 g/1
420 g/1
650 g/1

750 g/1
420 g/1
(6.5 Ibs/gal)
(2.8 Ibs/gal)
(3.5 Ibs/gal)
(5.4 Ibs/ga1)

(6.2 Ibs/gal)
(3.6 Ibs/gal)
780 g/1 (6.5 Ibs/gal)
340 g/1 (2.8 Ibs/gal)
420 g/1 (3.5 Ibs/gal)
420 g/1 (3.5 Ibs/gal)

750 g/1 (6.2 Ibs/gal)
420 g/1 (3.5.Ibs/gal)
420 g/1
250 g/1
340 g/1
420 g/1
3.5 Ibs/gal
2.1 Ibs/gal
2.8 Ibs/gal
3.5 Ibs/gal
420 g/1 (3.5 Ibs/gal
420 g/1 (3.5 Ibs/gal
     B.   Lacouer  Spot/Panel  Repair  Limits.   Effective six months from  the
         date  of  adoption,  a person shall not  spot/panel repair Group  I
         vehicles with existing  nitrocellulose or synthetic  lacquer  finishes
         using lacquer coatings  in  excess of the following limits, expressed
         as  grams of  VOC  per liter  (or  pounds  per gallon) of coating
         applied, excluding  water and exempt compounds (as defined in  VOC
         definition,  Section II  GG), unless  emissions to the atmosphere  are
         controlled to an equivalent level by  air pollution abatement
         equipment with an abatement device  efficiency at least 85 percent
         and which has been  approved in writing by the Executive Officer:
          Pretreatment Wash Primer
          Precoat
          Primer/Primer Surfacer
          Primer Sealer
          Topcoat
                                  VOC

                         780  g/1  (6.5
                         780  g/1  (6.5
                             Ibs/gal)
                             Ibs/gal)
                         720  g/1  (6.0  Ibs/gal)
                         780  g/1  (6,5  Ibs/gal)
                         780  g/1  (6.5  Ibs/gal)
    Effective twelve months from the date of adoption, a person shall  not
    spot/panel repair Group I vehicles with existing lacquer finishes  using
    any coating with a VOC content  in excess of the standards set forth  in
    Section III A  (1).

    C.  Transfer Efficiency.  Effective twelve months from  the date  of
        adoption for all  coatings,  a person shall not apply any coating  to
        any Group  I or II vehicles  or mobile equipment or their parts  and
        components unless one of the following methods is used:
                                   -6-
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                                                 SSO DRAFT 11/7/90
    (1)  Electrostatic application equipment, operated 1n accordance
         with the manufacturer's recommendations;

    (2)  High Volume Low Pressure (HVLP) spray equipment, operated 1n
         accordance with the manufacturer's recommendations;

    (3)  Any other coating application which has been demonstrated to
         the satisfaction of the Executive Officer and for which
         written approval of the Executive Officer  has been obtained.

D.  Prohibition of Soedf ication.  Ho person shall solicit or require
    for use or specify the application of a coating on a Group I or II
    vehicle, mobile equipment, or part or component thereof if such use
    or application results in a violation of the provisions of this
    determination.  The prohibition of this Section will apply to all
    written or oral contracts under the terms of which any coating
    which is subject to the provisions of this determination is to be
    applied to any motor vehicle, mobile equipment, or part or
    component at any physical location within the District.

E.  Prohibition of Sale.  A person shall, not offer for sale or sell
    within the District any coating if such product is prohibited by
    any of the provisions of this determination.  The prohibition of
    this section shall apply to the sale of any coating which will be
    applied at any physical location within the jurisdiction of th.<^
    .local air Pollution control agencies. _ This requirement shall not
    apply to the application of coatings where emissions to thg
    .atmosphere are controlled to an equivalent level  of this
    determination bv air pollution abatement equipment that has
    approved in writing bv the Executivg
    Compliance Statement Requirement.   The manufacturer  of  coatings
    subject to this determination  shall  include. a designation of  VOC
    {as defined in Sections  II  G6)  as  supplied, including coating
    components, expressed In grams  per  liter or pounds per  gallon,
    excluding water and exempt  compounds, on data sheets.

    Surface Preparatlon-'and  Clean-up Solvept.  The requirements of this
    section shall  apply to any  person  using solvent for  surface
    preparation and cleanup.

    (1)  A person  shall not  use an  organic compound for  surface
         preparation with a  VOC content  in excess of  200 grams per
         liter (1.67 pounds  per gallon).
    (2)  A person  shall use  closed, nonabsorbent containers for the
         storage or disposal  of cloth  or paper used for  solvent surface
         preparation and cleanup.
    (3)  A person  shall store fresh or  spent solvent  in  closed
         containers.
    (4)  A person  shall not  use organic compounds for the cleanup of
         spray equipment including paint  lines unless an enclosed
         system is used for  cleanup.   The  system must enclose  spray

                               -7-
                                  1
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              guns, cups, nozzles, bowli and other parts during vathlng,
              rinsing and draining procedures.  Equipment used shall
              mlnlmiie the evaporation of organic compounds to the
              atmosphere.

     H.  SfflaJ 1 product 1on7Ut 11 Hy Bodies.  The standards set forth In
         Section |II A (1) Shall apply provided production of utility bodies
         where the coating Is required to match that of the vihiclts upon
         which they will be mounted It less than or tqual to 20 vehicles per
         day.  T(\estandards set forth jn Section III A (2) shall apply
         provided production of utility bodies Is greater than 20 vehicles
         par day.

     I.  Specialty Coating* means a person shall not use any specialty
         coating with a VOC content in excess of 840 g/1 (7.0 Ibs/gal),
         excluding vater and exempt compounds.   Use of all specialty
         coatings except antiglare/safety coatings shall not exceed 5.0
         percent of all coatings applied, on a daily basis.  The application
         of topcoats with a specialty coating used as an additive shall be
         subject to the topcoat limits 1n Sections III A (1) or A (2).

     J:'Extreme Performance Coating Requirements means any person seeking
         to use an extreme performance coating in any coatirvg operation
         which is subject to this rule shall comply with the requirements of
         Section VI A.
IV.  EXEMPTIONS

     A.  Original Eoujpment Manufacturer.  The provisions of this Rule shall
         not apply to Original Equipment Manufacturer (OEM) coatings applied
         at manufacturing or assembly plants subject to a Motor Vehicle
         Assembly Plan Rule.
V.   TEST METHODS

     A.  Analysis of Samples.  Samples of volatile organic compounds as
         specified in Sections III A (1) or III A (2) shall be analyzed as
         prescribed by EPA Reference Method 24 or method determined to be
         equivalent and approved by the Executive Officer.

     B.  Determination of Emissions.  Emissions of volatile organic
         compounds as specified in Section III A (1) or III A (2) shall be
         measured as prescribed by EPA Reference-Method 25 or method
         determined to be equivalent or more stringent and approved by the
         Executive Officer.

     C.  nomination of Transfer Efficiency-  Transfer «"jciency as
         required by Section III C (3) shall be determined by a method
         approved by the Executive Officer.


                                    -8-
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     D-   Determination of Capture Efficltncy.  Capture efficiency  »s
          r»guir>Qy_Sect ion  III A and R shall bn determined bv the method
          itattd  in suboart  SSS  (Magnetic Tape Coating Facilities!  40  Cfp r
          Part  60. Section 60.713.

     E.   Determination of Iridasceryt particles in Hetanic/Iridtsctnt
      ,  -Topcoat.  IMdtscent particles 1n metallic/Iridescent topcoat as
          defined  In Section II  R shall be determined bv the South  Coast A,1r
          Ouallty  Management District (SCAQMO) Spectrograohic method
          contained in Section 3. Method ?6 of the SCAQHD "Laboratory M»fh,ffd
          of Analysis for Enforcement Samples* manual.

     F.   Determination of Acid  Concentration 1n Prstreatment Wash  Primer.
          Acfd,  concentration in  pratreatment wash primer as defined 1n
          Section  II U shall be  determined bv test method ASTM D-1613-85
          /modified).
VI.  ADMINISTRATIVE REQUIREMENTS

     A.  Extreme Performance Coating Petition.   Any person seeking to use an
         extreme performance coating 1n any coating operation which is
         subject to the provisions of this rule shall  comply with the
         following requirements:

         (1)  A petition shall be submitted to  the  Executive Officer stating
              the performance requirements, volume  of  coating and VOC level
              which is attainable.
         (2)  If the Executive Officer  grants written  approval,  such
              petition will be repeated on an annual basis.
         (3)  If the Executive Officer  grants written  approval,  such
              approval shall contain volume and  YOC  limit  conditions.
         (4)  Records  must be maintained as in  Section VI  (B).

     B-   Coating Records.   Any person subject to Sections  III A  (1) and III
         A (2) shall  comply with the following  requirements:

         (1)  The person shall  maintain and have available during an
              inspection,  a current  list of coatings in use  which provides
              all of  the coating data necessary  to  evaluate  compliance,
              including the following information,  as  applicable:

              (a)  coating, catalyst and reducer used
              (b)  mix ratio of components used
              (c)  VOC content  of coating as applied.

         (2)  The person shall  maintain records  on  a daily basis Including
              the following information:

              (a)  coating and  mix ratio of components in  the coating used
              (b)  quantity of  each  coating applied.


                                    -9-
                                            n
                                           . * V
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(3)  The pfcMc.fi jotll maintain records on o monthly b«»U ihoving
     ths typ« «n3 imouht of jotWr.t us«d for cleanup ihd «urf»c«
(4)  Such record* shall be rttained and avallablt for Inspection by
     the ExecutlVt Officer for tht pr»v'1ous 24 month pirlbd.
                           -10-
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                                PaintShop
          Common  Complaints,
                Specific   Solutions
                                  by Mark Clark
        n these days of fast-paced
        produce'deliver auto repaint-
        ing, it's hardj-o get a simple
 explanatioh'for the cause of common
 painters' problems. In this series of ar-
 ticles, we are going look at some of the
 most common complaints and try to
 explain in simple terms (no degree in
 chemisty required) what went wrong
 and why. These discussions are as ge-
 neric as possible, and no one brand of
 paint is being promoted over another.
  And that leads us to the absolute
 quickest way to reduce all your paint
 problems, no matter what brand you're
 using or what part of the country you're in.
  You can reduce your painting related problems by —
 ready?  — 50 percent. Sound like something you'd be
 interested in? Instead of 10 problems a week or 10
 problems a month, you can skip right down to only 5
 problems.
  How? It's easy, it's simple, and it's guaranteed to
 work. Use one brand all the way through, follow a sys-
 tem! When all the undercoats, solvents, topcoats and
 clears are guaranteed compatible, you'll have 50 per-
 cent fewer problems. Problems like adhesion, durabili-
 ty and re-coatability drop to the very minimum.
  The notion that any shop painter can don the chem-
 ical engineer's  hat and start mixing products and
 systems goes back to the days when this business was
 much simpler.
  Back in the days when most undercoats were a lac-
 quer base and most topcoats were either lacquer or a
 simple acrylic enamel, shop painters figured out that
 they could substitute a cheaper solvent from some oth-
 er manufacturer and then color with yet a third brand
 and seldom have problems.
             Like the paint reps say, one of the
            hardest guys to deal with is the paint-
           .er who combined several brands and
            didn't have a problem, once or twice or
            even ten times. Then, when his ''sys-
            tem" doesn't work, he can't accept the
            fact that he was just lucky each of
            those other times.
             The reason that intermixing is such
            a tremendous risk these days can be
            traced back to the vehicle manufactur-
            er. The consumer keeps demanding a
            better looking, more durable, more
            corrosion-resistant finish. The manu-
            facturers have been able to deliver
OEM finishes hundreds of times better than just a few-
years ago. Now here comes that super high-tech finish
into the body shop to be repaired "as good as new."
  The af termarket paint companies have really had to
scramble to create air dry (no heat or electricity like
OEM) finishes durable enough to match original
equipment. This, as you might imagine, was quite a
trick.
  What this means to body shop painters is that there
is no margin for error in applying or mixing today's
products. The  paint company chemist was able to
create a product to suit, but only if you do exactly as
he says. Not only must the painter combine the correct
solvent, catalyst and topcoat in the correct percent-
ages, but it must be applied over the correctly mixed
and appb'ed undercoats at the correct time.
  There is only one right way to use today's finishes;
exactly according to directions and using only one
brand. Besides reducing your paint problems 50 per-
cent, several other benefits also occur.  You will have
fewer products (read that — dollars) in your inventory,
                        (continued on pg. 82)
80 / June 1990 /  BodyShop Business
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 (continue*: jnim pg. SOI
 and since ihe same system is used all the time, every-
 one gets {.rood at it and more work is produced in less
 time. Knowing what one line will do under a variety
 of conditions is better than guessing what a vari-
 ety of products will do under the same condition.
   Now. having solved one half of your paint problems.
 let's take a look at some of the other ones that are left.
        It's simple to solve
  half  your  paint  problems.

   One of the most common and frustrating paint prob-
 lems is die-back. Die-back means that over time the
 paint job loses the gloss it once had. Only one thing
 causes die-back: trapped solvent. It is always at the
 root of any die-back. Well that was simple, right?
   The mystery comes up when you try to decide where
 the solvent was trapped. It could be in the primer, the
 primer-surfacer. the sealer, the color coats or the clear-
 coats. Choose one or two or more! All your paint pro-
 ducts have solvent in them, some you  add more sol-
 vent to. If you rushed the flash off time on any of the
 products, (who. you?) there is still solvent that wants
 to escape into the air. When it does, it has the same
 effect on the finish as wiping the car with a solvent-
 soaked rag.
   Maybe the most  common die^back occurs when a
 complete paint job is shot late in the day because the
 dust in the shop is at a minimum.
   The painter is the last guy in the shop and after the
 third coat, cleans his equipment, shuts off the fan and
 the light and heads home. When he returns the next
 morning, his great looking, super glossy paint job has
 died back and dulled down.
   What happened was that the bulk of the solvent rose
 up out of the paint film into the air where it should
 have been swept  away by the air movement created
 by the fan. With no  fan running, -(to  keep the job
 cleaner he thought) the solvent rose to the top of the
 paint film and just lay there — thus, die-back.
  The solution is to run the fan for a good 45 - 60
 minutes after the last coat. At the end of the hour, shut
 off the fan and open the booth doors. You're out of
 dust by then, and the air moving in the open doors
 will help the last  of the  solvent to evaporate off.
  Air movement pla vs a big role in die-back. Take this
 example: You're  painting a car in a  two-stall ga-
 rage with little or no air movement. The tempera-
 ture is 70 F  All  you need is  the correct  solvent
 for  70 F  and the correct .flash time between coats.
   Now. the same car. the same 70  F, but you're
 in a crossdraft spray booth with average air move-
 ment. You need to choose a solvent as if  it were
 10° warmer (80 F) because of the air's drying effect.
   Third time, same car. same 70 F, but in a downdraf t
-booth with lots of air movement. You now need a
 much slower drying solvent; in fact, almost 20°
 warmer. You must reduce as if it were 90 F in the
 booth. All that air whistling past causes the  surface
 of the paint film to skin over before all the solvent can
 evaporate out. That trapped solvent will eventually
 work its way out, causing extra work for you, and
-distress for your customer. Beat this problem by
 choosing the correct solvent for each of your under-
 coats and topcoats.  Equally important,  wait the
 recommended flash time (or more) between coats.
   Another common problem, solvent popping, is caus-
 ed by exactly the same trapped  solvent that causes
 die-back. Only in this case, there is so much solvent
 trapped under the prematurely dried  "skin" that it
 will literally burst out of the paint film, leaving k'ttle
 craters with a hole on top.
   Solvent popping is violent die-back. The solution is
 to immediately move to a slower drying solvent.
   When you must re-do something because of die-back
or solvent popping, sand the finish as soon as you can
and let it sit around the shop, sanded, for as long as
possible. When you sand, you open up the paint  film,
giving the solvent a hole to escape through.
  Another common problem is clearcoat de-lam-
inating (peeling) off the color coat. There are two
likely causes. How soon the customer comes back
gives you a good clue as to which one you've got.
  If the customer is back within 8 -10 weeks, it is most
likely a compatibility problem. In other words, the
clearcoat  never had  an intercoat bond with the
basecoat and was just ''sitting"  on the base  color.
  There are two kinds of adhesion: mechanical and
chemical. Mechanical means that you have abraded
(sanded) the surface to increase the area of contact
with the next product (i.e., up one side of the sand-
scratch and down the other means more surface area
to meet the new coat). Chemical adhesion depends on
putting a chemically compatible product over anoth-
er in the correct time frame. You may have the cor-
rect product, but let your base color dry too long and
the clear can get no bite into it.
  If it has been longer than 8 to 10 weeks before the
customer is back with peeling, chances are the clear-
coat wasn't applied thick enough.
  The main enemy of your paint finish is the ultra
violet rays of the sun. It's hard to put very many UV
                          (continued on ptf. 10-r>)
82 / June 1990  / BodyShop Business
-------
 (continued from pg. 821
 scrocncrs in n clcarcoat because (.hen it. isn t clear any-
 more. Some of your clearcont's durability depends on
 having a thick enough film to withstand the UV.
   What happens many times is that the clearcoat was
 applied at an acceptable mil build but was later wet
 sanded and buffed to get rid of dirt.
   If, for example, you had two mils of clear in two
 coats, you'll take one mi] off when you sand and polish. -
 The one mil you have left will not stand up very long
 to the sun. Now the U V rays come streaming through
 the clearcoat and oxidize the base color. The sun's rays
 destroy the binder in the color coat, leaving only the
 chalky pigment to which the clear won't stick, and off
 it comes! The solution is to put on more clear.
   If you know you're going to buff, add an extra coat
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 about getting your film so thick that it will crack, to-
                day's urethane enamel clears remain flexible up to a
                build of 20 mils or more. There is not, however, much
                to be gained in gloss by going past three to four coais.
                  Next time we'll look into the most common lifting
                problem, discuss a clever solution for blushing and
                examine some clues to where your fisheyes might be
                coming from. •
                   BodyShop Business is starting a question'and
                 answer forum for your painting questions. If you
                 have something that you 've always wanted to know
                 and can't seem to find an answer for, send us the
                 question. We can not answer questions about
                 specific brand-name products — address those to
                 your paint rep or jobber. Ask us the "how come"
                 kind of questions.  Using a panel of experts, we'll
                 answer in print the best questions. Thanks for your
                 interest.1
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                                                            BodyShop Business / June 1990 / 105
-------
                      A.  EPA PRESENTATION

     Mr.  Randy McDonald of the Chemicals and Petroleum Branch in
the Emission Standards Division presented the status of the Batch
Processes Control Techniques Guidelines (CTG).  The presentation
was followed by two additional related presentations:  one from
Mr. Rick Hamilton, of On-Demand Environmental Systems, and one
from Ms.  Terri Ranganath,  of E.  I.  du Pont de Nemours & Co.,
Inc., representing the Chemical Manufacturers Association (CMA).
These presentations are summarized below.  Handouts and slides
are attached.  Also included is a summary of the discussion that
took place between the NAPCTAC committee members and the Batch
project team after the three presentations were completed.

1.  Status of Batch Processes CTG

     The objectives of the presentation were to present the
approach taken to develop reasonably available control technology
(RACT) options for controlling volatile organic compounds (VOC)
emissions from batch processes;  to present the options and the
impacts of applying the options to batch processing VOC emissions
on a nationwide basis; and to highlight implementation issues
that still need to be addressed.  The discussion started out with
a characterization of batch processes—namely, that they are
non steady-state processes.   As an example, the emission events
from a batch reactor—such as vessel charging, reactor heatup,
occasional purging of the reactor vapor space, and product
discharge—were described and the characteristics of the
resulting emission stream were said to be continuously changing.
Mr. McDonald pointed out that the scope of the CTG is limited to
five industries, and the CTG contains RACT options for
controlling process vents and equipment leaks.  Wastewater and
storage emissions are addressed in separate CTG's.  Equipment
leak requirements were adopted from the requirements set forth
for emissions from batch processes in the equipment leaks
negotiated regulation.  Mr.  McDonald explained that process vents
were, therefore, the focus for the majority of work done to
develop this CTG.  The focus of the presentation then turned
towards explaining the approach taken to develop the options.  It
is summarized below.

     Four model processes were developed from industry data.
They included typical batch unit operations and associated
equipment such as reactors,  crystallizers, centrifuges, dryers,
and distillation units.   In calculating emissions and estimating
the emission stream characteristics of flowrate, duration, and
-------
VOC concentration, the assumption was made that primary
condensers servicing this equipment were operated at 20"C.  Also,
all pieces of equipment were assumed to be vented.

     Next, Mr. McDonald discussed the time-dependent variation
that can occur in flowrate and VOC concentration, and
subsequently in the resulting emissions.  This concept was
presented using slides that plotted concentration, flowrate, and
emission rate on the y axis and duration of the batch cycle on
the x axis.  Control device selection must account for such
variation and control VOC emissions that are most reasonable to
control.  Two types of control devices were used to examine the
limits of reasonable control for VOC emissions from batch
processes.  They are thermal incineration and refrigeration.
These devices were used exclusively because they can handle a
universe of compounds.  Refrigeration was used for rich VOC
streams (>10,000 parts per million by volume [ppmv]), and thermal
incineration for streams with lower VOC concentrations.  Costing
of the devices was done in accordance with the OAQPS Control Cost
Manual.  An illustration of the dependency of control device cost
effectiveness with the amount of onstream emission duration was
shown by plotting cost effectiveness versus flow rate for a
number of 10,000 ppmv streams having varying onstream
percentages.  This discussion led to the heart of the approach
for developing RACT options, which is outlined below.

