Draft
EIS
Automobile and Light-Duty Truck
Surface Coating Operations-
Background Information for Proposed Standards
Emission Standards and Engineering Division
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
May 1979
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Draft
EIS
Automobile and Light-Duty Truck
Surface Coating Operations -
Background Information for Proposed Standards
Emission Standards and Engineering Division
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
May 1979
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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of trade
names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services Office (MD-35),
U. S. Environmental Protection Agency, Research Triangle
Park, N. C. 27711, or from the National Technical Information
Services, 5285 Port Royal Road, Springfield, Virginia 22161.
PUBLICATION NO. EPA-450/3-77-020a
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Background Information
and Draft
Environmental Impact Statement
for Automobile and Light-Duty Truck Surface
Coating Operations
Type of Action: Administrative
Prepared by:
Don R. Goodwin (Date)
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C. 27711
Approved by:
David G. Hawkins (Date)
Assistant Administrator for Air, Noise and Radiation
Environmental Protection Agency
Washington, D. C. 20460
Draft Statement Submitted to EPA's
Office of Federal Activities for Review on
(Date)
This document may be reviewed at:
Central Docket Section
Room 2903B, Waterside Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Additional copies may be obtained at:
Environmental Protection Agency Library (MD-35)
Research Triangle Park, N. C. 27711
National Technical Information Service
5284 Port Royal Road
Springfield, Virginia 22161
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TABLE OF CONTENTS
Chapter Page
1 SUMMARY 1-1
1.1 Proposed Standards 1-1
1.2 Environmental, Energy and Economic Impacts .... 1-2
1.3 Inflationary Impact 1-8
2 INTRODUCTION
2.1 Authority for the Standards 2-1
2.2 Selection of Categories of Stationary Sources . . . 2-6
2.3 Procedure for Development of Standards of
Performance 2-8
2.4 Consideration of Costs 2-10
2.5 Consideration of Environmental Impacts 2-12
2.6 Impact on Existing Sources 2-13
2.7 Revision of Standards of Performance 2-14
3 THE AUTOMOTIVE AND LIGHT DUTY TRUCK INDUSTRY 3-1
3.1 General Description 3-1
3.1.1 Automotive Industry 3-1
3.1.2 Truck Industry 3-8
3.2 Processes or Facilities and Their Emissions .... 3-12
3.2.1 The Basic Process - Automotive Industry 3-12
3.2.2 The Basic Process - Light-Duty Truck Industry . . . 3-29
4. EMISSION CONTROL TECHNIQUES 4-1
4.1 General 4-1
4.2 The Alternative Emission Control Techniques .... 4-2
4.2.1 Water-Based Coatings 4-2
4.2.2 Electrodeposition 4-4
4.2.3 Water-Based Spray 4-10
4.2.4 Powder Coating 4-12
4.2.5 Higher Solids Coatings 4-15
4.2.6 Carbon Adsorption 4-18
4.2.7 Incineration 4-22
4.3 Emission Reduction Performance
of Control Techniques 4-32
4.3.1 General 4-32
4.3.2 Electrodeposition of Water-Bases 4-34
4.3.3 Water-Based Spray 4-35
4.3.4 Powder Coating-Electrostatic Spray 4-37
4.3.5 Higher Solids Coatings 4-39
4.3.6 Carbon Adsorption 4-41
4.3.7 Incineration 4-43
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TABLE OF CONTENTS (Continued)
Chapter Page
5 MODIFICATIONS AND RECONSTRUCTION 5-1
5.1 Background 5-1
5.2 Potential Modifications 5-2
5.3 Reconstruction 5-5
6 EMISSION CONTROL SYSTEMS 6-1
6.1 General 6-1
6.2 Base Case 6-2
6.3 Regulatory Options 6-2
7 ENVIRONMENTAL IMPACT 7-1
7.1 Air Pollution Impact 7-1
7.1.1 General 7-1
7.1.2 State Regulations and Controlled Emissions .... 7-3
7.1.3 Uncontrolled and Controlled Emissions (Options) . . 7-5
7.1.4 Estimated Hydrocarbon Emission Reduction
in Future Years 7-8
7.2 Water Pollution Impacts 7-10
7.3 Solid Waste Disposal Impact 7-21
7.4 Energy Impact 7-22
7.5 Other Environmental Impacts 7-31
7.6 Other Environmental Concerns 7-31
7.6.1 Irreversible and Inretrieveable Commitment
of Resources 7-31
7.6.2 Environmental Impact of Delayed Standards 7-32
7.6.3 Environmental Impact of No Standards 7-32
8 ECONOMIC IMPACT 8-1
8.1 Industry Economic Profile 8-2
8.1.1 Role of Motor Vehicle Industry
in the U.S. Economy 8-2
8.1.2 Structure of the Industry 8-3
8.1.3 Projected Demand 8-21
8.1.4 Determination of Existing Capacity 8-22
8.1.5 Determination of New Sources 8-27
8.2 Cost Analysis 8-31
8.2.1 Introduction 8-31
8.2.2 Capital Cost of Control Options 8-33
8.2.3 Annualized Cost of Control Options 8-41
8.2.4 Cost-effectiveness of the Control Options 8-58
8.2.5 Control Cost Comparison 8-71
8.2.6 Base Cost of the Facility 8-72
8.3 Other Cost Considerations 8-82
8.4 Potential Economic Impact 8-83
n
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TABLE OF CONTENTS (Continued)
Chapter
Page
8.4.1 Grass Roots New Lines 8-83
8.4.2 Control Costs 8-83
8.4.3 Potential Price Effect 8-88
8.4.4 Sensitivity Analysis 8-90
8.5 Potential Socioeconomic and
Inflationary Impacts 8-91
9 RATIONALE 9-1
9.1 Selection of Source and Pollutants 9-1
9.2 Selection of Affected Facilites 9-3
9.3 Selection of Best System of
Emission Reduction 9-4
9.4 Selection of Format for the
Proposed Standards 9-20
9.5 Selection of Numerical Emission Limits 9-23
9.6 Selection of Monitoring Requirements 9-26
9.7 Performance Test Methods 9-27
9.8 Modifications and Reconstructions 9-27
APPENDIX A A-l
APPENDIX B B-l
APPENDIX E E-l
m
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LIST OF TABLES
Table Page
3-1 Direct Employment in the Production of Automobiles .... 3-2
3-2 Share of Total U.S. Production 3-3
3-3 Automobile Assembly Plant Production Model Year 1977 . . . 3-5
3-4 Automotive Assembly Plants Model Year 1978 3-6
3-5 1975 U.S. Truck and Bus Factory Sales by Body Types
and Gross Vehicle Weight, Pounds 3-9
3-6 Light-Duty Truck Assembly Plant Model Year 1975 3-10
3-7 Light-Duty Truck Assembly Plant Locations
Model Year 1978 3-11
3-8 Estimated Light-Duty Truck Production 3-13
3-9 Base Case Energy Balance for Application of
Solvent-Based Primer to Automobiles 3-19
3-10 Base Case Material Balance for Application of
Solvent-Based Primer to Automobiles 3-20
3-11 Base Case Material Balance for Application of
Solvent-Based Enamel Topcoat to Automobiles 3-21
3-12 Base Case Energy Balance for Application of
Solvent-Based Enamel topcoat to Automobiles 3-23
3-13 Average Emissions for the Automobile
Finishing Process 3-27
3-14 Average Solid Waste Generated for
Automotive Finishing Process 3-28
3-15 Base Case Material Balance for Application
of Solvent-Based Primer to Light-Duty Trucks 3-31
3-16 Base Case Energy Balance for Application
of Solvent-Based Primer to Light-Duty Trucks 3-32
3-17 Base Case Material Balance for Application
of Solvent-Based Enamel Topcoat to Light-Duty Trucks . . . 3-33
3-18 Base Case Material Balance for Application
of Solvent-Based Enamel Topcoat to Light-Duty Trucks . . . 3-34
3-19 Average Emissions for the Light-Duty Truck
Finishing Process 3-36
3-20 Average Soid Waste Generated for Light-Duty Truck
Finishing Process 3-37
4-1 Water-Based Coatings 4-3
4-2 Theoretical Emission Reduction Potential Associated
with Various New Coating Materials for Use as
Automotive Body Coatings 4-36
4-3 Reduction of Organic Solvent Emissions 4-38
6-1 Automobile and Light-Duty Truck Coating Lines
Emission Control Options Evaluated 6-4
7-1 Automobiles Base Case - Emissions Projections 7-11
7-2 Automobiles Option 1 - Emissions Projections 7-12
7-3 Automobiles Option 2 - Emissions Projections 7-13
7-4 Automobiles Option 3 - Emissions Projections 7-14
7-5 Light-Duty Trucks Base Case - Emissions Projections . . . 7-15
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LIST OF TABLES (Continued)
Table
Page
7-6 Light-Duty Trucks Option 1 - Emissions Projections .... 7-16
7-7 Light-Duty Trucks Option 2 - Emissions Projections .... 7-17
7-8 Light-Duty Trucks Option 3 - Emissions Projections .... 7-18
7-9 Energy Balance - Base Case Model
and Process Modification 7-23
7-10 Energy Balance -- Add-On Emission Control Systems .... 7-24
7-11 Energy Balance -- Base Case Model
and Process Modifications 7-25
7-12 Energy Balance -- Add-On Emission Control Systems .... 7-26
7-13 Energy Balance — Base Case Model
and Model Process Modification 7-27
7-14 Energy Balance — Add-On Emission Control Systems .... 7-28
7-15 Energy Balance ~ Base Case Model
and Process Modification 7-29
7-16 Energy Balance -- Add-On Emission Control Systems .... 7-30
8-1 North American Automobile Assembly Locations 8-7
8-2 North American Light-Duty Truck Assembly Locations .... 8-9
8-3 U.S. and Canadian Projected Demand for North American-
Made Passenger Cars 1978-1983 8-23
8-4 Projected U.S. and Canadian Demand for North American-
Made Light-Duty Trucks 1978-1983 8-24
8-5 Estimated Passenger Car Production Capacity
in North America 8-25
8-6 Estimated Light-Duty Truck Production Capacity
in North America 8-26
8-7 Average Solvent-Based Paint Usage for Automobile
and Light-Duty Truck Bodies 8-34
8-8 Coating Equipment Requirements in a Plant Producing
55 Vehicles Per Hour 8-35
8-9 Turn Key Costs of Automobile and Light-Duty Truck
Coating Equipment Costs 8-36
8-10 Incremental Capital Costs of Water-Based System Versus
Conventional Solvent-Based Systems, Guidecoat 8-38
8-11 Technical Parameters Used in Developing Costs of
Incinerators for Control System 8-40
8-12 Delivered Cost of Exhaust Gas Incinerators 8-42
8-13 Capital Costs of Control Option IB-T for Surface
Coating of Automobiles 8-43
8-14 Capital Costs of Control Option IB-C for Surface
Coating of Automobiles 8-44
8-15 Capital Costs of Control Option II-T for Surface
Coating of Automobiles 8-45
8-16 Capital Costs of Control Option II-C for Surface
Coating of Automobiles 8-46
8-17 Capital Costs of Control Option IB-T for Surface
Coating of Light-Duty Trucks 8-47
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LIST OF TABLES (Continued)
Table Page
8-18 Capital Costs of Control Option IB-C for Surface
Coating of Light-Duty Trucks 8-48
8-19 Capital Costs of Control Option II-T for Surface
Coating of Light-Duty Trucks 8-49
8-20 Capital Costs of Control Option II-C for Surface
Coating of Light-Duty Trucks 8-50
8-21 Cost Factors Used in Computing Annualized Costs
for Control Options 8-51
8-22 Comparable Costs of Control Option IA for Surface
Coating of Automobiles 8-56
8-23 Comparable Costs of Control Option IA for Surface
Coating of Light-Duty Trucks 8-57
8-24 Comparable Costs of Control Option IB-T for Surface
Coating of Automobiles 8-59
8-25 Comparable Costs of Control Option IB-C for Surface
Coating of Automobiles 8-60
8-26 Comparable Costs of Control Option II-T for Surface
Coating of Automobiles 8-61
8-27 Comparable Costs of Control Option II-C for Surface
Coating of Automobiles 8-62
8-28 Comparable Costs of Control Option IB-T for Surface
Coating of Light-Duty Trucks 8-63
8-29 Comparable Costs of Control Option IB-C for Surface
Coating of Light-Duty Trucks 8-64
8-30 Comparable Costs of Control Option II-T for Surface
Coating of Light-Duty Trucks . . 8-65
8-31 Comparable Costs of Control Option II-C for Surface
Coating of Light-Duty Trucks 8-66
8-32 Aggregate Lengths of Spray Booths, Flash-Off Tunnels
and Ovens for Paint Shops Handling 55 Vehicle Per Hour . . 8-77
8-33 Base Cost of an Automobile and Light-Duty Truck Paint
Shop That Uses Solvent-Based Enamel 8-79
8-34 Base Cost of an Automobile and Light-Duty Truck Paint
Shop That Uses Solvent-Based Lacquer 8-80
8-35 Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Passenger Car - 6 M) 8-84
8-36 Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Light-Duty Trucks - GM) . . . . 8-85
8-37 Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Light-Duty Trucks - Ford) . . . 8-86
8-38 Absolute and Relative Incremental Control Costs
(4th Quarter 1977 Dollars, Passenger Car - Chrysler) . . . 8-87
8-39 Inflationary Impact Assessment 8-93
9-1 Automobile and Light-Duty Truck Coating Lines -
Emission Control Options Evaluated 9-10
9-2 Incremental Control Costs
Compared to the Cost of Lacquer Plant 9-16
VI
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LIST OF TABLES (Continued)
Table Page
9-3 Incremental Control Costs
(Compared to the Cost of Enamel Plant) 9-17
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LIST OF ILLUSTRATIONS
Figure Page
3-1 Automobile Production Trends 3-7
3-2 Traditional Coating Operations of An Automobile
and Light-Duty Truck Assembly Line 3-15
3-3 Flow Diagram - Application of Solvent-Based Primer
and Topcoat - Automobile and Light-Duty Truck Bodies . . . 3-17
4-1 Typical Electrodeposition System Diagram 5 4-5
4-2 Forced-Draft System Eliminating Solvent Vapors from
Surface Coating Process 4-24
4-3 Coupled Effects of Temperature and Time on Rate of .... 4-27
4-4 Schematic Diagram of Catalytic Afterburner Using
Torch-Type Preheat Burner with Flow of Preheated
Process Vapors Through a Fan to Promote Mixing 4-30
4-5 Effect of Temperature on Oxidation Conversion of Organic
Vapors in a Catalytic Incinerator 4-33
4-6 Emission Reduction Potential (Percent) with Use of
Higher Solids Coatings in Place of 16 Volume Percent
Lacquers (50 Percent Deposition Efficiency) 4-40
4-7 Emission Reduction Potential (Percent) with Use of
Higher Solids Coatings in Place of 28 Volume Percent
Enamels (50 Percent Deposition Efficiency) 4-42
8-1 Available Options for Control of VOC Emissions
Due to the Painting of Automobile and Light-Duty
Trucks 8-32
8-2 Cost Differential - Control Option 1A for Guide
Coat and Topcoat, Water-Based Enamel Versus Solvent-
Based Enamel 8-54
8-3 Cost Differential - Control Option 1A for Guide
Coat and Topcoat, Water-Based Enamel Versus Solvent-
Based Lacquer 8-55
8-4 Cost Effectiveness of Control Options 1A for Guide
Coat and Topcoat, Water-Based Enamel Versus Solvent-
Based Lacquer 8-69
8-5 Cost Effectiveness of Control Options as Applied to
Different Vehicle Types and Different Types of Solvent-
Based Coatings 8-70
8-6 Comparison of Purchase Prices of Catalytic
Incinerators with Primary Heat Recovery 8-73
8-7 Comparison of Purchase Prices of Thermal
Incinerators with Primary Heat Recovery 8-74
8-8 Comparison of Purchase Prices of Thermal
Incinerators with Primary and Secondary Heat
Recovery 8-75
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1. SUMMARY
1.1 PROPOSED STANDARDS
Standards of performance for automobile and light-duty truck surface
coating operations are being proposed under Section 111 of the Clean Air
Act. These proposed standards would limit emissions of volatile organic
compounds (VOC) from new, modified, and reconstructed facilities. Volatile
organic compounds are organic compounds which are precursors to photo-
chemical oxidant formation and which are measured by proposed Reference
Methods 24 and 25.