     A "mass flux" curve was shown and discussed in detail by
Mr. McDonald.  The mass flux curve is a plot of control device
cost effectiveness (dollars per Megagram [$/Mg]) versus maximum
instantaneous flowrate (standard cubic feet per minute [scfm])
for a set annual emission rate (termed "mass flux") for a range
of concentrations varying from 100 ppmv to 100,000 ppmv-  The
curves form an envelope that describes the range of cost
effectiveness values that are possible using the two control
devices specified above for any flowrate.  The left-hand
endpoints of the mass flux curve represent continuous emission
streams.  They are the lowest maximum instantaneous flowrates
that a vent stream can have for a set concentration to emit the
specified mass flux, which, for the first curve, was
20,000 Ib/yr.  As the curves move from left to right, the
duration of the emission streams becomes shorter and shorter so
that the right hand endpoints of the curve approximate very short
"bursts" containing high flowrates.

     A control device sized to handle emissions streams described
by the right-hand endpoints would be less cost effective (i.e.,
more expensive) than one sized to handle a stream described by
left-hand endpoints because the device would be large enough to
handle the burst but would not operate as long for the same mass
flux value (i.e., the Mg in $/Mg would remain the same, but the $
would be higher).  By drawing a horizontal line at a desired cost
effectiveness, intersecting the envelope formed by the mass flux
curves, and drawing a vertical tie-line down, the limit of


                             1116
-------
maximum instantaneous flowrate for a given cost effectiveness can
be set.  The RACT options were developed based on this analysis
and take the form of a regression line linking mass flux  (or
annual emission rate) and maximum instantaneous flowrate  at
certain cost effectiveness values.  A process vent would
therefore require control to a desired level (the current options
are 90, 95, and 98 percent reduction) if the maximum flowrate
were less than the value obtained from the equation of the
regression line for a specified annual emission rate.  This is
the approach that was taken to evaluate the limits of RACT for
process vents.

     For equipment leaks, Mr. McDonald reiterated that the RACT
option followed the requirements contained in the section
specific to batch processing contained in the equipment leaks
negotiated regulation.

     Mr. McDonald then presented the RACT options and their
associated nationwide impacts.  To estimate these impacts, model
plants were developed from the model processes presented earlier.
The number of facilities represented by these model plants
located in nonattainment areas having batch VOC emissions from
the industries in the scope of the CTG were estimated using data
from the Census of Manufacturers.  Selected RACT options were
shown  on a table with their estimated national emissions
reduction and costs.

     Finally, Mr. McDonald presented a slide of some of the
implementation issues that have arisen since the approach was
developed.  The first of these issues is how to obtain the annual
emission rate for a process vent or group of process vents.
Current thinking is that source testing is not technically and
economically feasible.  The Batch CTG document contains
methodologies for estimating VOC emissions from batch processing
steps.  These methodologies could be used to develop the annual
emissions estimate.  Maximum instantaneous flowrate is presumably
an easier parameter to obtain for various reasons.

     The second implementation issue discussed is how to verify
the annual emission rate.  Because of the format of the RACT
options, facilities will be required to anticipate the annual
emission rate from a process vent or group of process vents to
determine whether the vent must be controlled.  For industries
that have continuously changing production schemes, this task
could become very complicated.  The agency responsible for
enforcing RACT might require an end-of-the-year audit to ensure
that process vents or groups of process vents were controlled as
required.   Finally, testing or monitoring of control device
operating parameters might be required to ensure that the
required control efficiencies (i.e., 90, 95, and 98 percent) were
being achieved.
                              1117
-------
CONTROL TECHNIQUES GUIDELINES
         DOCUMENT
           (CTG)

            for

       VOC EMISSIONS
           from
      BATCH PROCESSES
      NAPCTAC Meeting

      November 21,1991
-------
Batch Processes are discontinuous processes
in which mass, temperature, concentration
and other properties of a system vary with time,
Batch Processes are typically characterized
as "non-steady state"
-------
     INDUSTRIES COVERED
       Polymers and resins
        Pharmaceuticals
     Paints and allied products
Synthetic organic chemicals (SOCMI)
      Agricultural chemicals
-------
         APPLICABILITY OF BATCH CTG
to
- Process vents
- Equipment leaks
- Storage tanks
- Wastewater
                          Covered by this CTG
                           Covered by other
                               CTGs
-------
   PROCESS VENTS
to
to
-------
ro
CO
                  MODEL PROCESSES
OBJECTIVE: To characterize the majority of batch processes
SOLUTION: 4 model processes
1. Solvent reaction with atmospheric dryer
2. Solvent reaction with vacuum dryer
3. Liquid reaction
4. Formulation
-------
                                       SOLVENT
             SOLVENT
             RECOVERY
Mode! batch process for solvent reaction w/ atmospheric dryer
                        1124
-------
                    CRYSTALLIZER
                      SLURRY
                      TANK
          CENTRIFUGE
          Lr
             DIST.
             UNIT
                                       SOLVENT
CENTRIFUGE
           SOLVENT
           RECOVERY
                               VACUUM
                                DRYER
Model batch process for solvent reaction w/ vacuum dryer
                       1125
-------
  WEIGH
  TANK
WEIGH
TANK
            MIX
           TANK
            1     f
         REACTOR
               •SOLVENT
           SURGE
           TANK
            DIST.
            UNIT
          SOLVENT
         RECOVERY
Model batch process for liquid reaction
              1126
-------
WEIGH
TANK
WEIGH
TANK
         MIX
         TANK
       REACTOR
        SURGE
         TANK
                                 SOLVENT
                   FILTER
       Model batch process for formulation
                   1127
-------
   CONCENTRATION, FLOWRATE, and DURATION
               determine
ro
oo
               EMISSIONS
-------
CONCENTRATION PROFILE OF A BATCH PROCESS
   90

   81

   72
O
tr 63
Ld
   54

   45
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27

18

 9

 0
  Ohr
          N

          Reactor
                                      Distillation
                                       r
                         Vacuum
                           dryer
                                             Solvent
                                            Recovery
                         2.2 hr

                   TIME (24  HOURS)
                                      22.2 hr
24 hr
-------
        FLOWRATE PROFILE OF A BATCH PROCESS
o
CO
   154 r
   132
E  110
   88
<   66

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    0
             Reactor
      Ohr
                          X
    Vacuum dryer
2.2hr
                                    N
                     TIME (24 HOURS)
                 Distillation
22.2hr
24 hr
-------
       EMISSION PROFILE OF A BATCH PROCESS
  16 r
 CO
< 8
cr
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00
in

^
LU
   0
             Reactor
         /
     Ohr
                                               Distillation
                                   Vacuum dryer
                           Solvent

                          recovery
2.2hr
                                              22.2hr    24 hr
                      TIME (24 hours)
-------
FLOWRATE PROFILE OF A BATCH PROCESS
154
132
^ 88
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22
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2.2 hr N| 22.2 hr 24 hr
TIME (24 HOURS)
 CONCENTRATION PROFILE OF A BATCH PROCESS
   90
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 9
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         Reactor
                                   Distillation
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                    2.2 hr     N|
               TIME (24 HOURS)
    EMISSION PROFILE OF A BATCH PROCESS
   16 r

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         Reactor
          n
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                                      OiitiUation
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                         2.2 hr       \
                   TIME (24 hours)
                                      22.2 hr    24hr
                       1132
-------
CO
CO
              CONTROL TECHNOLOGY
- Thermal incineration
    (< 10,000 ppmv)

- Condensation/refrigeration
   (>=10,000 ppmv)
     Other devices were examined (i.e. scrubbers and
      carbon adsorption),but these two are UNIVERSAL
-------
CO
        PACT OPTIONS STRUCTURED TO
          CONSIDER VARIATIONS IN:
- Concentration
- Flowrate
- Duration
-------
               Cost to Control by Thermal Incineration
                   For VOC Concentration of 1 0,000 ppmv
CO

  50000
  45000
  40000
  35000
  30000
  25000
P 20000
  15000
  10000
   5000
      0
     O
                 20% 1 0%
                                          7,
            10          100        1000       10000       100000
                 Maximum Instantaneous Flowrate (scfm)
-------
CO
cn
       FORMAT OF OPTIONS

- Linear equations which specify flowrate

 "cutoffs" when annual emission rate is input

- Emission streams must be controlled to a
 certain level (i.e. 98%, 95%, 90%) if the

 maximum flowrate of the emission stream

 is less than the specified cutoff
-------
    APPROACH FOR DEVELOPING RACT OPTIONS
    - Absorb duration into "mass flux" parameter, which
     is the yearly VOC emission rate

£   - Construct "mass flux" curves on axes of cost
S    effectiveness and flowrate for range of concentration
-------
CO
CO
     D)
    CO
    CO
    LLJ

    LU
O
LU
    LL
    LLJ
    8
                          MASS FLUX = 20000 Ibs/yr
                             LOW VOLATILITY Obluene)
                            CONDENSER CONTROL EFFICIENCY - 90%
                                             Short duration events
                   100% duration, 8760 hours
                  Condenser 100,000 ppmv
                                           100
                                   FLOWRATE(scfm)
                                                     1000
10000
-------
       35
C/)
0)
LU
       30-
       25-
LU  "p  20
>  §

P  R
O  .8  15J
       10-
        5-
LL
LLJ

So
8
        0
                          MASS FLUX = 35000 Ibs/yr
                            LOW VOLATILITY fToluene^
                           CONDENSER CONTROL EFFICIENCY - 90%
                         10              100             1000

                                 FLOWRATE(scfm)
                                                                         10000
     	THROX 10OOppmv    	THROX 8750ppmv
                                        	 CONDENSER 10000ppmv	CONDENSERIOOOOOppmv
-------
        35
  CO
  CO
  LJU
        30-
  25-
  UJ -p 20-
 •^  i
OUL
  LJL
  LU    10
   5-
  o
  o
         0-
                           MASS FLUX = 50000 Ibs/yr
                             LOW VOLATILITY fToluene)
                            CONDENSER CONTROL EFFICIENCY - 90%
                                                            (50,000,4000)
                          i  i  i  i i i 111
                    10              100            1000

                            FLOWRATE(scfm)
                                                                         10000
	THROX 10OOppmv    	THROX 8750ppmv
                                            CONDENSER lOOOOppmv 	CXDNDENSERIOOOOOppmv
-------
MASS FLUX = 75000 Ibs/yr
  LOW VOLATILITY (Toluene)
 CONDENSER CONTROL EFFICIENCY » 90%
               100             1000

       FLOWRATE(scfm)
                                                                   10000
	THROX 10OOppmv    	THROX 8750ppmv
                 CONDENSER 10000ppmv 	CONDENSER 100000ppmv
-------
to
                       DATA POINTS
   Mass Flux (Ib/yr)      Flowrate (scfm)    Cost-effectiveness ($/Mg)
20,000
35,000
50,000
75,000
500
2500
4000
7000
10,000
10,000
10,000
10,000
               Flowrate = 0.1167(Mass Flux) -1750
-------
 ,
CO
                     EQUIPMENT LEAKS
      - Adopted equipment leaks negotiated regulation as described
       in the Hazardous Organic NESHAP (HON)

      Portions specific to Batch Processing consider
M     - Exemption from control of sources in service
       less than 300 hr/yr

      • Control via pressure testing or leak detection and repair (LDAR)
-------
              NATIONWIDE IMPACTS

Extrapolated from model processes to model plants to nationwide
totals
Uses census of manufacturers data to estimate facilities located
in non-attainment areas for small, medium, and large groupings

Small plant                  1-19 employees,
                           3 model processes
Medium plant                20-99 employees,
                           10 model processes
Large plant                  >=1 oo employees,
                           30 model processes
-------
BATCH PROCESSES CTG RACT OPTIONS
  OPTION

     1
     DESCRIPTION
      OF OPTION

Controlling equipment leaks
NATIONWIDE
 EMISSION
REDUCTION
   (Mg/yr)

    6,900
NATIONAL
   COST
    ($)

$13,000,000
   AVERAGE
     COST
EFFECTIVENESS
     ($/Mg)

     $1,900
                    90% control of aggregated
                 process vents that are not exempt
               per cutoffs based on the $5K envelope

                     90% control of individual
                 process vents that are not exempt
               per cutoffs based on the $5K envelope

                     98% control of individual
                 process vents that are not exempt
               per cutoffs based on the $5K envelope
                                    53,400
                                    39,400
                                    41,000
 Options 2-4 include controlling equipment leaks to the level found in Option 1
 Options 2-4 do not include controlling the paints and allied products industry
                 $94,500,000
                 $95,000,000
                $363,000,000
                   $1,800
                   $2,400
                   $9,000
-------
CD
        IMPLEMENTATION ISSUES

- Estimating and/or testing to obtain annual VOC
 emission rate (Mass Flux, Ib/yr) and maximum
 instantaneous flowrate (scfm)

- Recordkeeping of process equipment usage,
 coupled with end-of-the-year audit

- Recordkeeping of control device operating
 parameters to ensure compliance with control
 requirements
-------
B.   INDUSTRY PRESENTATIONS
         1147
-------
          Batch Processes Control Techniques Guidelines

                       Richard E. Hamilton
                          Vice President
              On-Demand Environmental Systems, Inc.
                        505 Asbury Street
                        San Jose,  CA 95110

VOC REMOVAL

Thermal processors  offer significant benefits  for VOC abatement
control for a variety of industries. If a centrally located thermal
processing unit  is  used for VOC removal, then  all point sources
that emit VOCs may be ducted together and run to the processor. For
a broad range of applications it's understood that not all of the
facility's   emission  point   sources   will  be   emitting  VOCs
continuously  or  at  the  same  time.  For example,  Figure I shows an
emission cycle of VOCs  coming from a semiconductor manufacturing
process.  Even though the air  flow is  continuous,  VOCs  in the
exhaust stream occur only when  chemicals are being  used  in the
processing steps. For this application,  VOCs are in exhaust stream
an average of 18 percent of the time during the two shift per day
operation and range from 30 to 10 percent. Evaluated over a 24 hour
period, the  emissions average less than  10  percent  of the total
day.

If there are  continuous  VOC  emissions,  central  processors may be
attractive  from the stand  point  of  operating  cost. Figure  2
represents   a  centrally  installed  thermal  processor   for  a
semiconductor manufacturing operation which as we have studied does
not have continuous VOC  emissions.  Using several  smaller thermal
processors within  each  local  manufacturing area may be  a  more
practical approach because each can operate more efficiently under
specific conditions and may be inactive when not needed. Figure 3
shows  the  same point sources benefitting from  locally installed
thermal processors that  can respond to the emission cycle from the
processing equipment.

Effluent from individual pieces of processing equipment, or small
groups of equipment, may be directed to  small VOC  processors. If a
fuel-on-demand type processor is controlled by a VOC sensor and a
microcomputer, it will activate only when needed and consume fuel
only when the attached processing equipment is contributing VOCs to
the air stream.  This will also lower the cost of VOC destruction
since fuel consumption of thermal processors depends on the volume
of air that passes through them.

FUEL-ON-DEMAND THERMAL PROCESSING SYSTEMS

Microprocessor equipped, fuel-on-demand, thermal processing systems
may be activated to correspond to VOC  emission  requirements.  An
activation signal can be generated by an  electric signal indicating
that there are chemicals  in  the  exhaust or  by sensors located in
equipment  exhaust  ducts.  For  example  both  a  heated  surface

                                 1148
-------
semiconductor device  and a gas chromatograph  on a silicon wafer
have been  used  to detect total hydrocarbon levels or individual
solvents in the exhaust. Different combinations  of sensors can be
used to keep the thermal processors active until  VOC levels in the
air stream decay to an acceptable level.

A  fuel-on-demand thermal processor must achieve high destruction
efficiency immediately upon activation.  Some advantages of reduced
fuel consumption  are lost  if appreciable  stabilization time is
required. Small thermal processors can inject fuel  into the stream
containing VOCs. When the mixture reaches its lower flammability
limit, it can be ignited. Proper injection and uniform mixing with
the air  stream  prior to ignition will  prevent channeling of the
VOCs  through the  flame area.  This  is  important  because,  in
instances where such channels actually form,  VOCs may pass through
a  reactor without coming into contact with the  flame. Direct flame
contact is necessary since it enables high destruction efficiencies
with short residence time.  Figure 4 is  a cross  section  of the
reactor  used in  the On-Demand  Environmental  System's thermal
processor which is designed to ensure direct flame contact with the
VOCs in the air stream.

In addition to VOC destruction efficiency, NOx generation is also
an important  consideration.  Consequently,  a  responsive thermal
processor that operates only when  required will reduce the overall
amount of NOx produced,  compared  to systems that maintain a high
temperature on  a  continuous basis.  For  fuel-on-demand thermal
processors, it has been  demonstrated that reactor design affects
the levels of NOx produced during the operation. Levels below lOppm
of NOx  during operation have been  measured  from the  On-Demand
technology shown in Figure 4.

COMPUTER CONTROL

A  personal computer with interface hardware can cost-effectively
operate the thermal processor if the processors are equipped with
variable fuel  flow hardware.  Computer software can  incorporate
selected algorithms to optimize specific applications.  As the VOC
concentrations change, the  computer adjusts the flow of fuel to
maintain specific operating conditions.  In addition  to  the basic
features provided by  computer-controlled systems,  data  and alarm
conditions can be electronically  logged,  thereby providing files
useful for demonstrating regulatory compliance.

INSTALLATION COSTS

Using direct flame contact that provides  efficient energy transfer,
the thermal processors can be made  small and compact.  Therefore,
this technology  provides installation flexibility at the point of
generation of the VOC exhaust. Long and costly ducting runs to
central abatement devices can, therefore, be avoided. The units can
be installed in  a variety  of  configurations and  can be located
outdoors.
                                                       OD335 11/9/91


                                1149
-------
                                    Duty Cycle
                               Two Shift Day (16 Hr.)
                                                                 Figure  1
0.35-d
 0.3-
      On-Demand Environmental Systems

                                                             30.8%
                                             2ao%28.3%
      Avg.=18%
            1   2   3   4   5   12   13  14  15  16  17  18   19   20  21  22
                                     March 1991
-------
                Centrally  Installed Abatement
   Wafer Track
   Positive Photoresist
   Acetate,& HMDS Emission
   200 CFM, 40 ppm, 33% Duty Cycle
in
      Source 1
        Fab A
                  1000
       Equipment Cleaning
       Acetone/ IPA
       1200 CFM, 600 p|
         Sources
am, 85% Duty Cycle
                                 Resist Application
                                 Negative Photoresist
                                 Xylene
                                 500 CFM, 150 ppm, 20% Duty Cycle
                                    Source 2
                                     FabB
                                                           250
                                          Central
                                         Processor
                                          Location
                                      800
1900 CFM
Xylene
Acetone
IPA
Acetate
HMDS
100% Duty Cycle
                                                    Figure  2

                                                     On-Demand
                                                  Environmental Systems
-------
                 Point  Source  Emission  Control
in
to
     Wafer Track
     Positive Photoresist
     Acetate,& HMDS Emission
     200 CFM, 40 ppm, 33% Duty Cycle
                                 Resist Application
                                 Negative Photoresist
                                 Xylene
                                 500 CFM, 150 ppm, 20% Duty Cycle
Sourco 1
Fab A
t



M-


«



_

                25'
M-


-rSsr
Source 2
FabB
+
                               •35'
                   MONITOR
                                  r
                                  I
        Equipment Cleaning
        Acetone/ IPA
        1200 CFM, 600 PI
          Source 3
3m, 85% Duty Cycle
                                        I
                                                                        Figure  3
                                                                         On-Demand
                                                                      Environmental Systems
-------
         VOC  Thermal  Processor
                  Combustion Chamber Exhaust
 Exit Thermocouple
Combustion Zone
 Thermocouple
                                         Figure  4
                                II 11 c o      On-Demand
                      Air + VOC Input 1 J- rM Environmental Systems
-------
Mr. Rick Hamilton, On-Demand Environmental Systems

     This presentation provided an example of actual batch
emissions that currently are being controlled using thermal
incineration.  Several semiconductor facilities in California
have installed the small incinerators that On-Demand designs and
sells.  The on-stream duration of VOC emissions from these
facilities is representative of typical batch processing
industries.  Mr. Hamilton cited an example of VOC emissions7
being in the exhaust stream of a semiconductor process only
18 percent of the time during an 18-hour workday.