Numerical emission limits for each "affected facility" have been
selected as follows:
0.3 kilogram of VOC (measured as carbon equivalent) per liter of
applied coating solids from the prime coating operation
0.9 kilogram of VOC (measured as carbon equivalent) per liter of
applied coating solids from the guide coating operation
0.9 kilogram of VOC (measured as carbon equivalent) per liter of
applied coating solids from the topcoating operation
These limits are based on the use of water-based coating materials in the
prime coat, guide coat, and topcoat operations. Usually water-based prime
coat is applied by electrodeposition (EDP). A transfer efficiency of 40
percent is assumed for spray application of these coatings. The emission
limits may also be achieved by using add-on control devices, such as thermal
or catalytic incineration, to reduce VOC from solvent-based coatings.
Reference Method 24, "Determination of Volatile Content (as Carbon) of
Paint, Varnish, Lacquer, or Related Products," is proposed as the method
for analysis of coating materials. This performance test would be required
1-1
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at all affected facilities to determine potential VOC emissions from the
coating material. Determinations of emissions at plants which use add-on
control devices would require use of proposed Reference Method 25, "Total
Gaseous Nonmethane Organic Emissions."
1.2 ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS
The VOC emissions from automobile and light-duty truck coating opera-
tions can be controlled by the use of coatings having a low organic solvent
content, add-on controls, or a combination of the two. Low organic solvent
coatings consist of water-based enamels, high solids enamels, and powder
coatings. Add-on controls consist of such techniques as incineration and
carbon adsorption.
New Coatings
Water-based coating materials are applied either by conventional
spraying or by EDP. In the EDP process the automobile or truck to be
coated is dipped into a bath containing a dilute water solution of the
coating material. When charges of opposite polarity are applied to the dip
tank and vehicle, the coating material deposits on the latter. As the
coating material deposits on the surface, it acts as an insulator between
the bare metal surface and the EDP tank, thus limiting the film thickness
which can be applied by EDP. Consequently, EDP is limited to application
of prime coats, and spraying is used for guide coat and topcoat application
of water-based coatings. Currently, nearly half of domestic automobile
assembly plants use EDP for prime coat application, but only two domestic
plants use water-based coatings for guide coat and topcoat applications.
High solids coatings, which include coatings of 45 to 60 percent
solids, are being developed by a number of companies. While high solids
1-2
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coatings have the potential for use in the automobile industry, there are
problems which must be overcome. These coatings have a high working vis-
cosity which makes them unsuitable for use in many existing application
devices. There are also some problems with the finish produced by high
solids coatings. Since the viscosity of the material is very high, it
often produces an "orange peel," or uneven, surface. High solids coatings
are also limited because metallic finishes cannot be applied.
Powder coatings are a special class of high solids coatings that
consist of solids only. They are applied by electrostatic spray and are
being used on a limited basis for topcoating automobiles, both foreign and
domestic. The use of powder coatings is severely limited, however, because
metallic finishes cannot be applied using powder. As with other high
solids coatings, research is continuing in the use of powder coatings for
the automobile industry.
Add-on Controls
Incineration may be either thermal or catalytic. Thermal incineration
has been used to control emissions from bake ovens in automobile and light-
duty truck assembly plants because of the fairly low volume and high VOC
concentration in the exhaust stream. These units normally achieve a VOC
emissions reduction of over 90 percent. Thermal incinerators have not,
however, been used for control of spray booth VOC emissions. Typically,
the spray booth exhaust stream is a high volume stream (95,000 to 200,000
liters per second) very low in concentration of VOC (about 50 ppm). Thermal
incineration of this exhaust stream would require a large amount of supple-
mental fuel, either oil or natural gas. There are, however, no technical
problems with the use of thermal incineration.
1-3
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Catalytic incineration permits lower incinerator operating temperatures
and, therefore, requires about 50 percent less energy than thermal inciner-
ation. While catalytic incineration is not currently being employed in the
automobile and light-duty truck industry for control of VOC emissions,
there are no major technical problems which would preclude its use on bake
oven exhaust gases. However, catalytic incineration requires the use of
natural gas to preheat the exhaust gases since oil firing tends to foul the
catalyst. With regard to spray booth emission control, the same consider-
ations apply as in the case of thermal incineration (i.e., a high energy
impact and requirement for use of natural gas, whose future availability
for incinerator use is questionable).
Carbon adsorption has been used successfully to control VOC emissions
in a number of small industrial applications. However, the ability of
carbon adsorption to control VOC emissions from spray booths and bake ovens
in automobile and light-duty truck surface coating operations is uncertain.
The high volume/low VOC exhaust streams from spray booths would require
carbon adsorption units much larger than any that have ever been built.
Work is continuing, however, on efforts to apply carbon adsorption to the
automotive industry, and it may become a demonstrated technology in the
future.
Water-based coatings and incineration are two well demonstrated and
feasible techniques for controlling emissions of VOC from automobile and
light-duty truck coating operations. Based upon the use of these two VOC
emission control techniques, two regulatory options were evaluated. The two
options are summarized in the following paragraphs. In both options, the
prime coat is water-based and applied by EDP.
1-4
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Regulatory Option I includes two alternatives which achieve essen-
tially equivalent control of VOC emissions. Alternative A is based on the
use of a water-based prime coat, guide coat, and topcoat. Alternative B is
based on the use of water-based prime coat and a solvent-based guide coat
and topcoat with incineration of the exhaust gas stream from the topcoat
spray booth and bake oven to control emissions.
Regulatory Option II is based on the use of a water-based prime coat
and a solvent-based guide coat and topcoat. In this option, the exhaust
gas streams from both the guide coat and topcoat spray booths and bake
ovens are incinerated to control emissions.
Impacts
The incremental impacts of the proposed standards would be determined
by the final emission limitations adopted by the SIP's. Standards based on
Option I would lead to a reduction in VOC emissions of about 80 percent,
and standards based on Option II would lead to a reduction in emissions of
about 90 percent compared to VOC emissions from an automobile or light-duty
truck assembly plant using solvent-based coatings with no add-on control
devices. Growth projections indicate there will be four new automobile
assembly plants constructed by 1983. Based on this assumption, it is
estimated that by 1983 national emissions of VOC would be reduced by about
4,800 metric tons per year with standards based on Option I, or about 5,400
metric tons per year with standards based on Option II. Thus, both regula-
tory options would result in a significant reduction in emissions of VOC
from automobile and light-duty truck coating operations.
With regard to the water pollution impact, standards based on Option
II would have essentially no impact. Similarly, standards based on Option
I(B) would have no water pollution impact. Standards based on Option I(A),
1-5
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however, would result in a slight increase in the chemical oxygen demand
(COD) of wastewater being generated from automobile and light-duty truck
assembly plants. However, the increase in COD under Option I(A) would be
small relative to current COD levels at plants meeting existing SIP's, and
would not result in a significant increase in the water treatment require-
ments.
The solid waste impact of the proposed standards would be negligible.
The volume of sludge generated from water-based coating operations is
approximately the same as that generated from a solvent-based operations is
operations. The solid waste generated from solvent-based coatings, however,
is very sticky, and equipment clean-up is more time consuming than for
solvent-based coatings. Sludge from either type of system can be disposed
of by conventional landfill procedures without leachate problems.
With regard to the energy impact, standards based on Regulatory
Option I(A) would increase the energy consumption of surface coating opera-
tions at a new automobile or light-duty truck assembly plant by the equivalent
of about 18,000 barrels of fuel oil per year, representing an additional 25
percent over the current annual consumption rate. Option I(B) would cause
an increase of about 150 to 425 percent in energy consumption, equivalent
to 100,000 to 300,000 barrels of the oil per year. Standards based on
Regulatory Option II would result in an increase of 300 to 700 percent in
energy consumption, representing an additional 200,000 to 500,000 barrels
of fuel oil per year. The relatively high energy impact of standards
based on Regulatory Option 1(8) and Regulatory Option II is due to the
large amount of incineration fuel needed, and the ranges reflect the dif-
ference between catalytic and thermal incineration.
1-6
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In determining the economic impacts of the proposed standards, costs
were estimated for applying each control option to the four new assembly
lines which are expected to be built by 1983. Of these four lines, two are
General Motors lines (one passenger car and one light-duty truck), one is a
Ford light-duty truck line, and the other is a Chrysler passenger car line.
In the absence of any air pollution regulations, General Motors plants
would be designed to use solvent-based lacquer coatings in guide coat and
topcoat and Ford, Chrysler, and all other manufacturers, would use solvent-
based enamels in guide coat and topcoat.
Capital costs for the four new facilities planned by 1983 would be
increased by approximately $19 million as a result of the proposed standards.
This incremental capital cost for control represents about 0.2 percent of
the $10 billion planned for capital expenditures during the same time
period. The corresponding annualized costs would be increased by approxi-
mately $9 million in 1983. The price of an automobile or light-duty truck
manufactured at a new plant which complies with the proposed standards of
performance would be increased by much less than one percent.
1.3 INFLATIONARY IMPACT
The projected economic impacts of each alternative control system are
small, and the costs of the new source performance standards should not
preclude future construction of coating lines. Effects on production of
automobiles and light-duty trucks and on employment should be insignificant.
Total investment costs are projected to be approximately $19 million.
The fifth-year annualized costs, including depreciation and interest, are
estimated at approximately $9 million. The maximum anticipated unit price
increase is much less than one percent. Therefore, the Agency feels that
an economic impact analysis is not required.