     Mr. Hamilton also showed two possible configurations for the
units:  (1) handling manifolded exhaust vents and (2) controlling
individual exhaust vents at the point of generation.  Units
ranging in capacity to handle flowrates of 1,900 (cfm) down to
units handling 65 cfm were shown, and Mr. Hamilton stressed the
compactness of the units, which presumably would ease
installation, especially for controlling process vent streams at
the point of generation.  Finally, there was some discussion of
auxiliary equipment that has been employed with the systems,
primarily in detecting VOC's or specific air toxics in the vent
streams, and of the method of feedback control to augment or
release fuel in the incinerator only during a VOC emission event.
                                1154
-------
CHEMICAL
MANUFACTURERS
ASSOCIATION
                                              STATEMENT OF


                                             TERRI  RANGANTH

                                              ON BEHALF OF


                                 THE CHEMICAL MANUFACTURES ASSOCIATION

                                               BEFORE THE


                                    NATIONAL AIR POLLUTION CONTROL

                                     TECHNIQUES ADVISORY COMMITTEE

                                                 ON THE

                            CONTROL TECHNIQUES GUIDELINES FOR BATCH PROCESS


                                            NOVEMBER 21, 1991
                                               1155
                            2501  M Street, NW      202-887-1100
                            Washington, D.C. 20037  Telex 89617 (CMA WSH)
-------
 TESTIMONY OF THE CHEMICAL MANUFACTURERS ASSOCIATION BEFORE THE
   NATIONAL AIR POLLUTION CONTROL TECHNICAL ADVISORY COMMITTEE
    ON THE CONTROL TECHNIQUES GUIDELINES FOR BATCH PROCESSES
                       NOVEMBER 21, 1991

     Good Afternoon. My name Is Terry Ranganath, Air Quality
Engineer with du Pont.  I am happy to be before you today to
present testimony of the Chemical Manufacturers Association
(CMA) on the draft Control Techniques Guidelines for Control of
Volatile Organic Compound Emissions from Batch Processes.  CMA
is a nonprofit trade association whose members comprise 90% of
the productive capacity for basic chemicals in the United
States.  My presentation this afternoon will feature several of
CMA's observations, concerns, and recommendations regarding
CTG's, particularly the Batch Processing document

     CMA fully appreciates the role of CTG's in setting
Reasonably Available Control Technology (RACT) for
nonattainment areas.  Although styled as guidance documents,
CTG's are in practice more than merely guidance.  Air quality
professionals in government, industry, and environmental groups
recognize that CTG's are regarded as the final word in many
regulatory programs.  It is important that CTG's reflect the
type of well informed and reasoned analysis that such
influential documents demand.

     Control Technique Guidelines hold special significance for
companies that emit substances listed as hazardous air
pollutants (HAPS) under section 112.  Many of the 189 chemicals
listed as HAPs are volatile organics.   Companies that emit
VOC's on the section 112 list face the prospect of complying
with both RACT standards and MACT standards.

     It is important that EPA recognize that RACT and MACT are
two different standards.  The Clean Air Act clearly
contemplates that the "reasonably available" technology of RACT
standards are less stringent than the "maximum degree of
reduction" required under MACT.  CMA is concerned that the CTG
for Batch Processes confuses the two technology requirements.

     CMA supports performance standards based on percent
reduction as presented in the batch processes CTG.  However, we
believe the stringent 98% reduction efficiencies discussed in
the document are not appropriate for setting RACT.  In fact,
the draft CTG reads at times like a MACT standard.  When the
Agency identifies the presumptive norm for RACT for Batch
Processes, the discussion should be limited to control options
more in line with RACT.

     Sources that are required to meet both RACT and MACT for a
particular emission must not be forced to comply with
inconsistent standards.  CMA believes that sources which comply
with the more stringent MACT standard should be deemed to be in
compliance with the less stringent RACT requirements.
                             1156
-------
     The suggested RACT for Batch Processes is not identified
from the list of options in the draft CTG.  When the
presumptive norm for RACT is identified, we recommend that the
Agency revise the acceptable control efficiencies to reflect
the realities of operating the presumptive control equipment.

     Performance of control equipment varies with the type of
chemicals involved and operating conditions.  Therefore,
instead of a single percent reduction efficiency; the CTG
should identify an acceptable performance range which would
reflect real life emission control operations.

     There are two more areas of concern I would like to
address this afternoon.  The first regards the model used for
synthetic resin manufacturing.  The suspension-type
polymerization operation illustrated in the draft CTG is not
representative of typical synthetic resin manufacturing. In
particular, the 100% vapor saturation assumed in the example
does not account for the many operations which undergo full
vessel cleansing with water.  CMA recommends that the CTG
consider more accurate examples of synthetic resin
manufacturing.

     Secondly, we disagree with the suggestion that SOCMI
factors be used to estimate emissions from equipment leaks.
This is inconsistent with Agency's refusal to allow SOCMI
factors to be used in establishing baselines in the credit for
early reduction program.  Disallowing SOCMI factors in the
credits program is a tacit admission that the SOCMI factors
grossly overestimate actual emissions.  We recommend that the
Batch Processing CTG adopt the more accurate POSSEE database,
which is the CMA designed data entry system for fugitive
emissions testing.

     To conclude my comments, I would like to reiterate CMA's
support for the performance based format suggested in the Batch
Processing CTG.  CMA also supports the bubbling approach
discussed in the CTG as a means of complying with overall
process control requirements.  We are interested in working
constructively with EPA in developing technically sound CTG's
and look forward to offering further input.  CMA thanks the
committee for the opportunity to offer our views on the CTG for
Batch Processes.  I'd be happy to answer any questions from the
committee.
                             1157
-------
Ms. Terri Ranganath, Chemical Manufacturers Association

     Ms.  Ranganath, E.  I.  du Pont de Nemours & Co., Inc.,
representing the CMA, made a presentation which is included in
the attached handouts.   CMA agrees with the performance-based
standard of the options but stated that the use of the average
SOCMI factors overstated emissions from leaking process
components.  Additionally, a concern was stated that the
assumption EPA used for vapor space saturation also would
overstate emissions.  The prepared speech also stated that CMA
agreed with the "bubbling approach as a means of compliance."
[Ed. Note:  No bubbling approach is discussed in the CTG; there
is a RACT option that requires that facilities aggregate annual
emissions and maximum flowrates from single unit processes to use
in determining whether control is required.]  Ms. Ranganath also
suggested that the CMA's POSSE data base be used in estimating
equipment leak emissions.
                              1158
-------
                          C.   DISCUSSION

     After all three presentations were made, the floor was
opened up for questions from NAPCTAC members.  This discussion is
summarized below.

     Ms.  Deborah Sheiman of the Natural Resources Defense Council
(NRDC) opened the discussion by asking Mr. McDonald what the
difference was between RACT Options 2 and 3 on the slide.
Mr. McDonald responded that RACT Option 2 represented the
"aggregated" option, while RACT Option 3 represented the
"individual" option for 90 percent control of sources.  Both
options are in accordance with the $5,000/Mg envelope used for
illustrative purposes.  The aggregated options, simply put,
require that the annual emission rates from all process vents
from single process lines be aggregated and then used in the RACT
equation to yield a flowrate cutoff to determine whether the
sources must be controlled.  Mr. McDonald pointed out that the
option does not require that facilities physically manifold their
process vents together, but only requires that the control
requirement be evaluated as if the vents were manifolded
together.  The impact of aggregation in an option is that more
streams will require control for the same cost compare with the
individual option, as the numbers indicated.  Ms. Sheiman also
questioned why the more stringent RACT options were not presented
on the slide.  Mr. McDonald responded that the slide was intended
to show the format and impacts of the options, but for simplicity
showed only four examples.  All RACT options are presented in the
draft CTG document.

     Mr.  Brian Taranto of Exxon Chemical Americas commented on
the assumption made for estimating baseline (i.e., current
control practices).  He also said that the assumption that
industries other than Pharmaceuticals are uncontrolled results in
overestimating the national emissions from batch processes.  He
asked Mr. McDonald what the effect of this overestimation would
be on the estimated nationwide impacts of the CTG.  Mr. McDonald
responded that if the baseline emissions were in fact
overestimated, the net emission reduction resulting from the CTG
would decrease, as would the national cost associated with
implementing it.  Mr. Tarranto suggested that baseline control be
more precisely evaluated.  Ms. Ranganath repeated her concern
that use  of average SOCMI factors also overstate emissions [for
equipment leaks].

     Mr.  John Pinkerton, Program Director of Air Quality for the
National  Council of the Paper Industry for Air and Stream
Improvement, Inc., asked whether batch processing emissions would
be covered under the Hazardous Organic NESHAP (HON).  Ms. Susan
Wyatt, Chief of CPB, stated that the HON specifically exempts VOC
emissions from batch process vents at SOCMI facilities subject to


                                1159
-------
                                8

the HON.  However, some industries utilizing batch processes,
such as the polymers and resins industry and the Pharmaceuticals
industry, are on the source category list for NESHAP development
efforts.  Two NESHAP's currently are underway for the polymers
and resins industry.  These standards are expected to be
completed within 4 years.  Mr. Pinkerton expressed concern that
the CTG might go into effect before a MACT standard for the same
source, conceivably forcing facilities to undertake costs of
controlling for a less stringent standard, only to have to
retrofit or redesign a control system entirely for a more
stringent standard a short time later.

     Concern was also expressed about the way in which control
device cost effectiveness was calculated.  Mr. McDonald restated
the methodology and stressed that the cost-effectiveness values
obtained for the RACT options are really average values.

     Ms. Vivian Mclntire of Eastman Chemicals Company had several
questions and comments on the CTG.  The first concerned whether
the methodology considered sizing of devices for peak flows that
seemed to be insignificant to the overall emissions profile, as
was described in the slides.  Ms. Brenda Shine of Midwest
Research Institute assured her that the size and, therefore, the
capital cost of the control device was based on the peak or
maximum flow.  Ms. Mclntire suggested that the "mass flux" term
be introduced earlier in the document and pointed out some
typographical problems with the document.  Ms. Mclntyre also
asked about the specifics of the pressure testing provision
contained in the equipment leaks negotiated regulation.  This
question was addressed by Mr. Bob Ajax (seated in the audience),
formerly of the OAQPS Emission Standards Division, who was the
EPA representative in the development of this regulation while an
BSD Branch Chief.  He explained the background of the regulation
and added that the provision allowing pressure testing for batch
equipment was taken directly from industry suggestions.
Ms. Mclntire also expressed her concern that the CTG would
recommend stack testing as a means of verifying emission rate and
added that stack testing of batch emissions could lead to
erroneous results.  [Ed. Note:  EPA has not recommended stack
testing to determine applicability for the batch processes CTG
but rather an estimation procedure as of the date of this NAPCTAC
meeting.

     Mr. Taranto commended the batch team for including energy
and other environmental impacts and asked EPA to address the need
for facilities to obtain emission offsets and to do permitting.
-------
                 VOLATILE ORGANIC LIQUID STORAGE
             CONTROL TECHNIQUES  GUIDELINES DOCUMENT

                       A. EPA PRESENTATION

                         Mr. Mark Morris
                   Emission Standards Division
              U.S.  Environmental Protection Agency
          Research  Triangle Park,  North Carolina  27711

     Mr. Morris presented a summary of the draft CTG. This
presentation is provided in full text below:

     In ozone nonattainment areas there are thousands of tanks
storing petroleum liquids and chemical products at facilities
such as petroleum refineries, chemical plants, manufacturing
facilities,  and terminals and other distribution facilities.
These tanks emit over 200,000 metric tons of volatile organic
compounds (VOC)  annually, making storage tanks one of the largest
stationary sources of VOC emissions.  It is possible to reduce
these emissions by using readily available and cost-effective
controls.

     In this presentation we present the types of storage tanks
and their emission mechanisms and controls.  We also will present
some reasonably available control technology options, or RACT
options, and the benefits and costs of these options.  Finally,
we will discuss the implementation of RACT.

     There are three basic types of tanks.  There are fixed roof
tanks, internal floating tanks, or IFR tanks, and external
floating roof tanks, or EFR tanks.  These tanks are typically
aboveground and field erected.

     Our first diagram is of a fixed roof tank.  These tanks are
typically large, with the average petroleum tank having a
capacity of  1.3  million gallons,  and the average chemical tank
having a capacity of 160,000 gallons to 200,000 gallons.  The
fixed roof tank consists of a welded steel shell with a fixed
roof.  The fixed roof may be sloped or cone-shaped and supported
by one or more columns, or it may be a self-supported dome
without any  supportive columns.  The fixed roof tank is equipped
with hatches that allow access into the tank.  It is also
equipped with a  pressure-vacuum valve.  This valve prevents
damage to the tank by allowing a slight internal pressure or
vacuum to exist  within the tank.   Since this valve allows only a
slight pressure  to exist within the tank, any pressure buildup in
the tank would result in emissions through the valve.


                               llfil
-------
     There are two basic emission mechanisms of the fixed roof
tank:  working losses and breathing losses.  Working losses are
those losses that result due to a change in the liquid level in
the tank.  When liquid is withdrawn from the tank and the liquid
level goes down, ambient air is drawn in through the pressure-
vacuum valve.  This air becomes saturated with VOC's and is
expelled through the pressure-vacuum valve when the liquid level
rises.  Breathing losses result due to daily temperature changes,
which cause the thermal expansion and expulsion of the vapor
inside the tank.  Breathing losses also result from changes in
atmospheric pressure.

     Some of the parameters that affect fixed roof tank emissions
include the tank volume, the number of emptying/filling cycles,
or turnovers, and the vapor pressure and molecular weight of the
stored liquid.  Emissions from typical petroleum and chemical
fixed roof tanks are given on the next slide.

     As shown in the table, working losses make up about 75 to 90
percent of the overall fixed roof tank emissions.  You can also
see from the table that the petroleum tank emits more than the
chemical tank.  Although the chemical tank experiences more
turnovers, the petroleum tank emits more because it is larger.
Emissions in nonattainment areas from fixed roof tanks are given
in the next table.

     Overall, fixed roof tanks emit a substantial amount of
VOC's.  About 23,000 fixed roof tanks emit approximately 87,000
megagrams per year.  As shown in the table, about 11,500
petroleum tanks store liquids with vapor pressures less than or
equal to .5 psia.  These tanks emit about 13,700 megagrams per
year, or about one megagram per tank per year.  About 780
petroleum tanks emit approximately 8300 megagrams per year in the
.5 to 1.0 psia vapor pressure range.  This works out to be about
eleven megagrams per tank per year.  In the vapor pressure range
of 1.0 to 1.5 psia, about 1800 petroleum tanks emit approximately
47,000 megagrams per year, or about 26 megagrams per tank per
year.  You can see from the table that there are no tanks used to
store liquids with vapor pressures greater than or equal to 1.5
psia.  This is due to the fact that the 1977 fixed roof tank CTG
and state implementation plans prohibit the use of fixed roof
tanks for storing liquids above this vapor pressure.  These
emissions can be reduced by using the controls listed on the next
slide.

     Fixed roof tank emissions can be reduced by using vapor
recovery devices such as condensers and carbon adsorbers.  Vapor
control devices can also be used, such as incinerators.  These
devices are capable of reducing emissions by 95 percent or more.
Another, more common option is to install an internal floating
roof.  On average, installing an IFR in a fixed roof tank reduces
emissions by about 95 percent.  Installing an IFR requires that
the fixed roof tank be emptied, cleaned, and degassed.  By
installing an IFR, the fixed roof tank is converted to our second


                              1162
-------
tank type, the internal floating roof tank.

     Again, the internal floating roof tank has two roofs.  It
has a fixed roof and a floating roof which rises and falls with
the liquid level.  The floating roof can rest in complete contact
with the liquid, or it can rest on pontoons above the surface of
the liquid.  IFR's are typically made of aluminum, but can be
made using materials such as steel or stainless steel.  The
floating roof covers most of the liquid surface, and thus
prevents the vaporization of the stored liquid into the space
above the floating roof.  The floating roof does not cover the
entire liquid surface; there is still a space between the
floating roof and the tank wall in which vaporization can occur.
Floating roofs are equipped with seals to close this space.

     Some of the seal types that are used include vapor-mounted
seals, liquid-mounted seals, and mechanical shoe seals.  The
vapor-mounted seal is mounted such that a vapor space exists
between the seal material and the stored liquid.  The liquid-
mounted seal is mounted such that the seal material is submerged
in the liquid and no vapor space exists between the seal and the
liquid.  The mechanical shoe seal consists of a metallic shoe
that is held against the tank wall by springs or weights, and a
seal which extends from the floating roof to the metallic shoe to
close the vapor space.

     Some of the parameters that affect the emissions from the
IFR tank include the tank diameter and the vapor pressure and
molecular weight of the stored liquid.  There are two basic loss
mechanisms of the IFR tank: static losses and working losses.
Static losses consist of losses from seals, deck seams, and deck
fittings.  Working losses, again, result due to changes in the
liquid level.  When the liquid level goes down,  the tank wall  is
exposed.  The liquid that clings to the wall will vaporize and
escape through the roof vents at the top of the tank.   Emissions
from a typical IFR tank are given on the next slide.

     Again, static losses consist of seal losses, fitting losses,
and deck seam losses.  For the purposes of estimating costs and
emissions, a baseline IFR tank was used which was equipped with a
seamed floating roof with a vapor-mounted seal and typical
fittings.  For IFR's equipped with vapor-mounted seals, emissions
can be reduced by taking out the vapor-mounted seal and
installing a liquid-mounted seal.  Emissions could also be
reduced by installing a secondary seal above the vapor-mounted
primary seal.  For IFR's equipped with liquid-mounted seals,
emissions can be reduced by installing a secondary seal above the
liquid-mounted primary seal.  Fitting losses on IFR's can be
reduced by gasketing the fittings.  Gasketing the fittings
results in an emission reduction of about 50 percent.   Some IFR
fittings can be both gasketed and bolted to reduce emissions,  as
in the case of an access hatch.   For seamed IFR's, emissions can
be reduced or eliminated by taking out the seamed roof and
installing a welded roof,  which has no deck seams.  Although


                             11R3
-------
static losses can be reduced by using the controls described
above, there are no controls available  for reducing  the working
losses.  IFR emissions in nonattainment areas are given in the
next slide.

     Overall, about 8000 tanks emit approximately 22,000
megagrams per year.  Most of these emissions are from tanks
storing liquids with vapor pressures greater than or equal to 1.5
psia.  Most of these tanks are fixed roof tank conversions to IFR
tanks due to the 1977 fixed roof tank CTG.

     Our third tank type is the external floating roof tank.  EFR
tanks have no fixed roof but have a roof that rises  and falls
with the liquid level.  EFR's are not typically used in the
chemical industry.  The losses from the EFR tank are similar to
those of the IFR tank in that there are seal losses, fitting
losses, and working losses.  However, EFR losses differ from IFR
losses in several ways.  Since EFR tanks have no fixed roof, the
wind affects the losses more than from  the IFR tank.  EFR tanks
have welded roofs and therefore have no losses from  deck seams as
do IFR tanks.  Emissions from a typical EFR tank are given in the
next slide.

     Again, static losses consist of only seal losses and fitting
losses since EFR's have no deck seams.  There were two baseline
cases for EFR tanks due to past regulations.  The baseline EFR
storing a liquid with a vapor pressure  less than 1.5 psia was one
equipped with a mechanical shoe seal and typical fittings.  The
baseline EFR storing a liquid with any  other vapor pressure was
equipped with a mechanical shoe seal, secondary seal, and typical
fittings.  For EFR's with vapor-mounted seals, emissions can be
reduced by taking out this seal and installing a liquid-mounted
seal or a mechanical shoe seal, or by installing a secondary seal
above the vapor-mounted seal.  For EFR's with liquid-mounted
seals or mechanical shoe seals, emissions can be reduced by
installing secondary seals above these  seals.  Fitting emissions
on EFR's can reduced by gasketing the fittings.  Gasketing the
fittings reduces emissions by about 95  percent.  Again, although
static losses can be reduced, there are no controls  for reducing
working losses.  EFR tank emissions in  nonattainment areas are
given on the next slide.

     About 10,000 EFR tanks emit about  108,000 megagrams per
year.  Most of these emissions are due  to seals on tanks storing
liquids with vapor pressures greater than 1.5 psia.  Since the
1978 external floating roof CTG and state implementation plans
require secondary seals above this vapor pressure, no further
reductions can be achieved above this vapor pressure.  However,
fitting emissions can be reduced at all vapor pressures.

     RACT options for VOL storage consist of control technology
requirements for each tank type and some applicability criteria
such as tank capacity cutoffs and liquid vapor pressure cutoffs.
The control technology requirements for our selected options are,


                             1184
-------
for fixed roof tanks, to install an IFR with a double seal system
or single seal system with a liquid-mounted or mechanical shoe
seal.  The fittings would also have to be controlled.  The
requirements for IFR and EFR tanks would be to install secondary
seals and control fittings.

     This next slide presents our selected RACT options.  These
options differ only in their applicability criteria since the
control technology requirements are all the same.  Option six is
the most stringent option listed.  It has a vapor pressure cutoff
of .5 psia and capacity cutoffs of 20,000 gallons for fixed roof
tanks and 40,000 gallons for IFR and EFR tanks.  Option three in
this table most closely resembles the VOL NSPS level of control.
Option three has a vapor pressure cutoff of .75 psia and a
capacity cutoff of 40,000 gallons for all tank types.  The
impacts of these options are given on the next slide.

     Again, option six is our most stringent option.  It results
in an emission reduction of about 84,000 megagrams per year at a
total annual cost of about 49.3 million dollars, and average cost
effectiveness of about 590 dollars per megagram. Option six
results in an emission reduction of about 80,000 megagrams per
year at a total annual cost of about 37.2 million dollars, and
average cost effectiveness of about 470 dollars per megagram.
Also shown on this table are incremental cost effectiveness
values.  As shown in the table, going from option three to option
four, which is essentially becoming more stringent than the
latest NSPS level of control, results in an incremental cost
effectiveness of about 2200 dollars per megagram.

     Since RACT is a requirement for specific equipment, the
format would be that of an equipment standard.  However, vapor
recovery or control devices are acceptable if they are capable of
achieving 95 percent reduction.  Some sort of compliance
determination would need to be done to ensure proper installation
and operation of the required controls.

     For IFR tanks, this compliance determination would consist
of an initial internal inspection of the tank and seals, followed
by annual visual inspections, and internal inspections once every
ten years.  For EFR tanks, the compliance determination would
consist of initial primary and secondary seal gap measurements,
followed by annual secondary seal gap measurements, and primary
seal gap measurements every five years.  There would also be a
visual inspection whenever the tank was empty.

     The compliance schedule for the different tank types may
differ.  Installing RACT on IFR tanks requires that the tank be
cleaned and degassed.  The emissions that result from the
cleaning process are actually greater than the emission
reductions achieved by installing the controls.  Therefore, it is
recommended that the installation of RACT on IFR tanks be delayed
to the next tank cleaning.  Installing RACT on fixed roof tanks
also requires that the tank be cleaned and degassed.  However,
-------
the emission reductions achieved by installing the controls are
greater.than the cleaning and degassing emissions.  It is
therefore recommended that there be no delay in the installation
of RACT for fixed roof tanks.  Installing RACT on EFR tanks does
not require the tank to be cleaned and degassed.  It is therefore
recommended that there be no delay in the installation of RACT
for EFR tanks

     This concludes our presentation.
                             Ilfifi
-------
  CONTROL TECHNIQUE GUIDELINES
    (CTG) FOR VOLATILE ORGANIC
         LIQUID STORAGE
     NAPCTAC PRESENTATION
       NOVEMBER 21, 1991
                /-> PV
                n 7
b 1906-1. ADD/1
-------
  ORGANIZATION OF PRESENTATION






           •  Types of tanks



           •  RACT options



           •  RACT implementation
b 1906-1. ADD/2
-------
             TYPES OF TANKS
                 Fixed roof tanks



                 Internal floating roof tanks (IFR's)



                 External floating roof tanks (EFR's)
                     lies



b!906-l. ADD/3
-------
Pressure-Vacuum
           Valve
Gauge Hatch
          Manhole
Manhole
                                                                            Tank Support
                                                                            Column
               Nozzle
               (For Submerged
               Fill or Drainage)
                                           I'
-------
   EMISSIONS FROM A TYPICAL FIXED ROOF TANK
Losses
Breathing
Working
Total
Chemical
(160,000 gal,
50 turnovers/yr)
Mg/yr
0.9
5.3
6.2
%
15
85
100
Petroleum
(1 .3 million gal,
1 1 turnovers/yr)
Mg/yr
5.0
15.0
20
%
25
75
100
h 1906-1. ADD'5
-------
      EMISSIONS FROM FIXED ROOF TANKS IN
            NONATTAINMENT AREAS
Vapor pressure (psia)
< 0.5
0.5 - 1
1 - 1.5
> 1.5
Total
Petroleum liquid
Number
11,500
780
1,800
0
14,100
Emissions
(Mg/yr)
13,700
8,300
47,000
0
69,000
Chemical
Number
8,200
450
450
0
9,100
Emissions
(Mg/yr)
10,500
2,250
4,300
0
17,100
MW6-1 .ADD'6
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     FIXED ROOF TANK CONTROLS
              Vapor recovery/control
              Install IFR
b 1906-1. ADD/7
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                                                Cantor Vent
   Peripheral
   Roof Vent
Primary Seal
     Manhole
        Rkn
                                                                        Tank Support
                                                                        Column with
                                                                        Column Well
                                                                             Rbn Pontoon
              Rim Pontoons
Vapor Space
                                      1174
-------
    EMISSIONS AND CONTROLS FOR
           A TYPICAL IFR TANK
Baseline
Baseline
Baseline
Seal losses

Vapor-mounted
Liquid-mounted
Vapor-mounted and
 secondary seals
Liquid-mounted and
  secondary seals

Fitting losses

Ungasketed
Gasketed

Deck seam losses

Seams
Welded

Working losses
                           Emissions
                             (Mg/yr)
                                  0.13
                                  0.06
                                  0.05

                                  0.03
                                  0.21
                                  0.11
                                  0.04
                                  0

                                  0.03
b 1906-1. ADD/9
-------
           EMISSIONS FROM IFR TANKS IN
              NONATTAINMENT AREAS
Vapor
pressure
(psia)
<0.5
0.5 - 1.0
1.0-1.5
>1.5
Petroleum liquid
Number
130
25
60
5,260
Emissions
(Mg/yr)
18
24
84
18,810
Chemical
Number
0
250
250
1,400
Emissions
(Mg/yr)
0
200
300
1,500
M
  h!9O6-l.ADD/10
-------
   Rolling Ladder •
  Pontoon
  Manhole
•Guide Pole
Main Drain
Automatic
 Bleeder
   Vent
                                      Tank Gauge

                                      Access Hatch

                                      Seal Envelope
                                                                                 Primary
                                                                                 Shoe Seal
                                                                                  • Roof Leg
                                                                                   Support
                                         Rim Vent
                                                        r
                                                        1—Roof Drain
                                          ~ 77
                                           1- -.' a
-------
    EMISSIONS AND CONTROLS FOR
          A TYPICAL EFR TANK
Baseline
«1.5 psia)
Baseline
(>1.5 psia)
Seal losses

Vapor-mounted
Vapor-mounted and
 secondary


Mechanical shoe
                           Emissions
                             (Mg/yr)
          Mechanical shoe and
           secondary

          Liquid-mounted
          Liquid-mounted and
           secondary

          Fitting losses

          Ungasketed
          Gasketed

          Working losses
                                  15.0
                                  4.7
                                   1.25
                        0.12
                        0.70
                        0.10
                        0.24
                        0.02

                        0.22
                   T
                   JL
b!906-l. ADD/12
-------
        EMISSIONS FROM EFR SEALS AND
       FITTINGS IN NONATTAINMENT AREAS
Vapor
pressure
(psia)
<0.5
0.5 - 1
1 - 1.5
>1.5
Number of
tanks
960
300
470
8,000
Seal
emissions
(Mg/yr)
450
330
1,250
91,500
Fitting
emissions
(Mg/yr)
73
75
190
15,600
Total
523
405
1,440
105,400
M906-I ADD 13
-------
        RACT OPTION VARIABLES

              •  Control technology
              •  Tank capacity
              •  Liquid vapor pressure
                   II
bl906-l. ADD/14
-------
     RACT  CONTROL TECHNOLOGY

          •  Existing FIXED ROOF TANK -
             INSTALL IFR EQUIPPED with
             -   Vapor mounted primary and
                secondary seals
                      OR
             -   Liquid mounted primary seal
                      OR
             -   Shoe seal
                      AND
             -   Control fittings
          •  Existing IFR
             -   Control fittings
             -   Install secondary seal over
                vapor mounted primary seal
          •  Existing EFR's
             -   Control fittings
             -   Install secondary seal
                   T 1 Q
                   i. i s ?
b!906-l. ADD/15
-------
                    RACT OPTIONS
Option No.
1
II
III
IV
V
VI
Small
fixed roof
(20K < V <40K
gal)

--
—
—
VP>1.5
VP>0.5
Large
fixed roof
(V >40K gal)
VP>1.0
VP>1.0
VP>0.75
VP>0.5
VP>0.5
VP>0.5
Internal
floating roof
(V >40K gal)
VP>1.5
VP>1.0
VP>0.75
VP>0.5
VP>0.5
VP>0.5
External
floating roof
(V >40K gal)
VP>1.5
VP>1.0
VP>0.75
VP>0.5
VP>0.5
VP>0.5
CO
  M9O6-I.ADD/16
-------
                 RACT OPTION IMPACTS


Option
No.
1
II
III
IV
V
VI

Emission
reduction
(Mg/yr)
66,200
73,500
79,700
82,800
83,400
84,000
Total
annual
cost
($106/yr)
23.8
32.0
37.2
44.0
46.1
49.3

Cost
effectiveness
($/Mg)
360
430
470
530
550
590
Incremental
cost
effectiveness
($/Mg)
N/A
1,100
900
2,200
3,800
4,800
SO
CO
  M906-1. ADD/17
-------
        RACT IMPLEMENTATION
            Equipment format
            Compliance determination
                  1184



b!906-l.ADD/18
-------
     COMPLIANCE DETERMINATION
                 FOR IFR's
       Initial internal inspection

       Annual visual inspection

       Internal visual inspection once every
       10 years
b!906-l. ADD/19
-------
     COMPLIANCE DETERMINATION
                FOR EFR's
       Initial gap measurement

       Annual secondary seal gap measurements

       Primary seal gap measurement once every
       5 years

       Visual inspection whenever tank is empty
                  JL


b 1906-1. ADD/20
-------
         COMPLIANCE SCHEDULE
    •  IFR's - existing IFR's required to install
       RACT at next scheduled cleaning or 10
       years after promulgation

    •  Fixed roof tanks

    •  EFR's
                  T i 07
                  .L 1 e.J i


b 1906-1. ADD/21
-------
B.  INDUSTRY PRESENTATIONS
-------
        Presentation to the USEPA's NAPCTAC
Commenting on the Draft CTG for VOL Storage  Document

           Sheraton  Inn University Center
                Durham, North  Carolina

                Presented  by Rob Ferry
            Conservatek Industries, Inc.
            Chapel Hill, North Carolina
                  November 21,  1991
                          1189
-------
Summary

The conversion   of   external  floating   roof   tanks  to  internal
floating   roof  tanks by covering  the  tank with a self-supporting
fixed  roof is an established equipment option,  recognized by both
the   American    Petroleum   Institute    (API)  and  the  U.   S.
Environmental   Protection    Agency   (EPA).     The    type    of
self-supporting  roof which is typically  used  for this  purpose is
the aluminum dome.  This fact is also recognized by both  API  and
EPA.   It can be readily demonstrated  from the API Publications
2517  and 2519 that this equipment option has lower emissions than
either internal floating  roof tanks which have column-supported
fixed  roofs,  or typical  external floating  roof  tanks.

The recommendations of  this presentation are that:
           covering an  external floating  roof  tank with a
         self-supporting  roof  be recognized as an equipment
         option,
         -  this equipment option  be described  as typically being
         an aluminum dome,  and
         -  this equipment option  be recognized  as being at the
         most efficient end  of the  hierarchy.
Documentation

Recognition of external floating roofs being converted to
internal floating  roofs by covering with a self-supporting  fixed
roof:
         API - Publication 2519 (excerpt attached)
         EPA  - AP-42 (excerpt attached)

The  typical type of retrofit self-supporting fixed  roof is  an
aluminum dome:
         API - Standard 65O Appendix G (publication  scheduled  for
               December 1991)
         EPA  - CTG for Control of Organic Compound  Emissions from
               Industrial  Wastewater (excerpt from draft attached)

This equipment option has lower emissions than either  Internal
floating roof  tanks with columns,  or external floating  roof
tanks:
         This is a straightforward  conclusion  from  the  API
Publications.  The conversion to an internal floating roof  tank
by covering an external floating roof  tank  would result  in a  floating
deck with no deck  seams,  columns  or stub drains.  API  Publication
2519 has separate figures for typical fitting loss factors  for
column-supported  fixed  roofs  and  self-supporting fixed roofs.
This comparison is summarized in a Table from an article
published in  the  Oil and Gas Journal (copy attached).
         API Publication 2517 expressly states that emissions  from
external floating  roof tanks is wind dependent,  and API
Publication 2519  expressly states  that the  wind  movement  in a
tank which is covered  with a  freely vented  fixed roof  is not
significant.  Covering  the external floating roof tank, then,
eliminates  the effect  of the primary force which Induces vapor
losses (i.e. the wind).
                                11
-------
The magnitude of this reduction is illustrated on the attached
Figure 1 for both a  typical fitting  scenario and for the case of
a slotted gauge pole.  There  is not  presently a table of loss
factors for the fittings with  this equipment option,  and
alternate methodologies result in different factors.    This is
illustrated  in Figure  1  by  showing  a range  for  the loss  factors,
which is bounded by the two commonly suggested  methodologies.
The API is  currently preparing a contract to have the previous
test data reviewed, and the conflict in the factors  resolved.  It
is readily apparent,  however,  that wherever the most appropriate
value may fall  within  the defined range,  it  would still represent
a significant reduction  in emissions.
Conclusion

If  the  CTG is  silent with respect  to this  equipment option,  then
the States may  not  recognize the emission control efficiency  that
a user achieves by  covering  an external floating  roof tank with a
dome.   Such an omission might serve, in effect,  to discourage the
use of a very effective control technology.   I respectfully
request,  therefore,  that the language  of  the CTG  be
modified to incorporate the recommendations  set forth in  the
Summary above.  This could be  achieved by adopting the specific
language which is  included  in the  API comments concerning this
issue,  and additionally including descriptive  language
identifying aluminum dome roofs, similar to that in the
Industrial Wastewater  CTG (excerpt attached).
-------
                               EVAPORATION LOSS FROM INTERNAL FLOATING-ROOF TANKS
                                                                                                          19
    SECTION 2—DESCRIPTION OF INTERNAL FLOATING-ROOF TANK COMPONENTS
 2.1   Internal Floating-Roof Tanks

   Internal floating-roof tanks are cylindrical vessels that
 have both a fixed roof over the top^of the  tank, and a
Jloating deck that rests on the liquid stock surface. There
 are two  basic  types  of internal floating-roof tanks:
 (1) tanks in which the fixed roof is supported by vertical
 columns within the tank, which are typical of fixed-roof
 tanks fitted with an internal floating deck; and (2) tanks
 with a self-supporting fixed roof, with no internal sup-
 port columns, which are typical of external floating-roof
 tanks covered  with a fixed roof.  Tanks initially con-
 structed with both a fixed roof and a floating deck may be
 of either  type.
      addition to a  cylindrical shell and fixed roof, the
 basic components of an internal floating-roof tank in-
 clude:  (1) a floating  deck; (2) an  annular rim seal at-
 tached to the perimeter of the floating deck;  and (3) fit-
 tings that penetrate the floating deck and provide support
 for the fixed roof or serve operational functions. General
 types of these components, which are available in a range
 of commercial  designs, are described in this section.
 Included in these descriptions are comments  on evapora-
 tive loss  potential,  as well as  some design and opera-
 tional characteristics.  There are  other factors, such as
 tank maintenance and safety,  which  are important in
 designing and  selecting  tank equipment, but which are
 outside the scope of this publication.
   The use of an internal floating deck will reduce the
 concentration of hydrocarbon vapor in the space between
 the floating deck and the fixed roof from  that which
 would occur in a fixed-roof tank. This could  result in the
 occurrence of flammable vapor-air mixtures within the
 tank. To minimize the occurrence of flammable vapor-air
 mixtures, vents are installed at the top of the tank shell or
 in the fixed roof to provide circulation of air  through the
 space between the fixed roof and the floating deck. API
 Standard 650 [1], Appendix H, specifies the use of such
 vents and outlines design details for the storage of pe-
 troleum liquids. Such  tanks are referred to as freely
 vented internal floating-roof tanks and are those for
 which the loss-estimating  procedures  in Section 1 are
 applicable.
   Closed internal floating-roof tanks refer to those which
 are vented only through a pressure/vacuum  relief vent.
 Such tanks are sometimes used in chemical liquid service
 and in petroleum liquid service  where API Standard 650
 is not used. These  tanks  are  typically designed  with
 auxiliary  safety devices, as specified  by the user. The
 loss-estimating procedures in Section 1 are not applicable
 to closed  internal floating-roof  tanks.
2.2   Floating  Decks

   Floating decks are typically used to control evapora-
tive stock loss. The basic design concept is to reduce the
liquid surface exposed to evaporation to a minimum by
placing a floating deck in contact with the liquid surface
or by confining a layer of saturated vapor under a vapor-
tight  deck floating above the liquid. The loss of vapor
otherwise displaced from fixed-roof tanks by filling and
breathing is virtually eliminated. Evaporation loss does
occur during standing  storage through the  annular rim
space, deck fittings, and, in some cases, deck seams.
   Floating decks are used in volatile stock service, for
stocks with a true vapor pressure at storage conditions
below atmospheric pressure  (that  is, nonboiling). They
are available in virtually all commercial tank sizes, with
diameters ranging from about 400 feet to 20 feet,  and
with slight modification, down to 8  feet. Methods  and
materials have been developed to properly seal the annu-
lar space between the tank shell and the deck rim plate,
as well as sealing  around any number of  fittings  that
penetrate the deck.
   Floating decks  are currently of  two general  types:
(1) decks constructed by bolting (or mechanically join-
ing by any method) sheets or panels of deck material and
(2) decks  of welded construction.  Decks  with  bolted
seams are typically made  of lightweight materials,
whereas welded decks are typically made of steel plates.
Both types of decks are typically designed in accordance
with API Standard 650, Appendix H.
   Floating decks  can  be  further characterized by the
location of the deck relative to the liquid stock surface. A
deck that is supported above the liquid stock surface by
bouyant structures  is referred to as a noncontact deck. A
deck  that floats directly on  the liquid stock surface is
referred to  as a contact deck. Steel decks are typically of
contact design, whereas nonferrous materials are used in
both noncontact and contact designs.
  These general types and designs of floating decks are
currently available in many different materials  and with
various design features. The basic types of floating decks
used in internal floating-roof tanks are described in 2.2.1
through 2.2.4  and  illustrated in Figure 6. More detailed
descriptions are included  in  Bulletin 2513 [7] for the
welded deck types.

2.2.1   NONCONTACT DECKS WITH BOLTED
       SEAMS

  This  deck type is currently available in two basic
designs.  The  most common design  consists  of sheet
aluminum bolted to an aluminum grid framework to form
                                                  •v "

-------
 14
                                                          API PUBLICATION 2519
                 i
                 u.~
                 a
                 Q

                 I
                          4500
                           4000
                           3500
                           3000
                           2500
                           2000
1500
                           1000
                            500
                                                            BOLTED DECK
                                                   F, = (0.0228) D2 + (0.79) D + 105.2
                                                   \
                                                       7
                                                                                    \
                                                                                             7
                                                                                        WELDED DECK (See Note)
                                                                                     F, = (0.0132) D2 + (0.79) 0 + 105.2
                                          50        100        150       200       250
                                                                     TANK DIAMETER, D (It)
                                                                                            300
                                                                                                     350
                                                                                                               400
 BASIS: Fittings include: (1) access hatch, with ungasketed, unbolted cover; (2) adjustable deck legs; (3) gauge
 float well, with ungasketed, unbolted cover; (4) sample well, with slit fabric seal (10 percent open area); (5) 1-
 inch diameter stub drains (only on bolted deck); and (6) vacuum breaker, with gasketed weighted mechanical
 actuation. This basis was derived from a survey of users and manufacturers. Other fittings may be typically useil
 within particular companies or organizations to reflect standards and/or specifications of that group. This figure
 should not supersede information based on actual tank data.

 NOTES: If no specific information is available, assume welded decks are the most common/typical type currently
> in use in tanks with  self-supporting fixed roofs.
                          Figure 2—Total Deck Fitting Loss Factors (F,) for Typical Deck  Fittings
                                            in Tanks with Self-Supporting Fixed Roofs
-------
External Floating Roof  Tanks  -  A  typical  external  floating roof tank is
shown  in Figure  A.3-2.   This  type of  tank consists  of a  cylindrical  steel
shell  equipped with  a roof which  floats on the  surface of the  stored liquid,
rising and  falling with the liquid level.   The  liquid surface  is  completely
covered by  the floating roof, except  at the small annular space between the
roof and the tank wall.  A seal (or seal  system) attached to the  roof
contacts the tank wall  (with  small gaps,  in some cases)  and covers the
annular space.   The  seal slides against the tank wall as  the roof is raised
or  lowered.  The purpose of the floating  roof and the seal  (or  seal  system)
is  to  reduce the evaporation  loss  of  the  stored liquid.