1-7
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2. INTRODUCTION
Standards of performance are proposed following a detailed investiga-
tion of air pollution control methods available to the affected industry
and the impact of their costs on the industry. This document summarizes
the information obtained from such a study. Its purpose is to explain in
detail the background and basis of the proposed standards and to facilitate
analysis of the proposed standards by interested persons, including those
who may not be familiar with the many technical aspects of the industry.
To obtain additional copies of this document or the Federal Register notice
of proposed standards, write to the EPA library (MD-35), Research Triangle
Park, North Carolina 27711, telephone number (919) 541-2777. Specify
"Surface Coating Operations for Automobile and Light Duty Trucks: Proposed
Standards," EPA-450/3-77-020a.
2.1 AUTHORITY FOR THE STANDARDS
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, here-
after referred to as the Act. Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which ". . . causes or contributes significantly to
air pollution which may reasonably be anticipated to endanger public health
or welfare."
The Act requires that standards of performance for stationary sources
reflect "... the degree of emission limitation achievable through the
application of the best technological system of continuous emission reduc-
tion ... the Administrator determines has been adequately demonstrated."
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In addition, for stationary sources whose emissions result from fossil fuel
combustion, the standard must also include a percentage reduction in emis-
sions. The Act also provides that the cost of achieving the necessary
emission reduction, the nonair quality health and environmental impacts,
and the energy requirements all be taken into account in establishing
standards of performance. The standards apply only to stationary sources,
the construction or modification of which commences after regulations are
proposed by publication in the Federal Register.
The 1977 amendments to the Act altered or added numerous provisions
which apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary sources
which have not already been listed and regulated under standards
of performance. Regulations must be promulgated for these new
categories on the following schedule:
25 percent of the listed categories by August 7, 1980
75 percent of the listed categories by August 7, 1981
100 percent of the listed categories by August 7, 1982
A governor of a state may apply to the Administrator to add a
category which is not on the list or to revise a standard of
performance.
2. EPA is required to review the standards of performance every four
years, and if appropriate, revise them.
3. EPA is authorized to promulgate a design, equipment, work practice,
or operational standard when an emission standard is not feasible.
4. The term "standards of performance" is redefined and a new term
"technological system of continuous emission reduction" is defined.
2-2
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The new definitions clarify that the control system must be
continuous and may include a low-polluting or nonpolluting pro-
cess or operation.
5. The time between the proposal and promulgation of a standard
under Section 111 of the Act is extended to six months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, any
nonair quality health and environmental impact, and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations where
some states may attract industries by relaxing standards relative to other
states. Second, stringent standard enhance the potential for long-term
growth. Third, stringent standards may help achieve long-term cost savings
by avoiding the need for more expensive retrofitting when pollution ceilings
may be reduced in the future. Fourth, certain types of standards for coal
burning sources can adversely affect the coal market by driving up the
price of low-sulfur coal or effectively excluding certain coals from the
reserve base because their untreated pollution potentials are high. Con-
gress does not intend that new source performance standard contribute to
these problems. Fifth, the standard-setting process should create incen-
tives for improved technology.
Promulgation of standards of performance does not prevent state or
local agencies from adopting more stringent emission limitations for the
2-3
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same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under Section
111 or those necessary to attain or maintain the national ambient air
quality standards (NAAQS) under Section 110. Thus, new sources may in some
cases be subject to limitations more stringent than standards of perfor-
mance under Section 111, and prospective owners and operators of new sources
should be aware of this possibility in planning for such facilities.
A similar situation may arise when a major emitting facility is to be
constructed in a geographic area which falls under the prevention of signi-
ficant deterioration of air quality provisions of Part C of the Act. These
provisions require, among other things, that major emitting facilities to
be constructed in such areas are to be subject to best available control
technology. The term "best available control technology" (BACT), as defined
in the Act, means ". . . an emission limitation based on the maximum degree
of reduction of each pollutant subject to regulation under this Act emitted
from or which results from any major emitting facility, which the permitting
authority, on a case-by-case basis, taking into account energy, environ-
mental, and economic impacts and other costs, determines is achievable for
such facility through application of production processes and available
methods, systems, and techniques, including fuel cleaning or treatment or
innovative fuel combustion techniques for control of each such pollutant.
In no event shall application of best available control technology result
in emissions of any pollutants which will exceed the emissions allowed by
any applicable standard established pursuant to Section 111 or 112 of this
Act."
2-4
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Although standards of performance are normally structured in terms of
numerical emission limits where feasible, alternative approaches are some-
times necessary. In some cases, physical measurement of emissions from a
new source may be impractical or exorbitantly expensive. Section lll(h)
provides that the Administrator may promulgate a design or equipment stan-
dard in those cases where it is not feasible to prescribe or enforce a
standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods during
filling, and low concentrations for longer periods during storage, and the
configuration of storage tanks make direct emission measurement impractical.
Therefore, a more practical approach to standards of performance for storage
vessels has been equipment specification.
In addition, Section lll(h) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Administra-
tor must find: (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards require, or an
equivalent reduction at lower economic, energy or environmental cost; (2)
the proposed system has not been adequately demonstrated; (3) the techno-
logy will not cause or contribute to an unreasonable risk to public health,
welfare or safety; (4) the governor of the state where the source is located
consents; and that, (5) the waiver will not prevent the attainment or
maintenance of any ambient standard. A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS. Any such
condition will have the force of a performance standard. Finally, waivers
2-5
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have definite end dates and may be terminated earlier if the conditions are
not met or if the system fails to perform as expected. In such a case, the
source may be given up to three years to meet the standards, with a manda-
tory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Administrator to list categories of
stationary sources which have not been listed before. The Administrator
"... shall include a category of sources in such a list if in his judg-
ment it causes, or contributes significantly to, air pollution which may
reasonably be anticipated to endanger public health or welfare." Proposal
and promulgation of standards of performance are to follow while adhering
to the schedule referred to earlier.
Since passage of the Clean Air Amendments of 1970, considerable atten-
tion has been given to the development of a system for assigning priorities
to various source categories. The approach specifies areas of interest by
considering the broad strategy of the Agency for implementing the Clean Air
Act. Often, these "areas" are actually pollutants which are emitted by
stationary sources. Source categories which emit these pollutants were
then evaluated and ranked by a process involving such factors as: (1) the
level of emission control (if any) already required by state regulations;
(2) estimated levels of control that might be required from standards of
performance for the source category; (3) projections of growth and replace-
ment of existing facilities for the source category; and (4) the estimated
incremental amount of air pollution that could be prevented, in a prese-
lected future year, by standards of performance for the source category.
Sources for which new source performance standards were promulgated, or are
under development during 1977 or earlier, were selected on these criteria.
2-6
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The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all source categories not yet listed by
EPA. These are:
I. The quality of air pollutant emissions which each such category
will emit, or will be designed to emit;
2. The extent to which each such pollutant may reasonably be antici-
pated to endanger public health or welfare; and
3. The mobility and competitive nature of each such category of
sources and the consequent need for nationally applicable new
source standards of performance.
In some cases, it may not be feasible to immediately develop a stan-
dard for a source category with a high priority. Ths might happen when a
program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement. In
the developing of standards, differences in the time required to complete
the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
numerous pollutants must be investigated from a single source category.
Further, even late in the development process, the schedule for completion
of a standard may change. For example, inability to obtain emission data
from well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling. Nevertheless, priority
ranking is, and will continue to be, used to establish the order in which
projects are initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be deter-
2-7
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mined. A source category may have several facilities that cause air pollu-
tion, and emissions fT'om some of these facilities may be insignificant or
very expensive to control. Economic studies of the source category and of
applicable control technology may show that air pollution control is better
served by applying standards to the more severe pollution sources. For
this reason, and because there may be no adequately demonstrated system for
controlling emissions from certain facilities, standards often do not apply
to all facilities at a source. For the same reasons, the standards may not
apply to all air pollutants emitted. Thus, although a source category may
be selected to be covered by a standard of performance, not all pollutants
or facilities within that source category may be covered by the standard.
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must: (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, nonair quality
health and environmental impacts, and energy requirements of such control;
(3) be applicable to existing sources that are modified or reconstructed as
well as new installations; and (4) meet these conditions for all variations
of operating conditions being considered anywhere in the country.
The objective of a program for development of standards is to identify
the best technological system of continuous emission reduction which has
been adequately demonstrated. The legislative history of Section 111 and
various court decisions make clear that the Administrator's judgment of
what is adequately demonstrated is not limited to systems in actual routine
use. The search may include a technical assessment of control systems
which have been adequately demonstrated but for which there is limited
operation experience. In most cases, determination of the ". . . degree of
2-8
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emission reduction achievable ..." is based on results of tests of emis-
sions from well-controlled existing sources. At times, this has required
the investigation and measurement of emissions from control systems found
in other industrialized countries that have developed more effective sys-
tems of control than those available in the United States.
Since the best demonstrated systems of emission reduction may not be
in widespread use, the data base upon which standards are developed may be
somewhat limited. Test data on existing well-controlled sources are obvious
starting points in developing emission limits for new sources. However,
since the control of existing sources generally represents retrofit techno-
logy or was originally designed to meet an existing state or local regula-
tion, new sources may be able to meet more stringent emission standards.
Accordingly, other information must be considered before a judgment can be
made as to the level at which the emission standard should be set.
A process for the development of a standard has evolved which takes
into account the following considerations:
1. Emissions from existing well-controlled sources as measured.
2. Emissions data from such sources which are assessed with considera-
tion of such factors as (a) the representativeness of the tested
source in regard to feedstock, operation, size, age, etc.; (b)
age and maintenance of the control equipment tested; (c) design
• uncertainties of control equipment being considered; and (d) the
degree of uncertainty that new sources will be able to achieve
similar levels of control.
3. Information from pilot and prototype installations, guarantees by
vendors of control equipment, unconstructed but contracted pro-
2-9
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jects, foreign technology, and published literature are also
considered during the standard development process. This is
especially important for sources for which "emerging" technology
appears to be a significant alternative.
4. Where possible, standards are developed which permit the use of
more than one control technique or licensed process.
5. Where possible, standards are developed to encourage or permit
the use of process modifications or new processes rather than
"add-on" systems as methods of air pollution control.
6. In appropriate cases, standard are developed to permit the use of
systems capable of controlling more than one pollutant. As an
example, a scrubber can remove both gaseous and particulate emis-
sions, but an electrostatic precipitator is specific to particu-
late matter.
7. Where appropriate, standards for visible emissions are developed
in conjunction with concentration/mass emission standards. The
opacity standard is established at a level that will require
proper operation and maintenance of the emission control system
installed to meet the concentration/mass standard on a day-to-day
basis. In some cases, however, it is not possible to develop
concentration/mass standards, such as with fugitive sources of
emissions. In these cases, only opacity standards may be developed
to limit emissions.
2.4 CONSIDERATION OF COSTS
Among the requirements of Section 317 of the Act is an economic impact
assessment with respect to any standard of performance established under
2-10
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Section 111 of the Act. The assessment is required to contain an analysis
of:
(1) the costs of compliance with the regulation and standard, including
the extent to which the cost of compliance varies depending on
the effective date of the standard or regulation and the develop-
ment of less expensive or more efficient methods of compliance;
(2) the potential inflationary recessionary effects of the standard
or regulation;
(3) the effects on competition of the standard or regulation with
respect to small business;
(4) the effects of the standard or regulation on consumer cost, and,
(5) the effects of the standard or regulation on energy use.
Section 317 requires that the economic impact assessment be as exten-
sive as practicable, taking into account the time and resources available
to EPA.
The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and by comparison with the control costs
that would be incurred as a result of compliance with typical existing
state control regulations. An incremental approach is taken since both new
and existing plants would be required to comply with state regulations in
the absence of a federal standard of performance. This approach requires a
detailed analysis of the impact Upon the industry resulting from the cost
differential that exists between a standard of performance and the typical
state standard.
The costs for control of air pollutants are not the only costs con-
sidered. Total environmental costs for control of water pollutants as well
as air pollutants are analyzed wherever possible.
2-11
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A thorough study of the profitability and price-setting mechanisms of
the industry is essential to the analysis so that an accurate estimate of
V
potential adverse economic impacts can be made. It is also essential to
know the capital requirements placed on plants in the absence of federal
standards of performance so that the additional capital requirements necessi-
tated by thse standards can be placed in the proper perspective. Finally,
it is necessary to recognize any constraints on capital availability within
an industry, as this factor also influences the ability of new plants to
generate the capital required for installation of additional control equip-
ment needed to meet the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(c) of the National Environmental Policy Act (NEPA) of
1969 requires federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major federal actions
significantly affecting the quality of the human environment. The objec-
tive of NEPA is to build into the decision-making process of federal agen-
cies a careful consideration of all environmental aspects of proposed
actions.
In a number of legal challenges to standards of performance for various
industries, the federal courts of appeals have held that environmental
impact statements need not be prepared by the Agency for proposed actions
under Section 111 of the Clean Air Act. Essentially, the federal courts of
appeals have determined that "... the best system of emission reduction,
. . . require(s) the Administrator to take into account counterproductive
environmental effects of a proposed standard, as well as economic costs to
the industry ..." On this basis, therefore, the courts "... estab-
2-12
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lished a narrow exemption from NEPA for EPA determination under Section
111."
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "no action taken under the Clean Air Act
shall be deemed a major federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969."
The Agency has concluded, however, that the preparation of environmen-
tal impact statements could have beneficial effects on certain regulatory
actions. Consequently, while not legally required to do so by Section
102(2)(c) of NEPA, environmental impact statements will be prepared for
various regulatory actions, including standards of performance developed
under Section 111 of the Act. This voluntary preparation of environmental
impact statements, however, in no way legally subjects the Agency to NEPA
requirements.
To implement this policy, a separate section is included in this
document which is devoted solely to an analysis of the potential environ-
mental impacts associated with the proposed standards. Both adverse and
beneficial impacts in such areas as air and water pollution, increased
solid waste disposal, and increased energy consumption are identified and
discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..." after
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the proposed standards are published. An existing source becomes a new
source if the source is modified or reconstructed. Both modification and
reconstruction are defined in amendments to the general provisions of
Subpart A of 40 CFR Part 60 which were promulgated in the Federal Register
on December 16, 1975 (40 FR 58416). Any physical or operational change to
an existing facility which results in an increase in the emission rate of
any pollutant for which a standard applies is considered a modification.
Reconstruction, on the other hand, means the replacement of components of
an existing facility to the extent that the fixed capital cost exceeds 50
percent of the cost of constructing a comparable entirely new source and
that it be technically and economically feasible to meet the applicable
standard. In such cases, reconstruction is equivalent to new construction.
Promulgation of a standard of performance requires states to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112). If a state does not act, EPA must
establish such standards. General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on Novem-
ber 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the act provides that the Administrator ". . . shall, at
least every four years, review and, if appropriate, revise ..." the
2-14
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standards. Revisions are made to ensure that the standards continue to
reflect the best systems that become available in the future. Such revi-
sions will not be retroactive but will apply to stationary sources con-
structed or modified after the proposal of the revised standards.
2-15
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3. THE AUTOMOTIVE AND LIGHT-DUTY TRUCK INDUSTRY
3.1 GENERAL DESCRIPTION
3.1.1 Automotive Industry
The automotive industry is the largest manufacturing industry in the
United States. Motor vehicle and allied industries account for one-sixth
of the Gross National Product.1 In 1977, the four major automotive manufac-
turing companies—General Motors Corporation, Ford Motor Company, Chrysler
Corporation, and American Motor Corporation—had combined sales of $111
billion. Any significant change in the automotive industry affects the
entire United States economy. According to the U.S. Department of Commerce,
for every 10 workers producing automobiles, trucks, and parts, 15 addi-
tional people are employed in industries that provide the materials and
manufactured components for these industries.* Employment figures for the
automotive industry are given in Table 3.1.
Among the four automotive manufacturers, General Motors accounts for
the largest portion, 57 percent, of the total market. Table 3.2 shows
domestic production by manufacturer.
The automotive assembly plants are located in 19 states and 43 cities,^
as shown in Table 3.3. Over 32 percent of all automobiles produced in the
U.S. are manufactured in Michigan. Table 3.4 summarizes the automobile
*
The terms "automobile," "passenger car," and "car" are used interchangeably
throughout this report.
-------
TABLE 3.1 DIRECT EMPLOYMENT IN THE PRODUCTION
OF AUTOMOBILES
1967 341,000
1971 382,000
1972 412,000
1973 450,000
1974 350,000
1975 380,000
1976 (Est.) 390,000
3-2
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TABLE 3.2 SHARE OF TOTAL U.S. PRODUCTION
Make
American Motors
Chrysler Corp.
Ford Motor Co.
General Motors
Miscellaneous
12-Month Total
New Car Registration
by Company in U.S.
1967 1972
237,785 301,973
1,341,392 1,466,141 1
1,851,440 2,549,296 2
4,139,037 4,635,656 4
787,767 5,326
8,357,421 8,958,392 8
19_77_
181,433
,181,140
,431,126
,985,150
5,316
,784,165
Production Summary:
1974 Total U.S. Production = 7,324,504
1975 Total U.S. Production = 6,716,951
1976 Total U.S. Production = 8,497,893
1977 Total U.S. Production = 8,784,165
Sources: MVMA Motor Vehicle Facts & Figures '77 and '78. Wards
Automotive Yearbook. 1978.
3-3
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assembly plants by manufacturer, location, and make of automobile. On the
average, automobile assembly plants operate approximately 4000 hours per
year at production rates averaging over 45 vehicles per hour for mid-sized
passenger cars.
In 1973, production of automobiles was 9.7 million, a 10 percent
increase over 1972. Production of cars decreased considerably to 7.3
million in 1974 and 6.7 million in 1975. The major factor that brought
about the decline in production was the serious shortage of gasoline and
diesel fuel which developed at the end of 1973. Consequently, the con-
sumers began seeking small economical models, which were not yet available
in the domestic market. Many American assembly plants producing large cars
were converted to production of compact and subcompact models. As a result,
plants had to close down, production fell sharply, and at one time there
were nearly 150,000 auto workers out of work.
In 1976, however, production showed an upward trend, reaching the
level of 8.6 million cars. This increase can be attributed first to the
economic recovery during 1976 which allowed higher automotive sales.
Secondly, a wide range of sizes, such as subcompacts, compacts, inter-
mediate, and full-sized automobiles, were available. Demand for domestic
new cars is expected to be nearly constant over the next four years, with
1980 sales projected at 10,400,000 units, as shown in Figure 3.I.3 All
producers have announced their product mix plans through 1980, and there is
evidence of down-sizing with each car size category.
Sales of imported cars, which reached a peak of 18.4 percent of the
U.S. market in 1975, have held fairly steadily over the last several years
with minor fluctuations. Several foreign car manufacturers plan to produce
3-4
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TABLE 3.3 AUTOMOBILE ASSEMBLY PLANT PRODUCTION
MODEL YEAR 1977
Location
CALIFORNIA
Fremont
Los Angles
San Jose
South Gate
Van Nuys
DELAWARE
Newark
Wilmington
FLORIDA
Sebring
GEORGIA
Atlanta
Doraville
Lakewood
ILLINOIS
Belvidere
Chicago
KANSAS
Fairfax
KENTUCKY
Louisville
MARYLAND
Baltimore
MASSACHUSETTS
Framingham
MICHIGAN
Dearborn
Detroit
Flint
Hamtramack
Kalamazoo
Units
740,492
164,216
128*143
59,744
131,233
257,156
363,202
226,435
136,767
™
595,926
186,130
241,423
168,373
409,062
173,178
235,884
267,110
267,110
101,057
101,057
241,171
241,171
135,776
135,776
2,948,759
131,016
587,342
416,459
379,562
Percent
8.1
1.8
1.4
0.7
1.4
2.8
4.0
2.5
1.5
6.6
2.0
2.7
1.9
4.5
1.9
2.6
2.9
2.9
1.1
1.1
2.7
2.7
1.5
1.5
32.3
1.4
6.4
4.6
4.2
Location
MICHIGAN (Contini
Lansing
Pontiac
Wayne
Willow Run
Wi xom
MINNESOTA
Twin Cities
MISSOURI
Kansas City
Leeds
St. Louis
NEW JERSEY
Linden
Mahwah
Metuchen
NEW YORK
Tarry town
OHIO
Avon Lake
Lorain
Lordstown
Norwood
TEXAS
Arlington
WISCONSIN
Janes vi lie
• Kenosha
U.S. TOTAL
Units
ed)
404,000
326,231
273,150
255,078
175,921
115,464
115,464
1,010,786
93,946
252,119
664,721
596,791
243,455
260,560
92,776
230,894
230,894
660,101
36,136
241,017
162,029
220,919
230,371
230,371
457,581
275,576
182,005
9,104,543
Percent
4.4
3.6
3.0
2.8
1.9
1.3
1.3
11.1
1.0
2.8
7.3
6.6
2.7
2.9
1.0
2.5
2.5
7.3
0.4
2.7
1.8
2.4
2.5
2.5
5.0
.3.0
2.0.
100.0
MVMA Motor Vehicle Facts & Figures '78, p. 15.
3-5
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TABLE 3.4 AUTOMOTIVE ASSEMBLY PLANTS
Model Year 1978
Manufacturer
Location
Make of Automobile
American Motors
Kenosha, Wisconsin
Hornet, Gremlin, Pacer, Matador
Chrysler Corp.
Belvidere, Illinois
Hamtramck, Michigan
Jefferson Av., Detroit
Lynch Rd., Detroit
Newark, Delaware
St. Louis, Missouri
Wyoming, Michigan
Gran Fury, Royal Monaco, Chrysler
Volare, Aspen
Chrysler
Monaco, Fury
Volare, Aspen
Diplomat, LeBaron
Voyager, Sportsman Volare, Aspen
Export
Ford Motor Co.
Atlanta, Georgia
Avon Lake, Ohio
Chicago, Illinois
Dearborn, Michigan
Kansas City, Missouri
Lorain, Ohio
Los Angeles, Calif.
Louisville, Kentucky
Mahwah, New Jersey
Metuchen, New Jersey
St. Louis, Missouri
San Jose, California
Twin Cities, Minnesota
Wayne, Michigan
Wixom, Michigan
LTD II, Cougar/XR7
Club Wagon
Thunder-bird
Mustang II
Maverick, Comet
Cougar, LTD II
LTD, Thunderbird
LTD
Granada, Monarch
Pinto, Bobcat
Mercury
Pinto, Mustang II, Bobcat
LTD
Granada, Monarch, Versailles
Lincoln, Mark V
General Motors
Arlington, Texas
Baltimore, Maryland
Detroit, Michigan
Doraville, Georgia
Fairfax, Kansas
Flint, Michgian
Framingham, Mass.
Fremont, California
Janesvilie, Wisconsin
Lakewood, Georgia
Lansing, Michigan
Leeds, Missouri
Linden, New Jersey
Lordstown, Ohio
Norwood, Ohio
Pontiac, Michigan
St. Louis, Missouri
South Gate, Calif.
Tarrytown, New York
Van Nuys, California
Willow Run, Michigan
Wilmington, Delaware
Chevelle, Monte Carlo. Cutlass
Monte Carlo, Chevelle, Century, LeMans
Cadillac, Eldorado, Seville
Monte Carlo, Cutlass, Chevelle
Pontiac,.01dsmobilie 88, Le Sabre
Buick, Century, Riviera
Century, Cutlass
Monte Carlo, Century, Chevelle
Chevrolet
Grand Prix, LeMans
Oldsmobile, Cutlass, Toronado
Monte Carlo, Nova, Skylark, Chevelle
Cadillac, Oldsmobile, Buick
Sportvan, Sunbird, Monza, Vega, Astre
Camaro, Firebird
Pontiac, LeMans, Grand Prix
Chevrolet, Corvette
Chevrolet, Le Sabre, Oldsmobile 88
Nova, Skylark, Ventura
Camaro, Firebird
Nova, Omega, Ventura, Skylark
Chevette, Acadian
Checker Motors
Kalamazoo, Michigan
Checker
Sebring-Vanguard Sebring, Florida
dtlCar
Volkswagon
New Stanton, Pa.
Rabbit
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Millions of
Automobiles
10.5 ^
10.0
9.5
9.0
8.5
8.0
7.5
7.0
6.5
6.0
1974
I
1975
1976
1977
Years
1978
1979
1980
Figure 3.1 Automobile production trends.
3-7
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cars in the United States. Volkswagen is. already producing cars for sale
in America at its new plant in New Stanton, Pennsylvania.
3.1.2 Truck Industry
The truck industry manufactures a wide range of vehicles designed for
personal and commercial applications. Different models of vehicles are
classified by gross vehicle weight (GVW) and body type, as summarized in
Table 3.5.
Almost 39 percent of the total production is comprised of vehicles
with GVW of under 6,000 pounds, and about 75 percent of the total production
by trucks with less than 8,500 pounds GVW. The term "light-duty truck" as
used in this study indicates all vehicles with ratings of 8,500 pounds or
less GVW. Thirty-five percent of all light-duty trucks are produced in
Michigan. The remaining 65 percent are made in other states.
Table 3.6 shows light-duty truck assembly locations in cities and
states. Table 3.7 summarizes the light-duty truck assembly plants by
manufacturer and location.
As in the automobile industry, the truck industry has been affected by
recession in recent years. After .the record production of 3,007,495 units
in 1973, production slackened in 1974 and 1975. In 1976, however, pro-
duction of trucks reached almost the same level as in 1973 (3,015,000
units). Production in 1977 was 3,433,569 units. The major factors contri-
buting to this growth were the overall economic growth, the new popularity
of light-duty trucks and vans for personal use, and the improved availability
of gasoline.