Internal Floating Roof  Tanks  - An  internal  floating  roof  tank has both a
permanent fixed  roof and a deck inside.   The deck rises  and falls with the
liquid level and either floats directly on  the  liquid surface  (contact
deck)  or rests on pontoons several  inches  above the  liquid surface (non-
contact deck).   The  terms "deck"  and  "floating  roof"  can  be used
interrhanflpably  in rpfprpnre  to thf structure floating pn t-ho ] j gi)j d_i n^jHp
    tank.^ihere are two basic types  of internal floating roof  tanks, tanf
in  which the fixed roof is supported  by vertical columns  within the  tank,
and tanks with a self-supporting  fixed roof and no  internal support  columns.
Fixed  roof  tanks that have been retrofitted to  employ a  floating deck are
typically of the first  type,  while external floating  roof tanks typically
have a self-supporting  roof when  converted  to an internal floating roof
tank.  Tanks initially  constructed with both a  fixed  roof and a floating
deck may be of either type.
    _—	•—~^-~	-v___
     The deck serves to restrict evaporation of the organic liquid stock.
Evaporation losses from decks may  come from deck fittings, nonwelded deck
seams, and  the annular  space  between  the  deck and tank wall.  Typical
contact deck and noncontact deck internal  floating roof tanks are shown in
A.3-2
Figure 4.3-2.  External floating roof tank.1

                EMISSION FACTORS
                                 1194
9/85
-------
c/EPA
United States      Office of Air Quality
Environmental Protection Planning and Standards
Agency        Research Triangle Park, NC 27711 April 1989
Air


Guideline Series
       Control of Volatile
       Organic Compound
       Emissions from
       Industrial
       Wastewater

       Volume I • Chapters

       Preliminary Draft
-------
 ratio  of the  tank diameter to the depth of the wastewater contained in the
 tank.	
     .--' ~» •	•——^
^   An  existing open-top tank can be converted to a fixed-roof tank by
 retrofitting  the tank with a dome roof.  Aluminum, geodesic dome roofs are
 available  from several  manufacturers.  These domes have been used
 successfully  to cover petroleum and chemical storage tanks.   The domes are
 clear-span,  self-supported structures (i.e., require no internal columns  be
 placed in  the tank)  that can be installed on open-top tanks ranging in
 diameter from 5 to over_100 m (15 to over 330^ft)_.	
      Although fixed-roof tanks provide large reductions in organic air
 emissions  from open-top tanks, fixed-roof tanks still can emit significant
 quantities of organics.  The major sources of organic air emissions from
 fixed-roof tanks are breathing losses and working losses.  Breathing  losses
 occur from the expulsion of vapor through the roof vents because of the
 expansion  or  contraction of the tank vapor space resulting from daily
 changes in ambient temperature or barometric pressure.   These emissions
 occur in the  absence of any liquid level  change in the tank.  Working  losses
 occur from the displacement of vapors resulting from filling and emptying of
 the tank.
      Breathing and working losses from fixed-roof tanks can be reduced by
 installing an internal  floating roof, connecting the tank roof vents  to an
 add-on control device,  or installing pressure-vacuum relief valves on  the
 tank roof vents.  The use of internal floating roofs in fixed-roof tanks  is
 discussed  in  Section 4.3.2.2.
      For add-on control applications, vapors are contained in the tank until
 the internal  tank pressure attains a preselected level.  Upon reaching this
 level, a pressure switch activates a blower to collect the vapors from the
 tank and transfer the vapors through piping to the add-on control device.
 As a safety precaution, flame arrestors normally are installed between the
 tank and control device.  Other safety devices may be used such as a
 saturator  unit to increase the vapor concentration above the upper explosive
 limit.  Add-on control  devices for organic vapors are discussed in
 Section  4.4.
                               113R
                                     4-24
-------
    Fitting  losses
                                                                     Fig. 4
                                            Column-supported
                                               ungasketed
              0 :   20  '•  40  ,  66    60,    tOO   120   140   160   186   200
                >•'•-,      ;   .'.M :'! ,   ,         ''.•'{•     •  ,;
                  . '!..         ;; ,    Tank diameter, H         ' ;
 with the same  functionality. Further,
 losses from some deck seams in IFRTs,
 unlike EFRTs, contribute significantly
 to total loss. Fig. 1 shows an example,
 for a specific  case,  of  how  highly
 variable losses are from the two types
 of floating-roof tanks, with  varying
 wind speed and different rim seal and
 floating deck types. Such comparisons
 can be made for specific applications
 to identify cost-effective  loss control
 measures.
   Slock inventory control. The esca-
 lating value of petroleum stocks over
 (he past decade  has caused industry to
 focus attention  on  programs empha-
 sizing accurate stock inventory ac-
 counting  and   control.   Publication
 2519, together with improved opera-
 tional  and  maintenance  practices,
 provides the operator with more accu-
 rate procedures to  estimate evapora-
 tive stock losses, thus allowing for the
 evaluation of alternative controls that
 will enable the operator to select opti-
 mum los's  control methods.
   Environmental  applications.  An
 emission inventory  for existing tanks
 can be  more accurately developed
 using the new publication. Alternative
 design features  can be evaluated in
 the process of providing emission esti-
 mates required in permit applications
 for modified or  new tanks.
  The loss equations yield estimates
 of the total hydrocarbon vapor emit-
 ted to the  atmosphere. For environ-
 mental  considerations, emissions  of
 interest are generally only the reactive
 hydrocarbon vapor, which is typically
defined to  exclude methane and eth-
 ane. Therefore, these components, if
 present, should be subtracted from the
 calculated  losses for  environmental
 applications. The results of this API
 study, as well as the previous study on
 EFRTs, have provided the basis for API
 reviews and comments  on proposed
 environmental  tankage emission con-
 trol  regulations.  These  results  were
 provided in full detail to the Environ-
 mental Protection Agency, most re-
 cently during the public review period
 for the currently proposed regulation
 on benzene storage tanks.

 Calculating IFRT losses
   Formulation  of equations. Because
 essentially  no  data were  generally
 available on evaporative losses from
 IFRTs,  API/CELM developed a com-
 prehensive  test program to identify
 and  independently evaluate all the
 sources of  loss in  an IFRT  and the
 equipment and stock parameters that
 affect losses from each source.
  CELM formed a task group to over-
 see the test program, to analyze the
 results, and to document the resulting
calculation  procedures.  The test  pro-
gram,  conducted principally by Chi-
cago Bridge &  Iron Co.  (CB&I),  and
the data analysis procedures are de-
scribed in detail in the documentation
records for the  publication.
  Losses primarily occur during stand-
 ing storage. These losses occur from:
  1. The  rim  seal area around the
perimeter  of the floating deck
  2. The  area  where fittings  (e.g.,
columns that support the  fixed  roof
that covers the tank) penetrate through


                L197
   the floating deck
     3. Bolted seams in the floating deck
     Losses  can also  occur during and
   following emptying of the tank, due to
   evaporation of the stock which clings
   to the  tank  shell.  These withdrawal
   losses are accounted for in the publi-
   cation, but are often negligible. Thus,
   to avoid unnecessary complexity, the
   following discussion will assume that
   total IFRT losses can be approximated
   by the standing storage  loss.
     The loss equations account  for all
   the important  tank  and  stock para-
   meters that affect loss.  Thus, the most
   accurate loss estimates  are obtained
   when all of the parameters are speci-
   fied  for  a given tank.  However,  in
   many cases,  little specific information
   is practically available about the tank
   or tanks for which an estimate of loss
   is desired.
     Thus, to accommodate the interests
   of both  maximum accuracy,  when
   parameters are known, and maximum
   utility,  when  parameters  are  not
   known, the publication includes infor-
   mation  on the most common/typical
   values  for those  parameters  which
   may not routinely be  known.
    Minimum input. The minimum in-
   put necessary to develop a  loss esti-
   mate  includes:
    • Slock type (i.e.,  refined   petro-
   leum stock, crude oil, or petrochemi-
   cal)
    • True vapor pressure
    • Tank type  (i.e., column-support-
   ed or self-supported fixed roof)
    • Tank diameter
    All  other parameters can be speci-
   fied for existing tanks using the stated
   most common/typical values (e.g., va-
  por-mounted  seal, column-supported
  fixed roof, bolted deck).
    By specifying these four input para-
  meters, estimates of total  loss, as well
  as the  losses  from each  of the three
  sources, can  be calculated.
    Fig. 2 shows how total and source-
  specific losses increase with increas-
  ing tank  diameter  when the  other
  three  basic parameters are  constant
  and specified as noted. Similar plots
  in which  the  other parameters  are
  varied would show:
    • That total loss is roughly propor-
  tional to TVP
    • That total loss from a petrochemi-
  cal is  equal to that from  gasoline (for
  the same TVP), but that crude oil loss
  is approximately 60% lower
    • That the fitting loss is significantly
  reduced if no  columns  are used  to
  support  the fixed roof.
    Additional  parameters. In addition
  to the four required input parameters
  discussed  in  the preceding, several
  other  parameters, if known,  can be
  used to improve the total  loss estimate
  and to evaluate various  loss control

TECHNOLOGY 5
-------
        5000
    4-
                                                                EFRT 10mph SLOTTED GUIDE-POLE +  TYPICAL FITTINGS
,£>
    o
    E
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   a
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   en
   t/)
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   o
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   UJ
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   O
        4-000"
3000 _,_
        2000-
1000-4-
                                                               -EFRT 10mph SLOTTED GUIDE-POLE W/ GASKETED  COVER
                                                                + TYPICAL FITTINGS
•                                                        IFRT, COLUMN-SUPPORTED FIXED ROOF, BOLTED  DECK,
                                                        TYPICAL FITTINGS
                                                                APPROXIMATE REDUCTION IN FITTING LOSS FACTOR BY
                                                                COVERING AN EFRT WITH A SELF-SUPPORTING FIXED  ROOF
                                                       •EFRT - W/ TYPICAL FITTINGS O 10mph
                                                    -*— EFRT - W/  SLOTTED GUIDE POLE + TYPICAL FITTINGS O Zmph1
                                                       -IFRT - SS  FIXED ROOF.  WELDED DECK. SLOTTED GUIDE POLE1
                                                       •IFRT - SS  FIXED ROOF,  WELDED DECK, TYPICAL FITTINGS 2
                                                       -EFRT - W/  TYPICAL FITTINGS O 2mph 2
                                           100'*
                                                   150'*
                                                                 1.2
                                 TANK  DIAMETER  (ft)
                          HIERARCHY  OF EQUIPMENT OPTIONS
                               FITTINGS &  DECK SEAMS

                                     FIGURE  1
ALTERNATE APPROACHES TO EFRT CONVERTED TO  IFRT BY
COVERING WITH  A SELF-SUPPORTING FIXED ROOF.  API IS
CURRENTLY REVIEWING FITTING FACTOR DATA TO CLARIFY
THIS SCENARIO.

NOTE:  FITTING SCENARIOS ARE TAKEN AS THE TYPICALS
DESCRIBED IN API PUBLICATIONS 2517 AND 2519 UNLESS
NOTED OTHERWISE.
-------
CHEMICAL
MANUFACTURERS
ASSOCIATION
                                               STATEMENT OF

                                            TERRI  RANGANATH

                                               ON BEHALF OF

                                 THE CHEMICAL  MANUFACTURERS ASSOCIATION

                                               BEFORE  THE

                       NATIONAL AIR POLLUTION  CONTROL  TECHNIQUES ADVISORY COMMITTEE

                                                 ON  THE

                           CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS FROM

                             VOLATILE ORGANIC  LIQUID STORAGE IN FLOATING AND

                          FIXED ROOF TANKS CONTROL TECHNIQUES GUIDANCE DOCUMENT

                                            NOVEMBER 21,  1991
                                             JL >
                             2501 M Street, NW     202-887-1100
                             Washington, D.C. 20037  Telex 89617 (CMA WSH)
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                   CHEMICAL MANUFACTURERS ASSOCIATION
           TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL
                  TECHNIQUES ADVISORY COMMITTEE ON THE
           CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS FROM
             VOLATILE ORGANIC LIQUID STORAGE IN FLOATING AND
          FIXED ROOF TANKS CONTROL TECHNIQUES GUIDANCE DOCUMENT
     My name is Terri Ranganath.  I am air quality engineer for E.I. du
Pont de Nemours and Company.  I am speaking to you today on behalf of
the Chemical Manufacturers Association (CMA) where I serve as the work
group leader for the New Source Performance Standards/Control
Technology Work Group.  CMA is a nonprofit trade association whose
member companies represent over 90 percent of the production capacity
of basic industrial chemicals in the United States.  We are pleased to
have this opportunity to present our views to the National Air
Pollution Control Techniques Advisory Committee.

     CMA appreciates the statutory requirements for controlling
volatile organic compound (VOC) emissions and the requirement that
ozone nonattainment areas be regulated by reasonably available control
technology (RACT) standards.  Because they form the bases for RACT
standards, CTG's must be documents of high technical quality.

     At a minimum, CTG's should accurately describe the types of
facilities that will be affected by RACT standards.  CMA, however, does
not believe that the "presumptive norm" described in the CTG document
for storage tanks accurately describes the types of volatile organic
liquid (VOL) storage vessels that are commonly in use by the vast
majority of the chemical industry.   The applications in the CTG were
based primarily upon model tanks and model liquids generally employed
by the petroleum industry and can not be readily extended to chemical
facilities without consideration for the unique components of the
industry.   Therefore, CMA believes that the information contained In
the CTG does not have broad based applicability across the chemical
industry.

     Also, while the CTG has broadly defined the types of facilities
which will be subject to the RACT standards, the document does not
clearly establish the goals or the applicability parameters.  CMA
believes that both issues need to be definitively addressed prior to
publication of final guidance document to avoid any confusion on the
part of the regulated community.

     CMA has several recommendations regarding the content of the
storage tank CTG and the approach for defining what is RACT for sources
of VOC's from liquid storage tanks.
-------
 The Applicability  Parameters  and Goals  of  the  CTG  Are Not  Clearly
 Defined

      In explaining what will  be considered an  affected source  for the
 purposes of  this particular CTG, the document  allows for the state
 regulatory agency  to define the specific source or "affected tank"
 which will be  covered by RACT.  The CTG also suggests that the  state
 agency define  vapor pressure  and tank applicability ranges for  each
 type  of tank.  While CMA supports this  basic premise, we believe that
 states require guidance in setting vapor pressure  cut-offs for  RACT
 applicability.  Further, EPA  needs to clearly  define for state  agencies
 the scope of this  CTG and its  relationship to  previously published RACT
 standards.

      The CTG,  as presently written, does not clearly define for state
 agencies the scope of this guidance.  Nor  does it  clearly define its
 relationship to previously published control standards.  Environmental
 managers will  be faced with the question of whether the intended
 purpose of the CTG is to incorporate the two previously published CTG's
 and three NSPS documents, or  to merely  cover facilities not addressed
 in these documents.  The confusion could lead  facilities to duplicate
 their efforts  unnecessarily.   The intention of the CTG needs to be
 stated precisely and directly  in order  to  avoid such an outcome.

     The CTG also  needs to establish parameters for vapor pressure
 cut-offs.  The CTG suggests that state  agencies define vapor pressure
 and applicability  range for each type of storage tank.  While CMA
 supports this  premise, we believe that  RACT standards should issue
 guidelines for setting vapor pressure cut-offs.  The vapor pressure
 baseline discussed does not adequately  consider low volatility  liquids
 such as monomers like styrene, which can polymerize and cause floating
 roof tanks to  fail and not operate as a control device.  Establishing
 cut-offs avoids setting levels of control  which result in diminishing
 returns, both  incrementally and economically.
The CTG Inadequately Addresses Tanks with a Storage Capacity of Less
Than 40.000 Gallons

     Throughout the CTG, the EPA applies what is defined as the
"presumptive norm" for RACT to tanks with volume and vapor pressure
cut-offs of 40,000 gallons and 1.5 psia.  This "norm" and all the
accompanying estimations were based on the petroleum industry.  While
there exists some similarities between the petroleum and chemical
industries, the two do not parallel one another closely enough for the
standards described in the CTG to serve as an accurate reflection of
what may be achievable by the chemical industry.

     EPA also does not consider or adequately address tanks with a
storage capacity of less than 40,000 gallons.  Many of the tanks
utilized in the chemical industry are not 40,000 gallons or larger as
the EPA has assumed in the CTG.  EPA also erroneously assumes that

                             -; 1~1
                             ^ t~>  ' L
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horizontal tanks generally have a capacity of  less than  20,000
gallons.  The CTG states that "... most storage tanks below  20,000
gallons are horizontal rather than vertical tanks and a  large
percentage of these tanks are also underground...".  Across  the
chemical industry vertical tanks are operated  which have capacities of
less 20,000 gallons and there are numerous horizontal tanks  with
capacities above 20,000 gallons.  Further, based on this incorrect
assumption, the CTG document neglects to include any emission profiles
for tanks with capacities smaller than 20,000  gallons.

     In addressing tanks with capacities of 20,000 to 40,000 gallons,
the CTG considers only one vapor pressure and  two turnover rates. CMA
recommends that the EPA expand the emission profiles to the  full range
of vapor pressures discussed in the CTG document, as well as to tanks
with capacities less than 20,000 gallons.  Also, smaller tanks usually
have a higher turnover rate than two.
The CTG Overestimates the Control Efficiency of Internal Floating
Roofs

     Throughout the CTG, the equipment options and the estimated
control efficiencies described are again, based on the petroleum
industry, rather than the chemical industry.  This basis for evaluating
the effectiveness of the control techniques are inappropriate when one
considers expanding the efficiencies to process units which are unique
to the chemical industry.

     In estimating the rate of emissions from internal floating roof
tanks, the CTG acknowledges several factors, including type of roof and
seal selected, number of turnovers, tank volume and liquid type, will
affect the final amount of emission reductions achieved by the model
fixed roof tank.  Based on these factors, all of which were designed
with petroleum liquids as the baseline, the CTG estimates that a
facility can realize a reduction in emissions of 69 to 98 percent.

     CMA believes that the extrapolation of so many factors is
inappropriate and recommends that the CTG be developed which more
accurately reflects the percent reductions achievable by actual
chemical facilities.
The GTG Offers Limited Flexibility in Terms of Technical Alternatives

     The CTG document examines a limited number of control technologies
and, in fact, fails to consider technologies such as tank insulation
and submerged fill that are widely used by chemical facilities to
reduce emissions.  The CTG offers only one equipment standard (internal
floating roofs) and only one stringent control option (98 percent
control) as acceptable control technologies for 20,000 to 40,000 gallon
tanks.  In effect, this limited flexibility discourages the development
of technically innovative control options facilities would consider
-------
when examining  compliance  measures.   Additional  flexibility  is  needed
since neither an  internal  floating  roof,  nor  thermal  combustion are
realistic  controls  for  some  chemical  industry systems.

     The CTG also foregoes any  evaluation of  control  options  for  tanks
with capacities less  than  20,000 gallons  except  for the  installation of
a condenser, with a required control  efficiency  of 90 percent.   The CTG
states that this was  the only control option  examined because most
storage tanks below 20,000 gallons  are horizontal tanks, and  unsuitable
for internal floating roofs.  As stated elsewhere in  our comments, many
tanks with capacities below  20,000  gallons are vertical  systems.  While
we appreciate EPA addressing an alternative technology,  the CTG as
written does not consider  the condenser acceptable RACT.  By  promoting
the use of condensers in these  tanks,  the designated  98  percent control
level will not  be achieved.   In addition, CMA believes the 90 percent
control level is presumptive.   EPA  should acknowledge that condensers
operate at a range  of control levels  dependent on the system.

     Further, many  facilities are currently examining control measures
which will achieve  a  90-95 percent  control rate  of VOC emissions.
However, due to the lack of  flexibility in control options implied by
the CTG document, such  alternative  control efficiencies will  be
by-passed by facilities because they  could, in fact,  be viewed  as
improper controls   by the EPA.

     Internal floating  roof  control levels are also extremely dependent
on the system in which  they  operate.   One control level does  not
adequately address  the  possible range  of  controls available with an
internal floating roof.  Throughout the CTG,  a general equation must
have been used to calculate  the control efficiency of internal  floating
roofs for control of  VOL's.  That equation should be made part of the
CTG.  CMA recommends  that  facilities  be allowed  to utilize the  equation
to analyze the control  efficiency of  an internal floating roof  on their
systems.  The CTG should then allow the facility to meet or exceed that
control efficiency  in a manner  most suitable  for the  facility.
Therefore, a facility may use maximum  flexibility to  reasonably control
emissions in an effective, cost-effective manner.
The CTG Does Not Adequately Address the Interface Between RACT and
MACT Standards

     CMA is concerned that RACT regulations will be required without
consideration for maximum achievable control technology (MACT)
standards which may apply to the same facility.  The two sets of
standards could potentially create duplicative, possibly inconsistent,
regulations under the one regime.  The inconsistency which may result
could create difficulties in administration and enforcement, including
overlapping requirements, unclear jurisdiction and general confusion.
This problem could be further exacerbated because of different
enforcement authorities and different administrative implementation
programs.
-------
     Both standards are clearly defined in the statute, with RACT not
being more stringent than MACT.  We believe that facilities which have
complied with MACT should be deemed in compliance for purposes of RACT,
CMA urges authorities to be careful in their establishment and
designation of RACT standards and remain cognizant of the possibility
which exists for RACT, in effect, from becoming MACT.

     I thank the committee for the opportunity to testify on behalf of
CMA.  We are willing to offer assistance to EPA in its development of
the CTG and look forward to working with the Agency.  At this point I
would be glad to answer any questions.
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                          C: DISCUSSION

Following the presentations by the EPA, Chemical Manufacturers
Association,  and Conservatek, Mr. Bruce Jordan opened the floor
to questions and comments from the NAPCTAC members.  The short
discussion following the presentations and responses to questions
are summarized in the following paragraphs.

Ms. Mclntire asked if tanks with volumes less than 40,000 gallons
would be controlled by RACT.  Ms. Susan Wyatt of CPB/EPA
responded that the Agency was still examining possible volume and
vapor pressure cutoff points to determine the applicability of
RACT.

Ms. Mclntire also asked what emission reduction and cost
effectiveness was being assigned to IFRs.  Mr. Morris responded
that while the emissions reductions vary, typically IFRs are
about 95% effective in reducing emissions from fixed-roof tanks.
Also while the cost effectiveness would vary, about $300 - $400
per megagram was typical for controlling fixed roof tank, with
the installation of an IFR.

Mr. Taranto asked if RACT would be required equipment.
Mr. Morris stated that RACT would be based on requiring specific
equipment, but that RACT would allow for equivalent equipment and
would also allow for vapor control systems that are 95% effective
in reducing emissions.

Mr. Dennision agreed that RACT should be required equipment, but
suggested that EPA consider bifurcating RACT based on industry
type (i.e., chemical industry and petroleum industry)

Ms. Mclntire commented that while her company (Eastman Chemicals)
has numerous tanks, they do not use IFRs.  She had discussed
control of tanks with company personnel, and they agreed that
requiring IFRs was appropriate if an allowance for alternative
control techniques was a specific component of RACT.  Mr. Morris
responded that in all cases RACT would allow for vapor control
devices to be substituted for the installation of the IFR.
                               O
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D.  CORRESPONDENCE
      * O
         •
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PETREX  Inc.
2343 Dorcon Road • P. 0. Box 907 • Warren, Pennsylvania 16365
Telephone 814-723-2050 • Telefax 814-723-2055 • Telex 510 101 3005

November  12,  1991
United States  Environmental  Protection  Agency
Office of Air  Quality Planning  and  Standards
Research Triangle Park,  NC   27711

Attention:   Mr.  Bruce C.  Jordan
            Director
            Emission Standards  Division

Subject:  NAPCTAC Meeting Novembr  19-21,  1991
          CTG  for Volatile  Organic  Liquids

Gentlemen:

This letter transmits our comments  to the draft  CTG  for  volatile organic
liquid.

Our firm has been in the business  of designing,  manufacturing  and  installing
internal floating roofs  for nineteen years.  The contributors  of these
comments have  at least 30 years experience  each  in the tank, floating roof and
seal industry.

We think the CTG is  well  written and covers its  topic well.  There are however
certain  paragraphs and figures  that we  recommend be  changed.   We desire that
the CTG  fairly represent the current state  of  the art, and government regula-
tion and be technically  correct.  We also believe that the document should be
as generic  as  possible.   Some of our comments  are merely editorial.

These comments  have  also been given to  the  API Committee on Evaporation Loss
Measurement.

We expect to attend  the  session on  November 21,  1991, regarding the subject
CTG.

Very truly  yours,

PETREX,  Inc.
W.  L.  Wagner,  P.E,
President

WLW/br

 P.S.  If you have questions please call me or Bill Blumquist.
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PETREX Inc.
2349 Dorcon Road • P. O. Box 907 • Warren, Pennsylvania 16365
Telephone 814-723-2050 • Telefax 814-723-2055 • Telex 510 101 3005

November 7, 1991
Subject:   USEPA
          Control  Technique Guideline
          "Control  of V.O.C.  Emissions  from V.O.L.
           Storage in Floating and Fixed  Roof Tanks"

Our comments on this document are as  follows:

Page 2-3        Aluminum sandwich  panel  contact type  internal  floating roofs do
Para 2.2.3     not share the design feature of having  a mechanical seam
               consisting of overlapping  alumium  sheets bolted  together with
               clamping bars.  Evaporation  loss tests, made and submitted to
               API, on a mechanical seal  consisting  of a  gasket cast in place
               between two mating extrusions show a  much  lower  seam loss.

Pg. 2-4        Is  it common practice  to use P/V vents  and flame arresters
Para. 2.2.3    to  ventilate an IFR tank?

Pg. 2-4        Horizontal tanks,  above  or below ground, should  be  referred to
Para. 2.2.4    and eliminated from discussion.  Delete comments on
               composition, proportions,  etc.   Delete  illustrations Fig. 2-5
               and Fig. 2-6.

Pg. 2-5        Wiper type seals are also  used on  EFR's.   Add  to description
Para. 2.3.1    and Fig. 2-7.

Pg. 2-5        The discussion and illustrations concerning EFR  tank seals
Para. 2.3      should be limited  to mechanical  shoe  seals, liquid mounted
               seals, vapor mounted seals and secondary seals.   The use of a
               vapor mounted seal with  a  weather  shield is not  permitted and
               should not be shown.  No wiper type primary seals are shown.

Pg. 2-6        The height of the  mechanical shoe  seal  is  not  specified in
Para. 2.3.1.1  various EPA standards, such  as in  the Federal  Register, 40 CFR
               Part 60 Subpart Y  Paragraph  61.271 (a)  (1) (iii) and 40 CFR
               Part 60 Subpart Kb, Paragraph 60.1126 (a)  (1)  (ii)  (C).  This
               is  not definitive  since  the  term "mechanical shoe seal" alone
               does not guarantee the performance desired. The basis, we
               believe for the mechanical shoe seal  emissions is a test
               conducted some years ago by  CBI in California  using a 30 inch
               plus shoe.  Shoes  of lesser  length could not provide the same
               emission but could still qualify as a mechanical seal.  API
               2519 equates a mechanical  shoe seal to a liquid  mounted seal
               but with no limits to  shoe length. Later  in this document Pg.
               7-6, Para. 7.5 shoe height is mentioned.
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USEPA
Control  Technique Guideline

Page two


pg.  2-7         It is  highly doubtful  that the "wiping action" of a secondary
Para.  2.3.1.4   seal aids  in reducing  evaporation loss.  Any "wiped" liquid
               would  be above the primary seal.

Pg.  2-7         A shoe mounted seal  extending from the top of the shoe to the
Para.  2.3.1.4   tank shell  is not a  secondary seal.  This and Fig. 2-9 are
               wrong.  See definition Pg. 2-6, Para. 2.3.1.4.

Pg.  2-7         This implies that a  weather shield may be used over a secondary
Para.  2.3.1.4   seal.   A more common practice is  to combine the functions of
               secondary seal and a weather shield.

Pg.  2-8         Reference is made to Fig.  2-10 b.  This would be better
Para.  2.3.2.1   illustrated if the liquid  level were shown.

Pg.  2-9         In the comments on a shingle type seal the language is
Para.  2.3.2.2   misleading.  If a shingle  type construction does not provide a
               continuous  vapor barrier (as used in weather shields) then it
               should not  be considered a wiper seal.

Pg.  2-9         Wiper  seals using a  "blade" construction should not only be
Para.  2.3.2.2   joined but  sealed.  Simple, mechanical joining may not be vapor
               tight.

Pg.  2-9         Current EPA regulations require the use of a single, liquid
Para.  2.3.2.3   mounted seal or a vapor mounted primary seal plus a secondary
               seal.   The  description in  this paragraph and the illustrations
               in Fig. 2-10 and 2-11  do not reflect this requirement.

Pg.  2-9         The statement "Secondary seals are not commonly used on IFR
Para.  2.3.2.3   tanks", is  wrong.

Pg.  2-11       The primary purpose  of an  IFR vent or as described, "Vacuum
Para.  2.4.1.5   Breaker" is to vent  incoming or outgoing air or vapor through
               the IFR when filling or emptying.  The poppet type described
               and illustrated is strictly mechanical.  Other types operating
               on pressure/vacuum or liquid level are also used.

Pg.  2-13       Why is the  trapped vapor space under a mechanical shoe seal
Para.  2.4.1.8   ventilated  and not the vapor space under any other type of
               vapor  mounted seal?

Pg.  2-13       Reference  to Fig 2-3 is wrong.
Para.  2.4.2.1

Pg.  3-1             These  are a recapitulation of AP 42 Para. 4.3 and API           ppj
Para.  3.1  and  3.2  2519  and seem unnecessary.                                      _j

                                                                                    DO
                                                                                    m
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USEPA
Control Technique Guideline

Page three


Pg. 3-29  '     This is an excellent summary of regulations.
Para 3.3

Pg. 3-32       Some reference shold be made to support Subpart Kb, as it is
Para. 3.3.5    often referred to as such.

Pg. 3-33       Reference to the baseline control method as being a low cost,
Para. 3.3.6    non-contact IFR is wrong.  Depending on the diameter a non-
               contact IFR may cost more.  Also the use of a single vapor
               mounted seal is not permitted.

Pg. 3-34       It may be "picky" but when referring to RVP and then "vapor
Para. 3.4      pressure", TVP should be used.

Pg. 4-5        What is the basis for an IFR installation in a fixed roof tank
Para. 4.3      having an emission reduction of only 69%?

Pg. 4-5        What establishes the non-contact, bolted aluminum IFR as the
Para. 4.3      most basic?  Why is the use of a single vapor mounted seal
               mentioned when it is not permitted?

Pg. 4-17                 When retrofitting any IFR with liquid mounted
Para 4.6.2 and 4.6.3     or secondary seals additional buoyancy and storage
                         loss must be considered.  This may be especially
                         important with non-contact IFR's.

Pg. 4-18       Obviously, emissions from liquid stored in a fiberglass fixed
Para. 4.7      roof tank could be controlled by the use of a fiberglass IFR.

Pg. 5-3        This discussion on the relative effect of turnover Para.
5.2.1          rate and emissions from fixed roof tank vs. IFR tanks ignores
               the same relative effect of breathing losses.

Pg. 5-5        This states that the control options for IFR tanks are to
Para. 5.3      install IFR's??

Pg. 5-6        In considering the secondary impact emissions when emptying,
Para. 5.3.2.1  cleaning and degassing an IFR tank a large source of emissions
               has been ignored.  The large volume of hydrocarbon saturated
               trapped vapor under a non-contact IFR makes a large
               contribution.

Pg. 5-7        To suggest that a secondary seal may be added to an existing
Para. 5.4.2.1  EFR tank with the tank in service may be misleading
               economically and safety wise.  Not all such floating roofs have      "U
               a readily available flange to which a secondary seal can be          [fl
               bolted.  Many company safety rules will not permit such work.        -i{
                                                                                    33
                                                                                    m
                                                                                    *
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USEPA
Control  Technique  Guideline

Page four
Pg.  6-3
Para.  6.2

Pg.  7-3
Para.  7.2

Pg.  7-4
Para.  7.5
Pg. 7-6
Para.  7.5
Using 10 years as expected equipment life may be inaccurate.
A vapor mounted seal does not have to be foam filled,
In this paragraph the seal gap criteria appear only following
the paragraph concerning testing for EFR tanks.  Is the intent
to have these criteria apply only to EFR tanks?

N£ holes, tears or other openings in the shoe, seal fabric or
seal envelope is an absolute statement.  Can this be quantified
as in the gap criteria stated above?
General  commment:
General  comment:
     Table 4-1, Pg. 4-2 lists Control Options 1 through 6,
     later reference in Par'a 5.2, Pg. 5-1 is to Control Options
     1 through 5.  Description of these control options in
     Table 4-1, Pg. 4-2 mentions contact or non-contact for the
     first four options (2-5) and no mention of this for Option
     6.  Later on Pg. 5-21, Table 5-1 Control Option V (most
     effective) is described as a contact type IFR.

     Reading the information presented in Table 3-2, Pg.  3-7;
     Table 4-2, Pg. 4-3; Table 4-6, Pg. 4-13 and the general
     discussion on EFR tanks and gap criteria in Para. 7-5,
     Pgs. 7-5, 7-6 and 7-7 leaves the reader confused about the
     use of mechanical shoe seals in riveted tanks.  Is it
     common practice?  Is it acceptable?  What are emissions?
We will  be  pleased  to  discuss  these comments  with  you,
                                                                                    m
                                     1211
                                                                                    m
                                                                                    x
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                    State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES

                                                                      101 Saudi Wctntcr Street
                                                                            P.O. Box 7921
                                                                 Madison, Wisconsin 53707-7921
Canon D. Besadny                                                          TELEPHONE 608-266-2621
Secretary                                                                  TELEFAX608-267-3579
                                                                          TDD 608-267-6897

 November 14,  1991                                     IN REPLY REFER TO:   4530
 Bruce C.  Jordan,  Director
 Emissions Standards Division (MD-13)
 Office of Air Quality Planning and Standards
 U.S.  Environmental Protection Agency
 Research  Triangle Park,  NC  27711


       SUBJECT:     Comments For Draft  CTG Document   Control of Volatile
                   Organic Compound Emissions from Batch Processes


 Dear  Mr.  Jordan:

 My  name is Steve  Jorgensen,  and I am  an environmental engineer with the
 Wisconsin Dept. of Natural Resources,  Bureau of Air Management.  I've skimmed
 over  the  draft  CTG document entitled  "Control of Volatile Organic Compound
 Emissions from  Batch Processes".   As  a result,  I have several comments
 concerning Chapter 6 and Appendix F,  and will address them in chronological
 order.

       Section 6.3.3.1 Single Stream Versus  Aggregation.

             Sentence 1 of paragraph 2  reads,  ...  and 3/4 of the maximum flow
             rates from each process vent would be used as the maximum
             instantaneous flow rate.

             Question:    Can the reasoning behind using this ratio (3/4) be
                         included in paragraph 2?  What about using the ratio
                         of 1/1?  Such  a ratio would take into account the true
                         maximum (possible)  instantaneous flow rate.

       Section 6.4.1 Industries Covered

             Emissions with durations of under 7,800 hours per year,  for the
             applicable SIC Codes,  are  assumed to be the  result of batch
             processes.   Model  batch processes described  in Tables 6-7 through
             6-10,  however,  set a plant operation limit of 275 days per year
             (24 hour operation per day for  275 days corresponds to 6600 hours
             per year).

             Question:    Can the reasoning for this apparent difference in
                         bases  be included in the section?
                                    •Y f)
                                    JL 
-------
      Section  6.4.3  Baseline Assumptions/Extrapolations

            Question:   What is the exact definition of baseline  emissions?

            My interpretation from this section is that it represents  the
            remaining uncontrolled emissions from SIC Code 2834
            (pharmaceutical preparations) batch processes after pharmaceutical
            CTG controls have been applied.  Section 6.4.4, paragraph  2,
            sentence 3, however, suggests to me that baseline emissions
            include  (in addition to those described above) the uncontrolled
            emissions from the other 6 applicable SIC Codes.

      Section  6.4.4 Reductions

            The notation used to describe RACT options here appears to be
            incomplete.  In addition to Roman numerals and capital letters,
            numbers have been included elsewhere. For Example, the first RACT
            option listed in Table 6-1 is:  IA.1,5,9.

            Question:   What is the significance of the numbers used in the
                        RACT option descriptions?

My remaining comments for Chapter 6 and Appendix F are addressed on enclosed
copies of Figure 6-1; Tables 6-1,3,11, and 16; and page F-l.
The material covered in Section 6.4.2 through the end of the chapter
(including many of the figures and tables) was very difficult for me to
follow.  I still don't understand the RACT VOC options that are being
proposed, or their associated costs.  For these reasons, I cannot make an
overall comment on the validity of the CTG document.
For your information, I have included the number of known facilities by
applicable SIC Code in Wisconsin.  These facilities, located in non-marginal
nonattainment areas, are listed below.

                        SIC Code     No. of Facilities

                          2821               9
                          2834               11
                          2851               18
                          2861               2
                          2865               5
                          2869               3
                          2879               7

A breakdown of plant size (by employee number as in Table 6-15) would be
available upon request.   [  Note:  The total number of facilities in Wisconsin
within each SIC Code category is slightly larger.   In addition, Wisconsin uses
RACT guidelines to set VOC  limits statewide;  exemptions to these limits are
available for specific circumstances. ]
                                    o
-------
Sincerely,
Steven M. Jor.gensen, Engineer
Compliance Section
Bureau of Air Management
Wisconsin Dept. of Natural Resources

cc:   Dean Packard   AM/10
      Jon Heinrich - AM/10
      Dale Ziege   AM/10

Enclosures: Figure 6-1; Tables 6-1,3,11,  and 16; and p. F-l
                                    o
-------
          Cost of Control  by Thermal  Incineration

                     For VOC Concentration of 10000 ppm

                             (T = 1600F. HR = 70%)
30000
28000
26000
24000
27000
70000
j- • - 18000
to
l^» ^16000
*xJ 1 <~t
ct' _ 14000
Mo
** ^12000
0
10000

8000
6000
4000
2000
0






\
\
\



\
\ 1 ^
\ I /o
\ fjr~
\Ci,
\
.


                                                            ^
                                                             ^J^X^i

                                                            InL^M K*>
                                                            * ^^ ^k  ^ ^
                                                            $  ^-l^w'^
                                                            &  $  >    Ic

                                                            * I.*''
 10
On Slita* Ptictnloi)t
                 100
               uw
         1000



UQIIIUB V t t\\ I I o • Halt  •, i I n



       5       10
                                                 r-r ,	



                                                 10000
                                                                  I . I


                                                                  I 0 0 0 IIII
                      S  A * 2,
                                               20       50       1pO
                                                     li
                                                 5t  4tsi
-------
                     Table 6-1. Summary of RACT option exemptions
     PACT OPTION/
  VOLATILITY LEVEL
(CONTROL EFFICIENCY)
         I A. 1,5,9
         (98%)
                                      EXEMPTIONS for
                                    all levels of volatility
         IA.2,6,10
          (98%)
IA.3,7,11
    3/o)
         IA.4,9,12
          (98%)
                                   LOW VOLATILITY SOLVENTS:
                                 if MF < 10.000 bs/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MF0.1508M308 - NO CONTROL
                                MODERATE VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MP0.1062)-961.5 - NO CONTROL
                                   HIGH VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                      if MF >= 10,000 bs/yr AND FR >= (MP0.075)-100 - NO CONTROL

                                   LOW VOLATILITY SOLVENTS:
                                 if MF < 10,000 tos/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MP0.1537)-1527 - NO CONTROL
                                MODERATE VOLATILITY SOLVENTS:
                                 i MF < 10,000 bs/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MP0.0636)-772.7 - NO CONTROL
                                   HIGH VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                      if MF >= 10,000 bs/yr AND FR >= (MP0.055)-450 - NO CONTROL
                                           LOW VOLATILITY SOLVENTS:
                                         if MF < 10,000 bs/yr - NO CONTROL
                              if MF>= 10,000 bs/yr AND FR >= (MP0.0855)-1409 - NO CONTROL
                                         MODERATE VOLATILITY SOLVENTS:
                                         if MF < 10,000 bs/yr - NO CONTROL
                              if MF >= 10,000 bs/yr AND FR >= (MP0.0491)-881.8 - NO CONTROL
                                           HIGH VOLATILITY SOLVENTS:
                                         if MF < 10,000 bs/yr - NO CONTROL
                               if MF >= 10,000 bs/yr AND FR >= (MP0.044)-100 - NO CONTROL
                                   LOW VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MP0.0475)-1563 - NO CONTROL
                                MODERATE VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                     if MF >= 10,000 bs/yr AND FR >= (MP0.0248)-856.3 - NO CONTROL
                                   HIGH VOLATILITY SOLVENTS:
                                 if MF < 10,000 bs/yr - NO CONTROL
                       if MF >= 10,000 bs/yr AND FR >= (MP0.017)-10 - NO CONTROL
                                          -19
                                              * *> 1 P
                                              J_4,< 1.»<
-------
                                       Table 6-2. Percentage of emissions from batch processes
SIC
CODE
2821
2834
2851
2861
2865
2869
2879
SIC DESCRIPTION
Plastics materials and resins
Pharmaceutical preparations
Paints and allied products
Gum and wood chemicals
Cyclic crudes and intermediates
Industrial organic chemicals
Agricultural chemicals
<7800
(hrs/yr)
14,396
8,432
6,006
2,287
223
17,060
92
>0
(hrs/yr) "
124,547
15,459
11,998
20,415
8,365
173,167
3,912
"T 	 " " ' ' "
j
|
% BATCH
; 12%
55%
50%
11%
3%
10%
2%
                  NOTE:  Emissions data was obtained from AIRS facility subset data base search
   CO
Ch

NJ
NJ
-------
               -  /n  Idf&V  /tt£fc frl  •Ty? 6f  /6/  /

Table 6-3. Emission stream characteristics for solvent reaction model process w/ almoiphe^dryer
#of
unit ops per Calculation for 1
model batch unit operation
9.25 Displacement
(2000-gallon vessel)

TOTAL DISPLACEMENT EMISSIONS
(Ibs-batch/year)

Emission
Stream
VOC
LOW VOLATILITY
MODERATE VOLATILITY
HIGH VOLATILITY
LOW VOIJVTIUTY
MODERATE VOLATILITY
HIGH VOLATILITY

Row Rate
(acfm)
18
18
18




Temp.
(DegQ
20
20
20




Duration
(min)
15
15
15




VOC
(vol %)
0.6%
12.6%
57.9%




Emissions
Ib/event
0.29
2.82
30.02



Emissions
Ibs/batch
(Motel)
2.64
26.08
277.66



NO CONTROL
Mass Flux
Ibs/batch
2.64
26.08
277.66
727.02
7172.28
76355.65
CPC (Note 2)
Mass Flux
Ibs/balch
2.64
7.82
30.54
727.02
2151.68
8399.12
             REACTORS
1


M
ro
k=S
CS
1


1





Charging w/purge


1 leal -up w/purge



Reaction w^jurgc


Empty Reactor Purging


TOTAL REACTOR EMISSIONS
(Ibs-batch/year)

LOWVOIATIUTY
MODERATE VOIJkTIUTY
HIGH VOLATILITY
LOW V01.ATILITY
MODERATE VOLATILITY
HIGH VOLATILITY

LOW VOI.ATIUTY
MODERATE VOLATILITY
HIGH VOLATILITY
LOW VOLATIUTY
MODERATE VOLATILITY
HIGH VOLATILITY
LOW VOIJiTIUTY
MODERATE VOLATILITY
HIGH VOLATILITY
30
30
30
30
30
30

150
150
150
100
100
100



20
20
20
20 to 30
20 to 30
20 to 30

37
37
37
20
20
20



15
15
15
5
5
5

3
3
3
1
1
1



0.1%
3.1%
14.5%




0.5%
7.5%
27.2%
0.1%
2.7%
12.8%



0.12
1.17
12.51
0.1
0.52
5.13

0.39
2.65
22.19
0.06
0.5
1.5



0.12
1.17
12.51
0.10
0.52
5.13

0.39
2.65
22.19
0.06
0.50
1.50



0.12
1.17
12.51
0.10
0.52
5.13

0.39
2.65
22.19
0.06
0.50
1.50
184.08
1332.65
11365.50
0.12
1.17
5.63
0.10
0,52
1.85

0.39
1.35
5.33
0.06
0.32
1.26
184.08
925.91
3866.79
/•     f   /
                                  /n4
                                  ri
                                                         .