Assuming that another petroleum embargo does not occur and the improve-
ment in the general economy continues as forecast, the annual growth rate
3-8
-------
TABLE 3.5. 1975 U.S. TRUCK AND BUS FACTORY SALES BY BODY
TYPES AND GROSS VEHICLE WEIGHT,. POUNDS.
OJ
UD
Body Type
Pickup
General Utility
Van
lulti-Stop
Station Wagon (on
truck chassis)
Buses (including
school bus chassis)
Other body types
TOTAL *
6.000
and Less
1.036.438
100.797
185.610
-
6
.
2.855
1.325.706
6,001- 10.001- 14.001-
10,000 14.000 16,000
901 .278
193,836
341,002 , -
36,326. 18,014 1,221
139,897 - i -
...
110,722 2,274
1.723.061 20.288 1.221
16,001- 19,501- 26,001-
19.500 26,000 33,000
.
.
.
697
i - - *
126 29,173 545
7,065 145.083 30,057
7,888 174,256 30,602
Over T t ,
33.000 lolal
1,937.716
294.633
526,612
56,258
139,903
1,429 31,273
155,884 453,940
157,313 3,440,335
Source:
HVMA Motor Vehicle Facts & Figures '78 p. 12
-------
TABLE 3.6.' LIGHT-DUTY TRUCK ASSEMBLY PLANTS
Model Year 1375
Location of Plant
CALIFORNIA
Frejnont
San Josa
GEORGIA
Atlanta
Lakewoo'd
KENTUCKY
Louisville
MARYLAND
Baltimore
MICHIGAN
Detroit
Flint
Warren
Wayna
MISSOURI
Kansas City
St. Louis
NEW JERSEY
Mahwah
OHIO
Avon Lake
Lordstcwn,
Toledo
VIRGINIA
Norfolk
WISCONSIN
Jonesville
TOTAL
Units
130,829
53,000
77;829
61,925
13,228
48,697
153,404
153,404
72,175
72,175
601,456
10,543
250,050
.212,033
128,830
181,377
67,946
113,431
42,925
42,925
357,502
143,895
102,763
110,844
54,777
54,777
62,153
62,153
1,718,523
Percent
8
3
5
4
1
3 -
9
9
4
4
35
1
14
12
8
10
4
6
3
3
20
9
6
3
3
3
4
4
100 .
Sources: Ward's 1976 Automotive Yearbook; Automotive News, 1975 Almanac;
and DeBell & Richardson's estimated breakdown .
3-10
-------
TABLE 3.7. LIGHT-DUTY TRUCK ASSEMBLY PLANT LOCATIONS
Model Year 1978
Manufacturer
Location
Chrysler Corporation
Ford Motor Conpany
General Motors
Jeep
International
Warren, Michigan
St. Louis, Missouri
Atlanta, Georgia
Kansas City, Missouri
Lorain, Ohio
Louisville, Kentucky
Mahwah, New Jersey
Wayne, Michigan
Norfolk, Virginia
San Jose, California
Twin Cities, Minnesota
Baltimore, Maryland
Detroit, Michigan
Flint, Michigan
Fremont, California
Janesville, Wisconsin
Lakewood, Georgia
Lordstown, Ohio
Pontiac, Michigan
St. Louis, Missouri
Toledo, Ohio
Fort Wayne, Indiana
Source: Auto News, 1975 Almanac
3-11
-------
is expected to be four percent per annum to 1980. A modest growth of one
percent per annum is projected for 1980 to 1985.3 However, as with the
automobile industry, the demand for light-duty trucks will be influenced by
monetary policy, fiscal policy, and other economic development.
As in the automotive market, General Motors as a total entity domi-
nated the light-duty truck market with 45 percent of the total production
in 1975. Light-duty truck production by model is shown in Table 3.8.
3.2 PROCESSES OR FACILITIES AND THEIR EMISSIONS
3.2.1 The Basic Process - Automotive Industry
3.2.1.1 General
The finishing process of an automobile body is a multistep operation
carried out on a conveyor system known as the assembly line. Such a line
operates at a speed of 9 to 25 feet per minute and produces 30 to 70 units
per hour. The plant may operate up to three 8-hour shifts per day. Usual-
ly the third shift is used for cleanup and maintenance. Plants usually
stop production for several weeks during the summer season for inventory
and model changeover.
Although finishing processes vary from plant to plant, they have some
common characteristics. Major successive steps of such processes are given
below:
• Solvent wipe*
• Phosphating treatment
• Application of primer coat
• Curing of the primer coat
*
The term "solvent" in this document means organic solvent.
3-12
-------
TABLE 3.8. ESTIMATED LIGHT-DUTY TRUCK PRODUCTION
Make
Chevrolet
Dodge
Ford
General Motors
International
Jeep
TOTAL
1974
724,052
309,810
687,788
138,625
77,411
114, '132
2,051,818
1975
624,061
270,926
493,182
128,954
32,772
106,704
1,656,599
Sources: Auto News; 1975 and 1976 Almanac
issues. DeBell & Richardson esti-
mated breakdown
3-13
-------
• Application of surfacer
• Curing of surfacer
• Application of the topcoat(s)
• Curing of the topcoat(s)
• Paint touch-up operations
A process diagram of these consecutive steps of the automobile finish-
ing process is presented in Figure 3.2. These steps are explained in more
detail in Sections 3.2.1.2 through 3.2.1.4 of this document. Minimal
sanding operations may occur at various points of the operation, depending
on the manufacturer. Application of sealants generally occurs after the
primer application; sealants are usually cured together with the primer in
the primer coat oven.
Touch-up coating operations are conducted at various stages of the
application of the topcoat(s) to yield a uniform appearance of the coated
area. High bake touch-up coating is performed prior to attachment of heat
sensitive materials and is cured in a high temperature oven. Final, or low
bake, repair generally uses a highly catalyzed air-drying coating. Air-
drying coatings are required for the last touch-up, since at this stage
heat-sensitive plastics and rubber automotive parts have been built into
the automobile.
3.2.1.2 Preparation of Metal Prior to Coating
The automobile body is assembled from a number of welded metal sections.
Parts such as hoods and front fenders may or may not be coated. However,
the body and the parts that are coated all pass through the same metal
preparation process.
3-14
-------
Body welded and
solder applied
and ground down
Sealants applied
I
I
Solvent wipe
(Kerosene wipe)
Primer coat
applied (spray
or dip)
7-Stage phosphatlng
Cooling with
water spray
CO
en
Primer coat
(and sealant)
•cured In oven
(Sanding)
Topcoat cured
1n oven
Finished body
Second topcoat and
touchup sprayed
In booth
Paint touchup
cured In low
bake oven or
air dried
Surfacer
sprayed
In booth
Second topcoat
cured In
high bake oven
Final
touchup
Assembly
Figure 3-2. Traditional coating operations of an automobile and light duty truck assembly line.
aSolvent-based primers are applied by spraying in booth; water-based primers are applied in a dip tank.
Solvent-based primers are applied on an oven-dried body; water-based primers are applied on a wet body.
-------
First, surfaces are wiped with solvent to eliminate traces of oil and
grease. Second, a phosphating process prepares surfaces for the primer
application. Since iron and steel rust readily, phosphate treatment is
necessary to prevent such rusting. Phosphating also improves the adhesion
of the coating to the metal. The phosphating process occurs in a multi-
stage washer in the following sequence:
1. Alkaline cleaner wash - 20 to 120 seconds
2. First hot water rinse - 60°C (140°F) - 5 to 30 seconds
3. Second hot water rinse - 60°C (140°F) - 5 to 30 seconds
4. Phosphating with zinc or iron acid phosphate - 15 seconds
5. Water rinse, ambient - 5 to 30 seconds
6. Dilute chromic acid rinse - 5 to 30 seconds
7. Deionized water rinse - 5 to 60 seconds
The parts and bodies pass through a water spray cooling process and, if
solvent-based primer is to be applied, they are then oven dried.
3.2.1.3 Primer Coating
A primer is applied prior to the topcoat to protect the metal surface
from corrosion and to ensure good adhesion of the topcoat. Figure 3.3, a
flow diagram, shows process steps of both solvent-based primer and topcoat
applications. Approximately half of all finishing processes use solvent-
based primers. The rest use water-based primers.
Water-based primer is most often applied in an electrodeposition (EDP)
bath. The composition of the bath is about 10 percent solids, 4 percent
solvent, with the remaining portion being water. The solvents used are
typically organic compounds of higher molecular weight, such as ethylene
glycol monobutyl ether. When EDP is used, a surfacer (also called a primer
3-16
-------
GJ
I
Stack
(Over-Spray
(Solvents)
Co
Th
Co
Th
Finished Body •
Body
at Ing
and
Inner
Primer
spray booth
* Over-Spray loss
(Solids)
Stack
(Evaporation
(Solvents)
Surfacer oven
(If any)
Stack
1 Over-Spray
(Solvents)
atttig
and
Inner
Topcoat/Touch-
up Spray
Booth
* Over-Spray
(Solids)
Stack
* Evaporation
(Solvents)
Low Temper-
ature Cure
Oven
Stack ,
(Evaporation
(Solvent
Emissions)
Flash-off
of
Solvents
Stack
i Evaporation
f (Solvent
I Emissions)
Flash-off
of
Solvents
Stack
(Evaporation
(Solvent
Emissions)
Flash-off
of
Solvents
Stack
(Evaporation
(Solvent
Emissions)
Flash-off
nf
OT
Solvents
Stack
(Evaporation
(Solvents)
Primer
cure oven
Stack
tOver-SprajV
(Solvents) .
Surfacer Spray
Booth (If any)
Stack
i Evaporation
* (Solvents)
Topcoat
Cure Oven
-»~To fir
Stack
. Over-Spray
i (Solvents)
Final
Repair
al assembly
* Stacks may be used for specific single operations or several operations may be combined and
exhausted through a single stack.
Note: The only emission controlled areas of the process are the spray booths and cure ovens.
Figure 3-3. Flow Diagram - Application of solvent-based primer and
topcoat - automobile and light duty truck bodies.
-------
surfacer or guidecoat) is applied between the primer and the topcoat. This
surfacer can be either solvent-based or water-based. EDP and surfacer are
described in more detail in Chapter 4, Emission Control Techniques.
Solvent-based primer is applied by a combination of manual and automa-
tic spraying. Solvent emissions for solvent-based primer application were
derived from information collected from automobile manufacturers. Average
solvent emission was calculated to be 1.51 gallons per vehicle for the
primer application. Assuming that a car production line operates at a
production rate of 55 cars per hour and two (8-hour) shifts per day, 880
cars are produced daily. Approximately 9,300 pounds of solvent (basis:
density of 7 pounds per gallon) are therefore discharged daily from the
primer application process.
Yearly energy requirements for solvent-based primer application on a
car production line are tabulated in Table 3.9. Similarly, a material
balance is shown in Table 3.10, which includes the discharge of emission at
different steps in the process. This is the base case used in Chapters 6
and 7. Discharge of solvents to the atmosphere in the primer application
are estimated as follows: 88 percent loss during application and 12 percent
loss during oven drying of the coating.
3.2.1.4 Solvent-based Topcoat
The solvent-based topcoat is generally applied by a combination of
manual and automatic sprays. Average percent solids content in the paint
is in the range of 24 to 33 volume percent for solvent-based topcoat enamel
type automotive finish, and 12 to 18 percent volume for solvent-based top-
coat lacquer type automotive finish. A material balance for solvent-based
topcoat application is shown in Table 3.11. This is the base case used in
Chapters 6 and 7.
3-18
-------
TABLE 3.9. BASE CASE ENERGY BALANCE FOR
APPLICATION OF SOLVENT-BASED PRIMER
TO AUTOMOBILES
Operation Steps
Application
Cure
Total
106Btu/Yr a
5,177
73,656
78,833
Annual energy consumption calculations were based
on 211,200 cars produced per year, working from the
following: (1) Production rate - 55 cars/hr.
(2) Time - 2 shifts (8 hr/shift)/day; 240 days/
year; 3840 hr/year; or, 55 cars/hr x 3840 hr/yr =
211,200 cars/yr.
3-19
-------
TABLE 3.10. BASE CASE MATERIAL BALANCE FOR
APPLICATION OF SOLVENT-BASED PRIMER
TO AUTOMOBILES
Item
1. Coating applied (24% solids by volume)
Coating (40% solids by volume as bought)
Thinner
2. Material loss in the application
Solid
Solvent discharge
3. Total coating on body
4. Oven evaporation loss
Solvent discharge
5> Net dry solids on body
Liters Per
211,200 Cars a
952,533
635,022
1,587,555
215,368
1,063,144
1,278,512
309,043
143,398
165,645
211,200 cars is the annual production figure based on the
following: (1) Production rate - 55 cars/hr. (2) Time-
2 shifts (8 hr/shift)/day; 240 days/year; 3840 hr/year.