                                                      r
                                                                                       A



                                                                                    F
                                                                                                                                                     n**t ?  ?-
-------
Table 6-11. Solvent reaction model plant w/ atmospheric dryer
           MODEL PLANT EMISSIONS(lbs/yr)
                        SMALL/NC
   LOW VOLATILITY       333.236
MODERATE VOLATILITY    36U50
   HIGH VOLATILITY       749367
                           SMALL/CPC
                              36.236
                              44,621
                              86,603
                        MEDIUM/NC
   LOW VOLATILITY       1,109.676
MODERATE VOLATILITY    1203296
   HIGH VOLATILITY       2,495393
                           MEDIUM/CPC
                              120,666
                              148,590
                              288388
   LOW VOLATILITY
 MODERATE VOLATILITY
   HIGH VOLATILITY
 LARGE/NC
  3332J60
  3,613.502
  7.493,673
 LARGE/CPC
   362360
   446,215
   866.031
            MODEL PLANT EMISSIONS(tons/yr)
   LOW VOLATILITY
 MODERATE VOLATILITY
   HIGH VOLATILITY
 SMALL/NC
   166.62
   180.68
   374.68
 SMALL/CPC
    18.12
    2231
    4330
   LOW VOLATILITY
 MODERATE VOLATILITY
   HIGH VOLATILITY
MEDIUM/NC
   554.84
   601.65
   1247.70
MEDIUM/CPC
   6033
   74.29
   144.19
   LOW VOLATILITY
 MODERATE VOLATILITY
   HIGH VOLATILITY
 LARGE/NC
   1666.18
   1806.75
   3746.84
 LARGE/CPC
   181.18
   223.11
   433.02
NC = No Control
CPC = Current Pharmaceutical Control
   1. For surface condensers on sources emitting:
     -25C for VP>300mmHg
     -ISCfor 150
-------
kttf& ji&f &
OPTION
UNCONTSOLLED BASUJNH
DESCRIPTION EMISSIONS EMISSIONS
OPOKTION (MftV) (Mft^r)
& ^
AGGREGATED PROCESS VENTS WITH PR£SSURE TESTING AND WITHOUT MODE!. IT ANT
1 LJAJ.fl.12 SfifccttstroJo/iiprpted 187 .OH WJ7I
fgaeem verm llui we
DO* cicmpt per flA.4 ,8,12
2 IIU.4.8.12 90* control of •sprtiird 1 87.0*4 69,372
proueu vrni* dul *JT
ixdcietDpt per HB.-4.8.I2
) DC4.8.12 93% control of Hpvp*d 187,0*4 64.371
fTUueu vcnU dm we
DO! ciempt per IIC.4.8,1 2
INDIVIDUAL PROCESS VENTS WTT1I PRESSURE TESTING AND WTTHOUT MODEL Pl^NT 4
4 LA/4,8,12 98% ccrwol of mdividu&l 1B7.0*4 69,57}
pT -:o
^RO> ptOCCU VCQU (hll Ire
"^-^^^ o« curapt per IC.4.8,12
AOX3RECATED PROCESS VENTS WTTII PRESSURE TESTING AND MODEL PI ANT 4
7 IU.4.B.I2 90*eoom>lol.gpT|iicd 221.236 1111.794
pjaueu vcnli lh« ur
DOlcuinplpcrIB.4.8,12
PRESSURE TESTING ALONE WITII MODEL PLANT 4
t PT2 Ojidon of intuiting •
1.419 7.4W
HUl /\
>. _ NA^HONWIDE - NATIOfWfDE - . — — - AVBRACC
EAIISSION EMISSION NATIONAL COST COST PHK% ))62.911.207 S8.B92 8*
I29.4M 19,1)9 6«4 S7* 194.911.746 52.41) U'l
l)l.7a 40,1)0 7(r4 58* IJ41.798.449 J8.525 B-l
:ilj<)6 D.7I9 VM 81* 1IM.JI9.J4) 1I.8IU ml.
6S86 6886 971 92* 112.997.042 11.887 N/A
* Ntiicviwkk tmiuioo reduclion i*iuin bucluv. Cdi«tto P, «u cftlculiled ium| ilic folio* mj f.
  P-^D-t2,3lO)*(E/C)farRow« 1-7        ^
  rtua fcrmul* doea i»4 kllow the reiklud «miMK»u from ptumuoeuliul f<
' lo be iSjrthef rtduced by i|iplying tic RACT option to iheK cmtuioru.
 * Mokl |^4nt 4 re|>r««cni4 painl «mJ vvnuli nunuficiunn
     ys-   (6'/s.^td) * fc/4)
-------
CO ^
CO 45
LU T3
2 C
  cd
IL
II,
O
                 MASS FLUX = 10000 Ibs/yr
                    LOW VOLATILITY (Toluene), CCE = 98%
                                     A-
ou~
Ofi-
oU
20-
15-
1O-
I U
5_

. 	 j 	 . 	 ^ — _ 	 _^ 	 j 	
CIA& rVff$)A4>M &t£^ /?<%££. Ij 1
ct V0(
-------
  American Petroleum Institute
  1220 L Street, Northwest
  Washington, D.C. 20005
  202-682-8145
  James K. Walters
  Director, Measurement Coordination
                                              November 18, 1991
                                              RE: 300
Mr. Bruce C. Jordan
Director, Emission Standards Division
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711

Dear Mr. Jordan:

Attached please find the comments of the American Petroleum Institute (API) on the draft EPA
Control Technique Guideline, "Control of Volatile Organic Compound Emissions from Volatile
Organic Liquid Storage in Floating and Fixed Roof Tanks", as requested in your letter dated
October 4,  1991.

API requests that these comments be included as part of the official record of the EPA National
Air Pollution Control Techniques Advisory Committee meeting being held on November 19-21,
1991.

If you have  any questions on these comments, please contact me.

                                              Very  truly yours,
Attachment

cc:  CELM Members
    D. Wolter, D. Arrick
    Internal Mailing List
                                      T 9 O0>
                                      JL i~> u (^
   An equal opportunity employer
-------
            COMMENTS OF THE AMERICAN PETROLEUM INSTITUTE
                                      ON
        THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                   DRAFT CONTROL TECHNIQUE GUIDELINE

       'CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS FROM
                   VOLATILE ORGANIC LIQUID STORAGE IN
                     FLOATING AND FIXED ROOF TANKS"

                              NOVEMBER 18, 1991
INTRODUCTION

      The American Petroleum Institute (API) is pleased to comment on the EPA's draft
Control Technique Guideline, "Control of Volatile Organic Compound Emissions from Volatile
Organic Liquid Storage in Floating and Fixed Roof Tanks" (herein referred to as the "CTG").
API represents over 250 companies involved in all aspects of the oil and gas industry, including
exploration, production, transportation, refining and marketing.

      The EPA is to be commended on its preparation of the draft CTG. The document is very
comprehensive and many of the issues mentioned herein are complex.  In order to thoroughly
address API's comments, API requests that a meeting with EPA be arranged, as provided for
in EPA's October 4, 1991 letter.

      Also, API requests that the EPA strongly consider delaying the publication of the CTG
until the results of EPA's " 114" letter on tankage distributed to eight companies during the third
quarter of 1991 and  the API fittings loss  tests are available. These results could indicate that
revisions are  needed to the draft CTG.  If EPA must publish the CTG prior to receiving the
results, then EPA should be prepared to discuss (at the meeting mentioned above) ways to
incorporate the results into the CTG.

      The API comments below are divided into General Comments and Specific Comments
(identified by section and page number).

GENERAL COMMENTS

1.    API is pleased that the draft CTG has incorporated many of API's previous comments
      and refers  to and makes use of data, analysis and standards developed by API.  API
      would like to point out that the new API Publication 2518, "Evaporative Loss from
      Fixed-Roof Tanks" is now available and a copy is included for EPA use.  This new
      document should be considered by  EPA during the revisions of both the CTG and AP-42
      for calculations dealing with fixed roof tanks.

                                        1
-------
2.     Most of the November 1983 API comments on the current CTG have been incorporated
       into the 1991 draft CTG except the omission of self-supporting fixed roofs.  The CTG
       should recognize the retrofit of an external floating roof tank with a self-supporting fixed
       roof as an equipment option.  This point is discussed throughout the comments.

3.     API recommends that, in light of the secondary waste generation, emissions,  safety and
       cost impacts, it is important to maintain the flexibility to perform seal upgrades at the
       next scheduled tank maintenance period.

4.     The effective dates for a few of the references to  Subpart K are incorrect. The correct
       effective dates are shown in the appropriate Specific Comments sections.

5.     The draft CTG  does not  mention the  exemption for tanks at drilling or production
       facilities which are  used prior to  custody transfer.  Also,  there is no mention of the
       inspection requirements for the roof seals,  gaskets and membranes in all regulated
       internal and external floating roof  tanks.

6.     The hierarchies suggested in  Section 4.0, Control  Techniques, are overly simplified.
       There is apparently an assumption  that the fittings scenario does not change appreciably
       across the country.  In actual practice, fittings options vary significantly and differences
       in fittings scenarios could change the order  of hierarchy.   Notable examples are the
       presence  or absence of support columns for  an internal floating roof tank and slotted
       gauge poles for an external floating roof tank. API Publications 2517 and 2519 discuss
       typical fittings scenarios.  Further information on this is shown in Section 4.0 of the
       Specific Comments.

7.     In Section 6.0, the CTG should mention the  time frame of the cost estimates and how
       an adjustment for inflation (1991 dollars) is to be  handled. Also, the cost effectiveness
       data  is   shown  as   being   calculated  in  dollars/megagram  but   it   is really
       dollars/megagram/year annualized over ten years.  This is  misleading and  should be
       clarified.

8.     In Section 6.2,  pg  6-2, API suggests  the CTG be corrected to  show  the following
       referenced cost data. The retrofit  cost from CTG Reference 2 lists the price difference
       for internal  floating roof seals, liquid mounted vs. vapor mounted as $20 to $40 per
       linear foot as opposed to $20  as stated in the CTG from Reference 1.

       The data from Reference 2 indicates the retrofit cost of controlling internal floating roof
       fittings is greater than $10,000 per tank, not  the $600 stated in the CTG.

       The installed cost of secondary seals is between $49 per foot and $90 per foot according
       to Reference 2, as  opposed  to the $14 per foot stated.  Some operating  plant data
       indicates  that $90 per foot cost is more representative.
-------
9.
The retrofit cost to control the guide-pole fitting on an external floating roof tank is
$2604 to $3324 according to Reference 2, not $680 as in the CTG.

Considering discrepancies in the input data, some of which are mentioned above,  API
suggests that the cost effectiveness analysis shown in Section 6.0 be evaluated more
closely. API will be addressing this issue in the immediate future and would like to meet
with EPA  to discuss this analysis.  API cannot endorse the draft cost  effectiveness
analysis at  this time.

An API contractor is reviewing  fitting losses with the objective to develop improved
fitting factors.  API invites EPA QA/QC review of the API planned test work.  This
information should be available in  late 1992 and should provide an improved technical
basis for evaluating fitting losses. It is advisable for the EPA to incorporate the resulting
data into the CTG.
SPECIFIC COMMENTS BY SECTION AND PAGE NUMBER
Section 2.2.1, pg 2-1


Section 2.2.3, pg 2-3
Section 2.2.3, pg 2-3
Section 2.2.3, pg 2-4
                    Last  sentence, delete the word  "all" and change  the word
                    "prevent" to "reduce".

                    Add the following wording from AP-42 prior to beginning of first
                    full paragraph.  "There are two basic types of internal floating roof
                    tanks, tanks  in which the fixed  roof is  supported by vertical
                    columns  within the tank, and  tanks with a self-supporting fixed
                    roof and  no internal support columns.  Fixed roof tanks that have
                    been retrofitted to employ a floating deck are typically of the first
                    type, while external  floating  roof tanks typically have  a self-
                    supporting roof when converted to an  internal floating roof tank.
                    Tanks initially constructed with both a fixed roof and a floating
                    deck may be of either type."

                    Third  full paragraph, aluminum  sandwich panel  contact-type
                    internal floating roofs do not share the design feature of having a
                    mechanical seam consisting of overlapping aluminum sheets bolted
                    together with clamping bars. Evaporation loss  tests made by one
                    tank vendor on a mechanical seal  consisting of a gasket cast in
                    place between two mating extrusions  show a much lower seam
                    loss.

                    Last paragraph, it is not common practice to use pressure/vacuum
                    vents and flame arresters to ventilate an internal floating roof tank.
                    In fact, there is the potential to generate explosive atmospheres
                    within the tank and may violate safety standards.
-------
Section 2.3.1, pg 2-5


Section 2.3.1.1, pg 2-6
Section 2.3.1.5, pg 2-7
Section 2.3.2.3, pg 2-9
Section 2.3.2.3, pg 2-9
Section 2.4.1.5, pg 2-11
Section 2.4.1.6, pg 2-12
First paragraph, wiper-type seals are also used on external floating
roof tanks. Add to the description and to Figure 2-7.

The length of the mechanical shoe seal should not be specified
because there are many good quality mechanical shoe seals already
installed in compliance  with regulations that did not previously
specify  shoe length.

The height of the  mechanical shoe is not specified in various EPA
standards, such as  40 CFR Part 60,  Subpart Y,  Para. 61.271
(a)(l)(iii) and 40 CFR Part 60, Subpart  Kb, Para.  60.1126
(a)(l)(ii)(C).  It would  not be reasonable  to require retrofits on
tanks that had working mechanical shoe seals already in place.

The basis for the mechanical shoe seal emissions is probably a test
conducted some years ago by CBI in California using a 30-inch
plus shoe.   Shoes of lesser length could  not provide the same
emission but could still qualify as  a mechanical seal.   API
Publication 2519  equates a  mechanical  shoe seal to a liquid-
mounted seal but with  no  limits to shoe length.   Later  in  the
document, pg 7-6, para. 7.5, shoe height is mentioned.

This implies  that  a weather shield may be used over a secondary
seal.  A more common  practice is to combine the  functions of a
secondary seal and a weather shield.

Current EPA regulations (Subpart Kb) require the use of a single,
liquid-mounted seal or  a  vapor-mounted primary seal plus a
secondary seal. The description in this paragraph and Figures 2-
10 and 2-11 do not reflect this requirement.

The last sentence  states  "Secondary seals are not commonly used
on internal floating roof tanks." This is incorrect  for tanks now
covered by NSPS Kb.

The primary purpose of  an internal floating roof vent or "Vacuum
Breaker" is to vent incoming or outgoing air  or vapor through the
internal floating roof tank when filling or emptying. The poppet-
type described and illustrated is strictly mechanical.  Other types
operating on  pressure/vacuum or liquid level are also used.

Fifth sentence stating: "Open drainage systems can be used only
on  double-deck  floating roofs"  is  incorrect.   Open  drainage
systems are  optional on  open center deck roofs and are  not
-------
Section 2.4.2.1, pg 2-13


Figure 2-7, pg 2-21

Figure 2-11, pg 2-25

Section 2.5, pg 2-32


Section 3.1/3.2, pg 3-1


Section 3.2.1, pg 3-1
Section 3.2.1, pg 3-2


Section 3.2.1, pg 3-2

Table 3-1, pg 3-3
Section 3.2.2, pg 3-4
uncommon. This is also incorrectly presented in API Publication
2517 on pages 41  and 42.  Page 41 states that only double-deck
roofs  have overflow  roof  drains and  page 42  states that some
proprietary designs  are available.   These two statements are
contradictory.

First sentence, the reference to Figure 2-3 is incorrect.  The
correct reference is to Figure 2-1.

The word "Shield" is misspelled in  figures a, c and d.

The word "immersed" is misspelled.

The reference 1 for API Publication 2518 should be changed to
reflect the recent publication date of October 1991.

These are a recapitulation of AP 42, para. 4.3 and API 2519 and
seem unnecessary.

Add a  sentence after the  last complete  sentence  on this page
stating:  "Alternatively, breathing losses from fixed roof tanks may
be calculated using the methods described in API Publication 2518,
revised  October 1991."

Equation  (3-2) should be changed to agree  with the revised
equation in the new API 2518.

In description  of "P", change  "atmospheric" to "absolute".

The paint factor condition for medium  gray on the shell and roof
is listed as 1.40 for  good  paint  and  1.58 for poor paint.  API
Publication 2518,  First Edition, lists 1.46 for good paint.  This
typographical  error should  be  corrected.

API does not have a method for estimating evaporative losses from
horizontal tanks and cannot endorse the EPA method in the CTG.
However, based on the comments below and using  the suggested
changes, the EPA method may constitute a rough or screening
mechanism.

The user is referred to emissions equations for  fixed-roof tanks.
An equivalent diameter, De, is calculated on the length, L, of the
tank and  the  real (vertical)  diameter, D, of the tank.  The
equivalent  diameter is  then used in the  AP-42 fixed-roof tank
-------
                           equations. This calculation method shown is overly simplistic and
                           tends to over-estimate the emissions. This method would be better
                           described as a screening method for estimating emissions.

                           There are two factors that contribute to the over-estimation. The
                           first is that the user is instructed to calculate the average vapor
                           space by multiplying the exposed area of the liquid half-full, using
                           the equivalent diameter, by one-half of the real diameter (for the
                           height  value).  This value will always be greater than the real
                           (default) average vapor space volume, which is one-half of the
                           tank volume.

                           The second is that the exposed area of the stored liquid varies with
                           the liquid height and is at its maximum when the tank is half-full.
                           When the liquid level rises or falls, the exposed area decreases.
                           Therefore, the effective diameter value decreases from this mid-
                           point maximum.  This would have no effect on the vapor space
                           volume calculations but could reduce  the saturation levels of the
                           vapor space,  particularly when lower vapor pressure liquids are
                           stored.  Lower vapor pressure liquids are often stored in horizontal
                           cylindrical tanks.

Section 3.2.3.1.2, pg 3-8   Fourth sentence, change "1 to 15 mi/hr"  to "2 to 15 mi/hr."
Table 3-3, pg 3-9
Table 3-3, pg 3-9
The Kf,  factor for weighted  mechanical actuation, ungasketed
vacuum breaker should be "1.1".

The subscript "c"  states emergency roof drains are not used on
pontoon floating roof tanks.   This is not correct and  should be
deleted.
Table 3-5, pg 3-11
Table 3-5, the number of pontoon legs for the 250 foot diameter
tank should be "35".
Section 3.2.3.1.4, pg 3-14  This section should contain a paragraph explaining the effect of
                           tank color on the vapor pressure.  API Publication 2517, Section
                           2.2.2.3 and Table 10 describe this.
Section 3.2.4, pg 3-15
Section 3.2.4.2, pg 3-21
Add the following sentence to  the  bottom of the  paragraph:
"Vapors  are also  expelled by  the expansion of the air in the
enclosed space due to diurnal temperature changes (breathing)."

The rim  loss factors for tight fitting seals are not provided.  See
API Publication 2519, page 8,  Table 3.
                                           6

                                         122B
-------
Section 3.2.4.2, pg 3-21
Add the reference to "shoe"  seal as stated in the NSPS.
discussion of the NSPS in Section 3.3.5 of this CTG.
See
Section 3.2.4.3, pg 3-24
Section 3.2.4.4, pg 3-29



Section 3.3, pg 3-29

Section 3.3.1, pg  3-29
Section 3.3.4, pg 3-31
Section 3.3.5, pg 3-32
Thus change descriptions to: "Liquid-mounted or shoe primary seal
only" and "Liquid-mounted or shoe primary seal plus secondary
seal".

In description of NF1, add  "In the case of an internal floating roof
tank that has been converted from an external floating roof tank by
retrofitting with a self-supporting roof, Tables 3-3, 3-4 and  3-5
should be used  to estimate the number of fittings."

The deck seam loss factor  (Sd) of 0.20,  which is given as a default
value,  should also be listed as the factor for a deck constructed
with continuous metal sheets with a 5 foot spacing between seams.