(55 cars/hr x 3840 hr/yr = 211,200 cars/yr.
3-20
-------
TABLE 3.11. BASE CASE MATERIAL BALANCE FOR
APPLICATION OF SOLVENT-BASED ENAMEL TOPCOAT
TO AUTOMOBILES
Item
Liters Per
211,200 Cars
1. Coating applied (25% solids by volume)
Paint (.31% solids by volume as bought)
Thinner
1,881,053
451,451
2,332,504
2. Material loss in the application step
Solid
Solvent discharge
328,327
1.545,718
1,874,045
3. Total coating on body
458,459
4. Oven evaporation loss
Solvent discharge
203,660
5. Net dry solids
254,799
211,200 cars is the annual production fiqure based on the
following: (1) Production rate - 55 cars/hr. (2) Time -
2 shifts (8 hr/shift)/day; 240 days/year; 3840 hr/year.
(55 cars/hr x 3840 hr/yr = 211,200 cars/yr.)
3-21
-------
Because of the time that the body is in the spray booth, 85 to 90
percent of the solvent evaporates in the booth and its flash-off area.4
Solvent emissions vary with each automotive plant, depending mainly on the
number of units produced daily, the surface area of each unit, and the
amount of solvent in the paint. The process steps of solvent-based topcoat
application is shown in Figure 3.3.
The loss of paint from overspray varies between 20 to 60 percent for
solvent-based topcoats. Most automotive companies use waterwall-type spray
booths. The used water from the spray booths goes to sludge tanks where
solids are removed, and the water is recirculated. The sludge tanks are
cleaned yearly.5
Topcoat application is make in one or more steps (as many as three) to
ensured sufficient coating thickness. An oven bake may follow each topcoat
application or the paint may be applied wet. The energy balance for solvent
-based topcoat application is shown in Table 3.12.
Following the application of the topcoat, the painted body goes to the
trim operation area where vehicle assembly is completed. The final step of
the finishing operation is generally the final repair process in which
damaged paint is repared in a spray booth and air-dried or baked in a low
bake oven to protect the heat-sensitive plastic and rubber parts that were
added in the trim operation area.
3.2.1.5 Equipment Characteristics
Automotive finishing process equipment from which VOC emissions emanate
consists of spray booths, dip tanks, and bake ovens. Other equipment
includes specialized conveyors for moving the bodies and parts to be finished
through the process.
3-22
-------
TABLE 3.12. BASE CASE ENERGY BALANCE FOR
APPLICATION OF SOLVENT-BASED ENAMEL TOPCOAT
TO AUTOMOBILES
Operation Steps
Application
Cure
Total
106 Btu/Yr a
13,316
189,422
202,738
Annual energy consumption calculations based on 211,200
cars produced per year, derived as follows: (1) Produc-
tion rate - 55 cars/hr. (2) Time - 2 shifts (8 hr/shi.ft)/
day; 240 days/year. (55 cars/hr x 3840 hr/y5 = 211,200
cars/yr.)
This amount is highly dependent on climate since outside
air must be heated to comfortable temperatures. The amount
of heat required for this can be twice that required for
curing.
3-23
-------
Solvent-based primer and topcoat are applied by a combination of
manual and automatic spraying techniques. Spray booth lengths vary from
100 to 200 feet. Because the bodies and parts are in the spray booth for a
relatively long time, the majority of solvents are emitted in the spraying
area. High air flows through the booths dilute the vapors to such an
extent that exiting concentrations of solvent vapor are very low.
To comply with Office of Safety and Health Administration (OSHA)
regulations, a minimum air velocity within the booth is usually specified.
As a result, organic vapors are in the vicinity of 50 to 150 ppm in the
spray area.* However, even though the solvent concentration is low, the
volume of exhaust is high and the total amount of solvent emitted can
easily exceed the limit of 3000 pounds per day required by many state
regulations. Temperature in the spray booths range from 15°C (60°F) to
35°C (95°F).
Waterwall-type spray booths are the type most used in automobile
production facilities. In a typical booth design, the overspray paint
particles are removed by a curtain of water flowing down the side surfaces
of the booth enclosure. Waterfall systems in several booths are connected
to one or more large sludge tanks. The floating sludge is skimmed off the
surface of the water. The water is then filtered and recirculated to the
booths. Bake ovens for the primer and topcoats usually have four or more
heat zones. Oven temperatures range from 93°C (200°F) to 232°C (450°F),
depending on the type of coating and the zone. A bake oven can safely
Threshold limit for toluene or xylene: 100 parts/million (ppm).
American Conference of Governmental Industrial Hygienists, 1973.
3-24
-------
operate at 25 percent of the lower explosive limit (LEL), and in many
industries such concentrations are maintained. In the automotive industry,
however, concentrations are much lower. One reason is that ovens are very
long with large openings; hence, large amounts of air are pulled into them.
Another reason is that ovens are designed to provide a bake environment
that is not saturated with solvent, as air pressures in the oven tend to
force available solvent vapors into the panel insulation.6 The two major
automobile and light-duty truck manufacturers report solvent concentrations
at five percent of the LEL.7'8 According to another source, solvent concen-
tration in the oven may reach a maximum of about 10 percent of the LEL.9
3.2.1.6 Emission Characteristics
The three types of solvent-based coatings used in the automotive
industry are paints, enamels, and lacquers. Paints represent a small
fraction of the total quantity of the coatings used in automotive coating
operations. Paints are highly pigmented drying oils diluted with a low
solvency power solvent known as thinner. Applied paints dry and cure in
the oven by evaporation of the thinner and by oxidation during which the
drying oil polymerizes to form a resinous film. Enamels are similar to
paints in that they cure by polymerization. Many automotive coatings
contain no drying oils but cure by chemical reaction when exposed to heat.
Applied lacquers are dried by evaporation of the solvent to form the coat-
ing film.
The amount of solvent and thinners used in surface coating composi-
tions varies, depending upon the plant in which they are used. The solvents
used in enamels, lacquers, and varnishes are aromatic hydrocarbons, alcohols,
ketones, ethers, and esters. The thinners used in paints, enamels, and
3-25
-------
varnishes are aliphatic hydrocarbons, mineral spirits, naphtha, and turpen-
tine.
As mentioned previously, solvent emissions occur at the application
and cure steps of the coating operation. Calculation of solvent emissions
from representative plants resulted in the emission factors for the primer
and topcoat operations given in Table 3.13. Assuming that the production
rate of a finishing line is 880 cars per day (55 cars per hour, two 8-hour
shifts per day), 22,800 pounds of solvents (basis: density of 7 pounds per
gallon) are discharged daily from the finishing operation.
Solid waste generated by the automotive finishing process was also
determined based on data collected from the industry. Table 3.14 shows
solid waste factors for the automotive finishing process.
The spray booths' water effluent contains contaminants from overspray
of coatings. This effluent is discharged into sludge tanks, where solids
are removed, and the water is recirculated. The sludge tanks are cleaned
yearly when solvent-based coatings are used and four times per year for
water-based coatings.5
3.2.1.7 Factors Affecting Emissions
Several factors affect emissions discharged by the automotive industry.
Naturally, the greater the quantity of solvent in the coating composition
the greater will be the air emissions. Lacquers having 15 to 17 volume
percent solids are higher in solvents than enamels having 24 to 35 volume
percent solids.
Production affects the amount of discharge of solvent emissions—the
higher the production rate, the greater the emissions. This rate can also
be influenced by the area of the parts being coated.
3-26
-------
TABLE 3.13. AVERAGE EMISSIONS FOR THE
AUTOMOBILE FINISHING PROCESS
Liters Per Car
Coating
Primer -
Solvent-based spray
Topcoat -
Solvent-based spray
TOTAL
Applica-
tion
5.03
7.32
12.35
Cure
0.68
0.96
1.64
Total
5.71
8.28
13.99
3-27
-------
TABLE 3.14. AVERAGE SOLID WASTE GENERATED FOR
AUTOMOTIVE FINISHING PROCESS
Coating
Average Transfer Loss
of Solids in Coatings,
Liters/Vehicles
Primer -
Solvent-based spray
1.02
Topcoat -
Solvent-based spray
TOTAL
1.55
2.57
3-28
-------
Emissions are also influenced by the thickness of the coating and
technique used. There are no transfer problems when electrodeposition is
used; essentially all the paint solids are transferred to the part. There
can be dripping associated with dragout, but this material is normally
recovered in the rinse water and returned to the dip tank. VOC emissions
from EDP are, therefore, very low.
In the case of spray coating, the transfer efficiency varies, depen-
ding on the type of spraying technique used.* Transfer efficiency for
nonelectrostatic spraying ranges from 30 to 60 percent; with electrostatic
spraying the range is from 68 to 87 percent.10
State or intrastate regulations also influence emissions. Many states
have statewide or district regulations for the control of hydrocarbon
emissions from stationary sources.
3.2.2 The Basic Process - Light-Duty Truck Industry
3.2.2.1 General
With little exception, the finishing process of a light-duty truck
body is the same as for an automobile body. The production rate is usually
slower than for automobiles, 35 to 38 units per hour versus 30 to 70 units
per hour for automobiles. The process diagram in Figure 3.2 shows the
consecutive steps of the light-duty truck finishing process. Unless other-
wise noted, it may be assumed that what was stated for automobiles generally
holds true for light-duty trucks.
Transfer efficiency is the percentage of the total coating solids used that is
deposited on the surface of the object being coated.
3-29
-------
3.2.2.2 Primer Coating
Solvent emission data for solvent-based primer were derived from
information collected from light-duty truck manufacturers. The average
solvent emission of plants using solvent-based primer was calculated to be
1.40 gallons per vehicle for the primer application. Assuming that a
light-duty truck production line operates at a production rate of 38 light-
duty trucks per hour and two (8-hour) shifts per day, 608 light-duty trucks
are produced daily. This means that approximately 6,000 pounds of solvent
(basis: density of 7 pounds per gallon) are discharged daily from the
primer application process. A material balance showing the discharge of
emissions at different steps in the solvent-based primer application pro-
cess is presented in Table 3.15. This is the base case used in Chapters 6
and 7. Discharge of solvents to the atmosphere during primer application
occurs as follows: 88 percent loss during application and 12 percent loss
during oven drying of the coating. Energy requirements for the solvent-
based primer application in a light-duty truck production line are tabulated
in Table 3.16.
3.2.2.3 Solvent-based Topcoat
Table 3.17 presents the base case material balance for solvent-based
topcoat application. The base case energy balance is shown in Table 3.18.
The process steps of the solvent-based topcoat operation is given in
Figure 3.3.
Average percent solids content for solvent-based topcoat is 31 volume
percent for light-duty trucks. The amount of overspray ranges from 35 to
60 percent for solvent-based topcoating.
3-30
-------
TABLE 3.15. BASE CASE MATERIAL BALANCE FOR
APPLICATION OF SOLVENT-BASED PRIMER
TO LIGHT-DUTY TRUCKS
Item
Liters Per
145,920 Vehicles
1. Coating applied (30% solids by volume)
Coating (40% solids by volume as
bought)
Thinner
829,555
276.518
1,106,073
2. Material loss in the application step
Solid
Solvent discharge
189,140
681.340
870.480
3. Total coating on body
235,593
4. Oven evaporation loss
Solvent discharge
92,907
5. Net dry solids on body
142,686
145,920 vehicles is the annual production figure based on the
following: (1) Production rate - 38 vehicles/hour. (2) Time
2 shifts (8 hours/shift) per day; 240 days/year; 3840 hours/
year. (38 vehicles/hr x 3840 hr/yr = 145,920 vehicles/yr.)
3-31
-------
TABLE 3.16. BASE CASE ENERGY BALANCE FOR
APPLICATION OF SOLVENT-BASED PRIMER
TO LIGHT-DUTY TRUCKS
Operation Steps
Application
Cure
TOTAL
TO6 Btu/Year a
4,233
37,517
41,750
Annual energy consumption calculations were based on the
figure 145,920 vehicles, as follows: (1) Production rate -
38 vehicles/hour. (2} Time: 2 shifts (8 hours/shift) per
day; 240 days/year; 3840 hours/year. (38 vehicles/hr x
3840 hr/yr » 145,920 vehicles/yr.)
This amount is highly dependent on climate since outside air
must be heated to comfortable temperatures. The amount of
heat required for this can be twice that required for
curing.
3-32
-------
TABLE 3.17. BASE CASE MATERIAL BALANCE FOR
APPLICATION OF SOLVENT-BASED ENAMEL TOPCOAT
TO LIGHT-DUTY TRUCKS
Item
Liters Per
145,920 Vehicles
1. Coating applied (28% solids by volume)
Coating (31% solids by volume
Thinner
1,603,807
171.835
1,775,642
2. Material loss in the application step
Solid
Solvent discharge
281,701
1.127,657
1,409,358
3. Total coating on body
366,284
Oven evaporation loss
Solvent discharge
150,805
5. Net dry solids on body
215,479
145,920 vehicles is the annual production figure based on the
following: (1) Production rate - 38 vehicles/hour. (2) Time-
2 shifts (8 hours/shift)/day; 240 days/year; 3840 hours/year.
C38 vehicles/hr x 3840 hr/yr = 145,920 vehicles/yr.)
3-33
-------
TABLE 3.18. BASE CASE MATERIAL BALANCE FOR
APPLICATION OF SOLVENT-BASED ENAMEL TOPCOAT
TO LIGHT-DUTY TRUCKS
Operation Steps
Application
Cure
TOTAL
TO6 Btu/Year a
10,852
96,322
107,174
a Annual energy consumption calculations were based on the yearly
production figure of 145,920 vehicles, as follows: (1) Produc-
tion rate - 38 vehicles/hour. (2) Time - 2 shifts (8 hours/
shift)/day; 240 days/year; 3840 hours/year. (38 vehicles/hr x
3840 hr/yr = 145,920 vehicles/yr.)
This amount is highly dependent on climate since outside air
must be heated to comfortable temperatures. The amount of
heat required for this can be twice that required for curing.
3-34
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3.2.2.4 Emission Characteristics
The types of solvent-based coatings solvents and thinners used in the
light-duty truck industry are essentially identical to those used for
automobiles and described in paragraph 3.2.1.6, except that lacquers are
seldom used for light-duty trucks.
As mentioned previously, solvent emissions occur at the application
and cure steps of the coating operation. Calculation of solvent emissions
from plants visited resulted in the emission factors for the primer and
topcoat operations given in Table 3.19. Assuming that the production rate
of a finishing line is 608 light-duty trucks per day (38 vehicles per hour,
two 8-hour shifts per day), 15,800 pounds of solvent (basis: density of 7
pounds per gallon) will be discharged daily from the finishing operation.
Solid waste generated by the light-duty truck finishing process was
also determined based on data collected from the industry. Table 3.20
shows solid waste factors for the light-duty truck finishing process.
3-35
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TABLE 3.19. AVERAGE EMISSIONS FOR THE
LIGHT-DUTY TRUCK FINISHING
PROCESS
Liters Per Truck
Coating
Primer -
Solvent-based spray
Topcoat -
Solvent-based spray
TOTAL
Applica-
tion
4.67
7.73
12.40
Cure
0.64
1.03
1.67
Total
5.31
8.76
14.07
3-36
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TABLE 3.20. AVERAGE SOLID WASTE GENERATED FOR
LIGHT-DUTY TRUCK FINISHING
PROCESS
Coating
Average Transfer Loss
of Solids in Coatings,
Liters/Vehicle
Primer -
Solvent-based spray
1.30
Topcoat -
Solvent-based spray
TOTAL
1.93
3.23
3-37
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3.3 REFERENCES
1. Larson, C.J. Transportation and Capital Equipment
Division, U.S. Industrial Outlook 1975. U.S. Depart-
ment of Commerce, p. 133.
2. Ward's 1976 Automotive Yearbook. Ward's, Communica-
tions, Inc. 1976. p 90-91.
3. Wark, D. Automotive Study. DeBell & Richardson, Enfield,
Connecticut. 1977. pp. 24-27.
'4. Air Pollution Engineering Manual. U.S. Department of
Health, Education, and Welfare; Cincinnati, Ohio. 1967
p. 711.
5. Telephone conversation, Tibor Gabris of DeBell & Richard-
son with spokesman of General Motors Assembly Division,
General Motors Corporation, Van Nuys Plant. October 29,
1976.
6. Johnson, W.R. General Motors Corporation, Warren, Michi-
gan. Letter to J.A. McCarthy of EPA. August 13, 1976.
7. Letter of V.H. Sussman, Ford Motor Company, One Park-
lane Blvd., Dearborn, Michigan, to Radian Corporation,
commenting on report "Evaluation of a Carbon Adsorption/
Incineration Control System for Auto Assembly Plants."
March 15, 1976.
8. Comments of General Motors Corporation on EPA "Guide-
lines for Control of Volatile Organic Emissions from
Existing Stationary Sources". W.R. Johnson to J.A.-
McCarthy of EPA. August 13, 1976.
3-38
-------
9. Conversation, J.A. McCarthy of EPA with Fred Porter of
Ford Motor Company, Dearborn, Michigan. September 23,
1976.
10. Waste Disposal from Paint Systems Discussed at Detroit,
Michigan. American Paint & Coating Journal. February 23,
1945. pp. 35-36.
3-39
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4. EMISSION CONTROL TECHNIQUES
4.1 GENERAL
This chapter and Chapter 6 both analyze the available emission
control technology for the automobile and light-duty truck industry. The
purpose of this chapter is to define the emission reduction performance of
specific control techniques, while Chapter 6 evaluates complete emission
control systems that combine finishing processes with one or more emission
reduction techniques.
The purpose of the control techniques as discussed in this chapter
is to minimize emissions of volatile organic compounds to the air. These
compounds - ketones, alcohols, esters, saturated and unsaturated
hydrocarbons, and ethers - make up the major portion of the solvents used
for coatings, thinners, and cleaning materials associated with industrial
finishing processes.
There are several types of control techniques presently in use
within the automobile and light-duty truck industry. These methods can be
broadly categorized as either add-ons or new coating systems. Add-ons are
used to reduce emissions by either recovering or destroying the solvents
before they are emitted into the air. Such techniques include thermal and
catalytic incinerators and carbon adsorbers. New coatings refers to
application methods that use coatings that contain relatively low levels
of solvents. Such methods include electrodeposition or air spray
4-1
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of water-borne coatings and electrostatic spray of water-borne and powder
coatings. Because of the lower solvent content of the new coatings, these
application methods are inherently less polluting than processes that use
conventional solvent-borne coatings.
The following discussion characterizes the control techniques and
defines the emission reduction associated with each technique in the auto
and light-duty truck industry.
4.2 THE ALTERNATIVE EMISSION CONTROL TECHNIQUES
4.2.1 Water-borne Coatings
Water-borne coatings are the most common of the control techniques
in current use in the automobile and light-duty truck industry. Most
water-borne coatings are applied by electrodeposition as primers.
Water-borne spray topcoats and surfacers are used considerably less often
than water-borne primers.
The terminology for water-borne coatings tends to be confusing—the
names of the various coating types are often misused or used
synonymously. The term water-borne, as discussed here, refers to any
coating that uses water primarily as the carrier and is meant to
distinguish such coatings from solvent-borne coatings.
There are three types of water-borne coating materials: latex or
emulsion coatings, partially solubilized dispersions, and water-soluble
coatings. Table 4.1 lists the significant characteristics of these three
types of water-borne coatings. These indicated properties are not meant
to be absolute, since individual coatings vary.
4-2
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TABLE 4.1. WATER-BORNE COATINGS
Properties
Resin particle
size
Molecular
weight
Latex or
Emulsion Coatings
0.1 micron
1 million
Partially
Solubilized
Dispersions
Utlrafine
50,000 - 200,000
Water-Soluble
Coatings
20,000 - 50,000
Viscosity
Viscosity control
Gloss
Chemical Resis-
tance
Exterior durabil-
ity
Impact resistance
Stain resistance
Color retention
on oven bake
Reducer
Washup
Low - not depen-
dent on molecu-
lar weight
Requires thick-
eners
Solids at appli- High
cation
Low
Excellent
Excellent
Excellent
Excellent
Excellent
Water
Difficult
Somewhat dependent
on molecular wt.
Thickened by addi-
tion of cosolvent
Intermediate
Low to medium-
high
Excellent
Excellent
Good
Excellent to good
Water
Moderately
difficult
Very dependent on
on molecular
weight
Governed by mo-
lecular weight
and solvent per-
cent
Low
Low to highest
Good to excellent Fair to good
Very good
Good to excel,
Fair to good
Good to fair
Water or water/
solvent mix
Easy
Source: Industrial Finishing (July 1973) p. 13.
4-3
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4.2.2 Electrodeposition
Only water-borne coatings can be applied by the electrodeposition
(EDP) process. Currently, electrodeposition (also called electrocoating)
is used in more than half of the existing assembly plants for application
of automotive primers to bodies and associated parts, such as fenders and
hoods. Such systems have been described in detail.1»2»3
In applying electrodeposition coatings, the parts are immersed in a
bath of low-solid water-borne coating solution; the tank or grids on the
periphery of the tank are negatively charged while the parts are grounded;
and negatively charged polymer is attracted to the metal item and is
deposited as a highly uniform coating.** The process is analogous to
electroplating. Systems of the opposite polarity can also be used.
Cathodic EDP, in which the part is negatively charged, is a new
technology which is expanding rapidly in the automotive industry. In-
creased corrosion resistance and lower cure temperatures are two of
the main reasons for this change from anodic to cathodic systems.
Cathodic systems are also capable of applying better coverage on deep
recesses of parts. Since cathodic EDP has these advantages, and in-
dustry is presently converting to cathodic, it will be used as the
base EDP system in this document. Figure 4.1 shows a typical closed-
loop EDP process.
The solubilized resins used in automobile and light-duty truck
primers are generally based on malenized oils or malenized polyester.
These resins are combined with pigments, such as carbon black and iron
oxide, and are dissolved in water/solvent ratios ranging from 98/2 to
90/10 percent. The solvents used are typically higher molecular weight
4-4
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t
en
Colonized Water
Elcctrocleposition
Dip Tank
Coating Supply
Ultrafiltration
Coating Return
Ultraflltrnte
Holding Tank
r-tJ
Drain
Figure 4.1. Typical Electrodepos1t1on System Diagram 5.
-------
organic compounds, such as ethylene glycol monobutyl ether (butyl
cellosolve™).6
After electrodeposition, the coatings are baked and the amine,
solvent, and water evaporate to leave a cured film that closely resembles
a solvent-borne finish.^
In a typical EDP operation, bodies or parts are loaded on a
conveyor that carries them first through a pretreatment section. The
treated and washed bodies or parts are automatically lowered into the EDP
tank containing the water-borne coating, a 6 to 12 percent dispersion of a
389
collodial polymer. ' ' The body or part becomes the cathode of the
electrical system while the tank or grids mounted in the tank-become the
anode. To avoid has marking the coating, direct current electrical
power is not applied until the part is totally submerged. Current flow
through the bath causes the coating particles to be attracted to the metal
surface, where they deposit as a uniform film. The polymer film that
builds up tends to insulate the part and prevent futher deposition. Dwell
time in the tank is typically 1-1/2 to 2 minutes.3'8'10'11
The current is then shut off, and the parts are raised out of the
bath, allowed to drain, rinsed to remove dragout, and then baked. Solids
from the dragout are collected in the rinse water and are usually returned
to the EDP tank. This recovery can result in coating savings from 17 to
30 percent.12'13 Excess water is removed from the coating bath using an
ultrafilter.
The conveyors, pretreatment section, and bake oven used for EDP are
conventional items; the critical components of the system include the
following:14'15
4-6
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Dip Tank. The dip tank is a large rectangular container
generally with a capacity of 121,120 to 321,725 liters (32,000
to 85,000 gallons), depending on part size.*6 Larger tanks
are used for priming bodies, while the smaller units are used
for coating associated parts, such as fenders and hoods. The
tanks are coated internally with a dielectric material, such as
epoxy, and are electrically grounded for safety.^'^
Shielded anodes are submerged and usually run along both sides of the
tank.
Power Supply. Direct current electrical power is supplied by a
rectifier with a capacity of approximately 250 to 500 volts and
300 to 2,500 amperes, depending on the number of square feet
per minute to be finished.
Heat Exchangers. Coating drawn from the dip tank is passed
through a heat exchanger to dissipate heat that is developed
during the coating operation. The temperature is normally
maintained at 20 to 24°c + 1°C (68 to 75°F + 2°F).3'9'10
Filters. An in-line filter is also placed in the recirculating
system to remove dirt and polymer agglomerates from the coating.
Pumps. Recirculating pumps are used to keep the coating
solution stirred.
Ultrafiltration Unit. Excess water is removed from the coating
in this unit. The concentrate, the coating, is returned to the
dip tank. A portion of the permeate, the excess water, is used
as rinse water, while the remainder is sewered.
4-7
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• Coating Mixing Tank. Coating mixing tanks are used to premix
and store coating solids for addition to the dip tank as needed.
• Control Panel. The electrodeposition process is generally
controlled from a central control console. This panel contains
all start-stop switches plus instruments for monitoring
voltage, amperage, coating temperature, and pH.
Proper pretreatment can be critical to coating performance -
particularly if the substrate has grease or oil on the surface.
Solvent-borne coatings generally will dislodge an occasional oil spot, but
water-bornes will not.17 Cleaners developed for solvent-borne coating
systems are generally adequate for EDP.
Coating in the dip tank is affected by voltage, current density,
temperature, dwell time, pH, and solids content. ^
By increasing the voltage or the temperature in the bath, the film
thickness can be increased. Excessively high voltage will cause holes in
the films because of gassing, however. Too high a temperature is also
undesirable; some coatings will flocculate at temperatures approaching
90°C. Refrigeration of the bath is necessary to maintain temperatures
below this point.