This is an excellent summary of  the regulations.

Subpart K became effective June 11, 1973 for tanks greater than
65,000 gallons  that were  constructed, reconstructed or modified
after that  date.   The date of March, 1974 is effective for tanks
between 40,000 and 65,000 gallons.

No mention  is  made of the  exemption for tanks at drilling or
production facilities which are used prior to custody transfer.

Subpart Ka NSPS, the effective date is implied to be April, 1980.
The  subpart  actually   is  effective  for  tanks  constructed,
reconstructed or modified  after May, 1978.

There is no mention of the exemption for production tanks used
prior  to custody transfer, which are less than 420,000 gallons.
Also, there is no mention of the inspection requirements for  the
seals on external floating roof tanks.

Volatile Organic Liquid NSPS,  there is  no mention that this is
actually Subpart Kb.  The effective date is implied to be April
1987.  The subpart actually is  effective for tanks constructed,
reconstructed or modified  after July 1984.

There is no mention of the exemption for production tanks used
prior  to custody transfer, which are less than 420,000 gallons.
Also, there is no mention of the exemption for tanks at gasoline
bulk plants and service  stations,  or tanks used for the storage of
-------
Section 3.3.5, pg 3-32


Section 3.3.5, pg 3-32
Section 3.3.6, pg 3-33
Section 3.4.1.1, pg 3-34


Section 4.0, pg 4-1
Table 4-1, pg 4-2
beverage alcohol. Also, there is no mention of the requirement for
periodic inspection of roof seals,  gaskets, and membranes in all
regulated  internal floating roof tanks and external  floating roof
tanks.

Some  reference  should  be made to support 40 CFR  Part 60,
Subpart Kb as it is often referred to as  such.

Last paragraph,  add as second sentence:  "Shoe seals  are also
typical to internal floating roof tanks which have been converted
from external  floating roof tanks  by retrofitting  with a  self-
supporting fixed roof."

Reference to the baseline control method as being a low cost, non-
contact internal floating roof tank is incorrect.  Depending on the
diameter, a non-contact internal floating roof tank may cost more.
Also, the use of a single vapor-mounted seal is not permitted.

When  referring to RVP and then "vapor pressure", TVP should be
used.

Differences  in  fittings  scenarios  could  change  the order of
hierarchy.  A spreadsheet is attached as Exhibit A which further
illustrates the concern mentioned above.  The CTG  indicates that
the contribution to  the total loss due to fittings is +/- 28%.  The
spreadsheet shows that "typical" fittings on a 50 foot diameter tank
with a mechanical shoe primary seal are, in fact, 28% of the total.
The fittings contribution increases to 72%, however, if the tank
has a slotted guide-pole.  The respective contributions due to each
source category vary too widely to be assigned a representative
percentage.

A hierarchy of equipment cannot be readily achieved  when all
source categories are included in  the same list because different
combinations would result in  different  rankings.    A separate
hierarchy for each source category however,  could be readily
developed.  Such an approach  would also lend itself to including
all  floating  roof tanks,  rather than having  separate  lists for
internal and external floating roof tanks.

This table lists Control  Options 1 through 6.  The reference in
Section 5.2, pg  5-1 is  to Control  Options I through  V.  The
inconsistency in these tables is confusing.
-------
Table4-l,pg4-2


Table 4-1, pg 4-2



Table 4-2, pg 4-3

Table 4-2, pg 4-3
Section 4.3, pg 4-5


Table 4-3, pg 4-7

Table 4-4, pg 4-8

Section 4.3.3, pg 4-9
Section 4.4, pg 4-9
Section 4.4, pg 4-9
Table 4-5, pg 4-11
Under Control Options 5 and 6, add "or shoe" after the words
"liquid-mounted".

Add superscript "b" after superscript "a" in the title after "RATE".
Add another footnote:  "bSelf-supporting fixed roofs would result
in lower emission rates for each control option."

Footnote "a" is missing.

Add superscript "b" after superscript "a" in the title after "RATE".
Add another footnote:  "bConversion to an internal floating roof
tank by retrofitting  with a self-supporting fixed roof would result
in lower emission rates for each control option."  The reason is
primarily because it blocks the wind, but the "shading" effect may
provide  additional  benefit by resulting  in  a  lower  surface
temperature of the stored product.

Third paragraph, are  the  fittings assumed to  be controlled  or
uncontrolled?

In footnote, third sentence, change "split"  to "slit".

Add "or shoe"  after "Liquid-mounted" in two places.

The second paragraph  does not address bolted  construction with
gasketed seams as a potential emission reduction or control.  The
statement that  the deck seam losses are not a factor of the type of
seam is incorrect.

The first paragraph in  this section should  be deleted.   There are
too many options to consider,  i.e. tank size, fittings, seal details,
etc. to make such a generic statement.

First sentence, add  "typical" before the words "internal floating".
Also, add a sentence to the end of the paragraph:  "An internal
floating roof tank with welded deck seams and no support columns
would emit less VOC  per unit of storage  area than do external
floating roof tanks due to the elimination of wind influence."

Deck fitting type 3 (or any equipment description) does not address
slotted gauge pole/sample wells. This should be added.
                                           9

                                       ' o o
-------
Section 4.4.3, pg 4-12
Table 4-6, pg 4-13

Table 4-6, pg 4-13
Table 4-6, pg 4-13


Section 4.5, pg 4-14
Section 4.5, pg 4-14
Section 4.5.1, pg 4-14.
Add a last sentence: "Retrofitting an external floating roof tank
with a self-supporting  fixed roof would convert  the  tank to an
internal floating roof  tank and eliminate the wind influence,
thereby reducing the rim seal losses. "
Title of second column should be
Add as sixth description:  "Metallic shoe primary seal only with
self-supporting  fixed roof retrofitted to tank0."   Add "3.0^" and
"99%" in second and third columns respectively.

Add as last description:  "Liquid-mounted or shoe primary  seal
with rim-mounted secondary seal with self-supporting fixed roof
retrofitted to tank6." Add "1.6d" and "99%" in the second and
third columns respectively.

Add footnotes  as follows: '""Retrofitting with a self-supporting
fixed roof converts the tank to  an internal  floating  roof tank."
"dFrom values listed in Section 3.2.4.1."

Sixth description as  written, change "steel"  to "seal".  Also, in
footnote a, the word "listed" is shown twice.

Delete the first sentence on this  page.  It is uncommon to put a
redundant blower in the vapor collection system.  Blowers/ electric
motors do not fail often enough to justify a full spare.  In case of
a failure, the tank vents through  the pressure/ vacuum vents while
the blower is repaired.   Occasionally, there are more than one
blower for capacity reasons,  not  sparing.

The reference to saturators should be deleted.  Saturators are very
unusual. More common are  systems that are designed to run rich
(above upper explosive limit), enriched  with natural gas to 1.2
times upper explosive limit (21 percent),  or inerted with nitrogen
or inert flue gas. Some systems are designed to run lean  (<25
percent of lower explosive limit).  Flame arresters and/or water
seals are almost always used.

The statement  that  applying the technology  to VOL's is not
difficult should be stricken.  The application of carbon adsorption
to petroleum mixtures is a complex problem. The reference given
is for vapor recovery of a pure hydrocarbon, benzene, which is a
simpler problem.   Some  specific issues to be  concerned about
when applying  carbon adsorption (CA):
                                           10
-------
      o     CA capacities to adsorb C1( C2, C3, and C4 molecules are very low. For practical
             purposes, CA is not a good recovery technology for these molecules.  They pass
             through the bed almost immediately.

      o     Hot vapor streams which contain heavier components  saturate the carbon with
             molecules which cannot be removed except by conditions more severe that the
             CA unit is capable of. The carbon usually must be replaced.

      o     The H2S present in some petroleum product vapors reacts on the carbon to form
             solid  elemental sulfur (Clause Reaction), which fouls the carbon bed.   The
             elemental sulfur cannot be regenerated off the bed so H2S containing streams are
             not good candidates for CA.

      o     Water vapor is  also adsorbed by the carbon,  so vapor streams with high humidity
             must  be dried before  the CA unit.  Also, if water vapor is present, the carbon
             must be protected from sub-freezing temperatures or else the carbon particles will
             be damaged by ice crystal formation.

      o     Part of the complexity of applying carbon  adsorption is in sizing the carbon
             column to handle a peak vapor load in short period of time vs. a truck loading
             rack recovery unit that handles small vapor volumes over a long period of  time.
Section 4.5.1, pg 4-14
Section 4.5.2, pg 4-15
Section 4.5.2, pg 4-15
Section 4.5.2, pg 4-15
Section 4.5.3, pg 4-15
Third paragraph, regarding steam regeneration, it would be unique
for a typical gasoline marketing facility to generate steam and have
an associated wastewater treatment system on site.

First  paragraph,  fourth line, delete "the simplest  to operate".
Oxidation units require a significant supplemental supply of fuel to
operate.  Of concern, they generate NOx and CO which may need
to be removed and also may require regular monitoring.

The reference to saturators should be deleted.  Saturators  are very
uncommon. Vapor gathering systems are deliberately designed to
operate at less than 25  percent of  the lower explosive  limit or
above 1.2 times  the upper explosive limit to avoid the possibility
of propagating explosions.

Delete the word "two"  in  the  second  full paragraph,  second
sentence.  Only a single water seal between the combustion device
and the vapor system is common.  Dual seals are a redundance
used at the owner's option.

Refrigerated  condensation   systems  are  also  used  on  vapor
collection systems in addition to vent condensers.
                                          11
-------
Section 4.6.2, pg 4-17
Sections 4.6.2, pg 4-17
  & 4.6.3
Section 4.6.4, pg 4-17
Section 4.6.5, pg 4-17
Section 4.7, pg 4-18



Section 4.8, pg 4-18


Section 5.2.1, pg 5-3
Section 5.4.1, pg 5-7
Additional rim floatation should be added as another consideration
in the modifications.

When retrofitting any internal floating roof tank with liquid
mounted or secondary seals, additional buoyancy and storage loss
must be considered.  This may be especially important with non-
contact internal floating roof tanks.

Practical experience has shown that hot work and/or tank redesign
is almost always required, therefore, the tank must be taken out of
service, cleaned and degassed.

Add a new section "4.6.5 Self-Supporting Fixed Roofs on External
Floating Roof Tanks.  Several design issues are encountered in the
retrofit of a self-supporting fixed roof to an existing open-top tank.
For example, the reactions from the fixed roof produce localized
loading  on the tank.  The self-supporting fixed roofs are typically
made of aluminum, which results  in the potential for differential
movement between the aluminum fixed roof and the steel tank
shell  due to  the difference  in  their  coefficients of thermal
expansion."

Add the wording, "Emissions from liquid stored in a fiberglass
fixed  roof tank could be controlled  by the  use of a fiberglass
internal floating roof tank."

The date for Reference 1, API Publication 2517, should be June
1989.

Third full paragraph, second sentence. Do  not agree that the only
control option is a condenser.  The proper  control method would
be a vapor balance system; delivery to these tanks is typically by
truck.  This control system is described in an EPA report dated
December  1977  (Report 450/2-77-035,  page  14,   reference
alternative #2   vapor balancing of transport truck and the storage
tanks).

The last sentence should be revised to read: "From Figure 5-8, it
is shown that the greatest  emission reduction for a  baseline
external  floating roof tank with  metallic  shoe  primary seal  is
obtained from  the  addition of a  secondary  seal and controlled
fittings.  From Figure 5-9, it  is shown that the greatest emission
reduction for a baseline external floating roof tank with a vapor-
mounted primary seal is obtained  by  the substitution of a liquid-
                                           12
-------
Section 5.4.2.1, pg 5-7
Figure 5-9, pg 5-20

Section 5.5.1, pg 5-21


Section 5.5.2, pg 5-22


Section 6.2, pg 6-4
Section 6.2, pg 6-3


Section 7.2, pg 7-3
Section 7.2, pg 7-3
mounted  primary  for  the  vapor-mounted  primary  seal  in
conjunction with  the addition of secondary  seals and controlled
fittings."  The sentence,  as written, is incorrect as it refers to two
different baseline tanks and does not differentiate between the two.

First paragraph, it mentions that external floating roof tanks are
equipped with a flange on which a secondary seal can be mounted.
However, due to the ages of most external floating roof tanks, this
flange either requires repair or modification in order to mount the
secondary seal.  In some cases hot work may be needed when
installing a secondary seal on an external floating roof tank.  In
these  cases, tanks would have to be cleaned and degassed.

Also,  adding  a secondary seal to an existing external floating roof
tank  with the tank  in service  may violate  safety  company
guidelines and should be left to each company to decide.

Figure 5-9 does not include a definition for the "1m" abbreviation.

Table 5-1, the word "emissions"  in the title of column  3 is
misspelled.

Table 5-2, the title of column 2 should read "Nationwide Emission
Estimates, Mg/yr (tons/yr)".

The value of petroleum  product recovery  credits  is more
appropriately $50 per ton instead of $320 per  ton, based on
wholesale butane prices at $0.10 per pound. The losses from most
petroleum product (and crude oil) storage is primarily butanes and
pentanes that were contained within  the products.   The CTG
should be revised to show $50 per  ton of recovered product.  See
Exhibit  B.

First full paragraph, using 5  10 years as the expected equipment
life may be  more accurate.

Add the following definition for clarity because of the inspection
requirements  in Section 7.5:   "Internal floating  roof tanks are
storage  vessels that have a floating  roof and a freely vented fixed
roof.  The fixed roof is  not necessarily free of openings but does
span the entire open plan area of the vessel."

Fifth  full  paragraph, a  vapor-mounted seal does not have to be
foam-filled.   Delete "foam-filled."
                                          13
-------
Section 7.5, pg 7-4
Section 7.5, pg 7-6
Section 7.5, pg 7-7
Section 7.6, pg 7-8
Reading the information presented in Table 4-2, Table 4-6 and the
general discussion on external floating roof tanks and gap criteria
in Section 7.5, it may be difficult for operators of riveted tanks
with  mechanical shoe  seals  to  meet  the specified  seal gap
requirements  of Section 7.5.

Item (ii) should be revised to state that no appreciable holes, tears
or other openings  in  the shoe,  seal  fabric  or  seal envelope.
Alternatively, the EPA should quantify this requirement as in the
gap criteria stated above.

The requirement  that the owner prepare an "operating plan" for
control devices is redundant and  unnecessary.  The  devices are
subject to capacity verification and emissions testing when they are
installed. Additional documentation is unnecessary.  In addition,
the  units  are  always  designed  and  tested  (per  state  test
requirements) at maximum, worst case loadings.  The documen-
tation for off peak flow rates, compositions, etc. is generally not
available and would cost individual terminal operators thousands
of dollars  each  to have developed.   This  section could  be
simplified  to  require  that   the  owner/operator   must  have
documentation that the system is capable of handling the peak load
that  is expected from his current maximum  operating  rate.
Previous permit applications,  design/ purchase specifications, or
state approved performance testing would be sufficient.

Item 1., states the highest maximum true vapor pressure for the
range of products stored should be used for emission calculation.
This number  would give the maximum emissions for that product
at that particular time but would not be representative of the true
emissions over the  period of a year.   For example, a products
pipeline will  pump  a varying number of vapor pressure products
depending on the season.  Using the maximum  vapor  pressure
over-estimates  the  true emissions  over  this  period.   A  more
accurate method would be to use the weighted  average true vapor
pressure and  corresponding temperature.
                                           14
-------
            MOV 08  '91  16=33 CONSERVflTEK NO CAR  919 933 4210
                                                                                                                     P.2
         i »T r-¥**\rt**l tW  nt*  f*rt*lVl*.«*-t.lT TtfFJ"**   .—I nATTUO ri/".n/~ TfllU//*
         nirnnm.ni  iir  rmnrnrni urrn   Himiihn niiiir  innnn

                  (assume 10 »ph Mind b(Jttd  for £FRT)
  50'  Diaieter
EOUIPrlEHT  DESCRIPTION
  SEAL
FflCTORS
Open top tank, welded  shell   (EFRis)     38.00
  •echanical  shoe  oriwry  seal

Open top, Melded shell     (£FRi5,ss)     2.00
  shoe priaary + secondary seal

Coluw-supported fined roof  (WFRvii)     6.70
  Bolted dock, priwry ual  only

Coluin-aip'M fixed roof  (blfftvi.ss)     £.50
  Bolted deck, pniary + secondary
Self-supporting  fixed roof
  Uelded deck, sow seal only
    3.00
Self-wip'ting  fixed roof        1.60
                          secuiiddr/
 100' Diaieter
EQUIPHENT DESCRIPTION
  SEA.
FACTORS
Open top,  shoe  seal only   (EFRis)       38.00

Colum-supported, bolted  b)     £.30

Open top,  shoe  + secondary(EFR«s,ss)     2,00

Self-supporting) welded   (vIFRis)        3.00

Self-supporting, wlded   (*IFRis,ss>     1.60
 ISO1  Maieter
F-fiUIPHBO DE5CRIPTIDH
  SEAL
FflCTORS
Open top, shoe seal only   (EFftaO       36.00

Column-supported, bolted  (bIFRvi)        &.70

Colmn-supported, bolted  (bIFRvt,ss)     £.50

Open top, shoe + secondary 
-------
           WHAT IS THE PRODUCT CREDIT FOR REDUCED VOC LOSSES ?
There are two ways of looking at the value of lost material:
  The value is the same as the value of the liquid in the tank, or
  The value is that of the lost material sold as a separate product.

The first method is appropriate for single component liquids, or for
end-user commodities.

The second method is better for unfinished materials in production, and
for wholesalers of broad product slates such as oil refiners.

The material that evaporates from petroleum fuel tankage is primarily
lighter components such as butanes, pentanes, and other light hydrocarbons.
VALUE AS FINISHED PRODUCTS
                                 $/GAL     LB/GAL     $/LB
           CRUDE OIL                0.56       7.1        0.08
           GASOLINE                0.65       5.6       0.12

VALUE AS COMPONENT

           BUTANE (normal)          0.47       4.9       0.10
           NATURAL GASOLINE       0.53       5.6       0.09

                    AVERAGE OF BOTH METHODS =     $0.10
All prices per gal shown above were taken from the Plait's Oilgram Price
Report for Tues., 11/12/91; adjusted to price per gallon units.

All figures rounded off.
-------
APPENDIX:  RECORD OF ATTENDANCE
-------
                                RECORD OF ATTENDANCE
         NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE MEETING
                           NOVEMBER 19,  20,  AND  21, 1991
PLEASE   PRINT
          NAME  AND
        AFFILIATION
                 BUSINESS ADDRESS
                (INCLUDE ZIP CODE)
  TELEPHONE
   NUMBER
DATE(S)
ATTENDED
                                       14Z?

   frmoco Oi
           %OO
            M(L
             II//1&2D
                             /Ol
                     A
-------
                                RECORD OF ATTENDANCE
         NATIONAL  AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE MEETING
                            NOVEMBER 19, 20, AND 21,  1991
PLEASE   PRINT
          NAME  AND
        AFFILIATION
 BUSINESS ADDRESS
(INCLUDE ZIP CODE)
TELEPHONE
 NUMBER
DATE(S)
ATTENDED
                                   ?
                                   '/*-*•/
                                                         57 V
                          tf-

                                                                     /HL.
                                       .OB
                                            0 C
                                        JC
-------
                                RECORD OF ATTENDANCE
         NATIONAL AIR POLLUTION CONTROL TECHNIQUES  ADVISORY COMMITTEE MEETING
                            NOVEMBER  19,  20, AND 21, 1991
PLEASE   PRINT
          NAME AND
        AFFILIATION
 BUSINESS ADDRESS
(INCLUDE ZIP CODE)
TELEPHONE
 NUMBER
DATE(S)
ATTENDED
                                                         bo;
                               w
                                                                        I fa ft I
                                                                             i
  AD^yOtf*"*   ~&
                                             <*
-------
                              RECORD OF ATTENDANCE
        NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE MEETING
                          NOVEMBER 19,  20, AND 21,  1991
PLEASE  PRINT
         NAME AND
       AFFILIATION
 BUSINESS ADDRESS
(INCLUDE ZIP CODE)
TELEPHONE
 NUMBER
DATE(S)
ATTENDED
  Jodie,
                                                     733-33^0
                                                                  U-ft

                                                                  It-/ 9
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                                                                   kin
                                - V a
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-------
                                 RECORD  OF ATTENDANCE
         NATIONAL AIR POLLUTION CONTROL  TECHNIQUES ADVISORY COMMITTEE MEETING
                            NOVEMBER 19, 20, AND 21,  1991
PLEASE    PRINT
          NAME AND
        AFFILIATION
                                BUSINESS ADDRESS
                               (INCLUDE ZIP CODE)
TELEPHONE
 NUMBER
DATE(S)
ATTENDED
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                               RECORD OF ATTENDANCE
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  NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE

                        MINUTES OF MEETING

                       NOVEMBER 19-21, 1991
Prepared by:
               Office of the 'Director
               Emission Standards  Division
     I certify that, to the best of my knowledge, the foregoing
minutes and attachments are complete and accurate.
                          Bruce  Cjxtfordan,  Chairperson
                   National Air  Pollution Control Techniques
                               Advisory Committee
                   U.S. Government Printing office
                                        312-014/40042
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