At high pH, there is a reduction in the deposition; if the pH drops
below the isoelectric point, the total coating in the bath can coagulate.
If the solids content in the coating is too high, the voltage.
cannot wring the moisture from the deposited film; if the bath is too
dilute, then the film will be thin. Film build up is usually about 0.7
mil.
4-8
-------
For successful operation of an EDP system it is necessary to
monitor on a regular basis: voltage, amperage, pH, temperature, and
solids. For satisfactory appearance of the final finish, it is important
to rinse the parts thoroughly after painting; the final rinse should be
with deionized water.
Parts coated by EDP are normally baked from 15 to 30 minutes at 163
to 190°C (300 to 400°F), with the higher temperatures being used for
automobile primers.1,3,15,19,20
Solvent emissions are related to both coating composition and
production rate. The greater the quantity of solvent in the water-borne
coating, the greater the air emissions. Solvents used in water-borne
coatings are high molecular weight organic compounds, added to aid in
fusing the coating particles into a continuous film.
Production in terms of square meters per hour has an influence on
emissions: the higher the rate, the greater the emissions. This rate
depends on the area of the parts, their spacing on the conveyor, and the
conveyor speed.
Emissions also are influenced by coating thickness: thicker
coatings will carry a greater amount of solvent. The thickness depends on
the voltage and amperage applied across the electrodes. Normally there
are no transfer efficiency problems with electrodeposition; nearly all the
coating solids are transferred to the part. There can be dripping
associated with dragout, but this material is recovered in the rinse water
and returned to the dip tank.
The emission reduction capacity of EDP is related to the solvent
content of the coating and the percent solids of the coating as the part
emerges from the bath, both of which influence the weight of solvent
4-9
-------
associated with applying a given weight of dry coating solids. Similarly,
the percent emission reduction is related to the emission level of the
solvent-borne primer being replaced, which varies with the percent solvent
in the coating and the transfer efficiency.
EDP is not used alone, however, for most automobile and light-duty
truck primers. Most employ a primer surfacer, also called surfacer or
guidecoat, to build film thickness and permit sanding between the primer
and topcoat. These primer surfacers are applied by spraying and can be
either solvent or water-borne. Because of the solvent content, they can
have a significant effect on the overall solvent emissions for primer
operations (see Chapter 6 - Emmission Control Systems).
4.2.3 Water-borne Spray
Since the application of water-bornes by EDP is limited to one-coat
priming, auto manufacturers have chosen spray coating for applying
water-borne surfacers and topcoats.21,22,23 TwQ Qenera] Motors plants
pi pp
are in production with water-borne surfacer and topcoats, A»" and there
is one Ford Motor Company experimental line in Canada.23 General
Motors' automobile plant currently under construction in Oklahoma City,
Oklahoma and light-duty truck plant being planned for Shreveport,
Louisiana will both use water-borne surfacer and topcoats.
The topcoat materials used are thermosetting acrylics with 23 to 25
volume percent solids,4'24'23'25 and water/solvent ratios of 82/18 to
88/12, respectively, in the volatile portion of the coating. These
compositions correspond to solvent to solids ratios in the range of 0.36
to 0.60 by volume.
4-10
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The general finishing processes for both General Motors plants
using water-borne surfacer and topcoats are similar. »22 The finishing
process at the General Motors South Gate, California plant has been
described in detail;25 the steps are as follows:
1. A conventional cleaning and phosphating with no dry-off.
2. An electrodeposition primer application followed by baking.
3. Application of sealers.
4. Coating with an epoxy ester-based water-borne spray primer
surfacer (guidecoat) using automatic and manual air spray.
5. Flash-off for 5 to 8 minutes in a 77 to 93°C (170 to 200°F)
tunnel.
6. A partial bake.
7. Application of interior coating plus additional sealant. The
coating used here is a water-borne acrylic enamel.
8. Final baking of the primer.
9. Wet-sanding and masking of the interior.
10. Application of a water-borne acrylic enamel topcoat in two
separate booths with a flash-off and set-up bake after each
application.
11. Coating of the trunk with a water-borne emulsion coating.
12. Touch-up and accent color application in a third booth.
13. A final bake at 163°C (325°F) for 30 minutes.
In addition to automobile topcoats, water-borne coatings are also
being used to finish components, such as wheels and engines.26'27'2**
As with any coating, emissions of volatile organics from
water-borne topcoats into the air is dependent on the percent solids and
4-11
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solvent in the coating and the thickness of the coating that is applied.
In addition, emissions are'influenced by the number of units produced per
hour and the surface area of each unit.
One critical factor in any spray operation, a factor that can have
serious effect not only on emissions but on cost and secondary pollutants,
is transfer efficiency - that percentage of the coating that actually
deposits on the part. With conventional spray transfer efficiencies are
usually in the range of 30 to 60 percent. Electrostatic spray increases
29
transfer efficiences to 70 to 90 percent.
4.2.4 Powder Coating
Powder coating, although considered here as a new coating method,
has been in use since the 1950's.31 Fluidized-bed coating began in the
early 1950's, and electrostatic spray was introduced in the early 1960's.
Powder coating, regardless of process, involves the application of 100
percent solid materials in dry powder form; no solvents are used, although
traces of organics can be driven off from the resins during curing.
Powder coating materials are available as both thermoplastic and
thermosets, but the thermosets are the only materials of interest here for
thin, high-performance finishes for automobiles and light-duty trucks.
Powder coating is being used throughout the industrial finishing
industry for such diverse painting applications as metal furniture, wire
goods (baskets, racks, and shelves), piping, and tubing, fencing and
posts,32 garden tractors and lawn equipment,33 and bicycles.
In the automotive industry in the United States, powder coating has
been used on two pilot lines for applying topcoats - one at a General
Motors Corporation automobile assembly plant in Framingham,
4-12
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Massachusetts,35 and one at a Ford Motor Company automobile assembly
plant in Metuchen, New Jersey.36 Powder coatings are also being applied
to under-the-hood parts, such as oil filters and air cleaners3''™ as
well as bumpers, trailer hitches, and emergency brake cable
guides.39'40'41
In Japan, Honda is reported to be topcoating cars with powder at
the rate of 55 units per hour, while Nissan Motor Company began applying
powder topcoats to trucks sometime during 1977.42 Nissan is
constructing a new plant at Kanda, North Kyushu, where the powder topcoats
will be applied to light-duty trucks at the rate of 2,100 per month.
Trucks will be finished in one of eight colors; all applied from a single
spray booth.43
At the present time the most significant use of powder for
automobile finishing is a large pilot line being used by the Ford Motor
Company at Metuchen, New Jersey, for applying topcoats. This line has
been successfully finishing Pintos in solid colors since 1973.° The
powder coating operation has been placed adjacent the main assembly line.
Prior to the powder finish, cars are pretreated and primed in an identical
manner to cars receiving conventional finishes. Cars to be powder coated
are moved from the main assembly line and are painted by electrostatic
spray in one of two booths. The bulk of the coating is applied with
automatic powder guns. Inaccessible areas are hand sprayed. For good
flowout, a 6.3 to 7.6 x 10"2 millimeter (2.5 to 3.0 mil) coating is
applied, which is equivalent to approximately 2.9 kilograms (6.5 pounds)
•3C
of coating per car.
4-13
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To fuse and cure the coating, the cars are baked at 177° c
(350°F) for 30 minutes. Following finishing and baking, the cars are
moved back into the main assembly line.
The cars are finished in one of eight solid colors. Overspray is
approximately 35 percent,36 most of which is recovered.
Ford has not successfully demonstrated the application of powder
metallic coatings. In applying solvent-borne coating, the viscosity is
low enough for the metallic flakes to turn and orient parallel to the
surface as the coating dries. With powder, however, the molten polymer is
viscous and the flake keeps a random orientation, making the appearance
less aesthetically pleasing. This is of great importance, since metallic
coated vehicles account for over 50 percent of sales.
On a typical automobile or light-duty truck assembly line, the
color of the topcoat to be applied is determined by individual orders,
which come completely at random. This requires a color change after each
vehicle. The time allowed for the change is dictated by the line speed,
which permits approximately 13 seconds between vehicles.
Color changes are normally difficult and time-consuming, requiring
removal of essentially all powder from the booth, lines, and guns.44
Color contamination cannot be tolerated or the finished coating will
contain particles of dissimilar color, giving a salt-and-pepper look.
Through modification of their equipment, Ford has been able to
achieve the desired 13-second color change. Metallic powder coatings are
not, however, currently available and this fact precludes their
consideration as a control option.
4-14
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4.2.5 Higher Solids Coatings
Higher solids coatings hold the potential of being able to apply
the same weight of paint solids with reduced emissions of volatile
organics. Such coatings fall in the general categories of radiation
curable systems, higher solids nonaqueous dispersion coatings, high-solids
coatings, and powder coatings. Powder coatings have already been
discussed (paragraph 4.2.4). Radiation-cured coating involves the
photocuring of mixtures of low molecular weight polymers or oligomers
dissolved in low molecular weight acrylic monomers. These formulations
contain no solvent carriers and can be cured using either electron beam or
ultra-violet light sources to essentially 100-percent solids
coatings.45,46,47 These coatings have generated little interest in the
auto industry, presumably because of the health hazard associated with the
spray application of these relatively toxic monomer mixtures and the
difficulties involved in obtaining adequate cure of the paint when applied
to irregularly shaped substrates.
Medium-solids nonaqueous dispersion (NAD) coatings are being used
in the auto industry. Nonaqueous dispersion coating vehicles are polymer
dispersions of particles in the size range of 0.01 to 30 microns in
diluents that are nonsolvents or, at least, very poor solvents. The
diluents are liquids other than water and are usually limited to the more
common hydrocarbons, i.e., alcohols, esters, etc. At nonvolatile contents
potentially as high as 40 to 60 volume percent, NAD products form easily
pourable liquids of relatively low viscosity; the viscosity being
essentially independent of the molecular weight of the polymer. °
4-15
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During the early 1970's, NAD coatings began to generate interest as
spray topcoats for automobiles, both domestic and foreign. As a result,
several companies are now using NAD coatings of less than 50 percent solids
on automobile and truck assembly lines for the application of both lacquer
49 50
and enamel topcoats. '
At the present time in the industry, topcoats are being applied
either from lacquers - both nonaqueous dispersion and solution - or from
nonaqueous dispersion enamels. A small percentage of the autos produced
are still being finished with solution enamel paints.
Most of the autos produced at General Motors, representing about
half of the domestic production, are finished with lacquers. These
lacquers range from approximately 12 to 18 volume percent solids applied,
depending on whether the lacquer is a nonaqueous dispersion or a solution.
Most of the vehicles manufactured by Ford, Chrysler, and American
Motors are being topcoated with NAD enamels. General Motors uses these
coatings for their trucks. These enamels vary in their degreee of
dispersion; in fact, some come very close to being solutions. Solid color
NAD enamels, which are relatively low in dispersion, are supplied at a
solids content generally in the range of 39 to 42 volume percent.
Metallic NAD enamels tend to be higher in dispersion than the solid colors
and are normally supplied at 33 to 37 volume percent solids:49'50 these
enamels are then diluted with solvent for application.
NAD enamels used in the industry have essentially the same solvent
contents as their solution enamel counterparts. Although higher solids
contents are technically feasible, these have not been realized because of
application and appearance problems. The present NAD enamels, therefore,
are inherently no less polluting than solution enamels.
4-16
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Most of the impetus behind the switch to NAD coatings was due to
the ability of the dispersion coating to build sufficient film rapidly
without the sagging and solvent popping usually associated with solution
enamels and lacquers. Use of NAD lacquer also allowed spray application
at almost double the usual solids for solution lacquers, thereby cutting
the number of coats required by 40 to 50 percent. These improved
application performances made it possible to increase line speeds by 50 to
60 percent without capital investment in equipment of facilities.
High-solids coatings are a relatively new family of materials that
is currently being developed and investigated in the automotive, can,
coil, and appliance industries. The attraction of such coatings seem
based on a low solvent content, the promise of application with
conventional finishing equipment, and the promise of energy savings
through the use of more reactive systems. Although the traditional
definition of high solids as specified in "Rule 66" indicates no less than
80 volume percent solids,51 most of the people in industry are
considering everything from 60 to 100 percent as high solids.
There will very likely be no radically new resin binders associated
with high-solids coatings; most are modifications of their low-solids
counterparts. The coatings can be categorized as either two-component/
ambient-curing or single-component/heat-converted materials.
The coatings that are of the most immediate interest are the
two-component/ambient-cure materials; they offer not only a reduced
solvent content but also a tremendous energy savings since they require
little, if any, baking. Resin systems being investigated include
epoxy-amine, acrylic-urethane, and urethane.52'53'54'55
4-17
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The heat-converted, high-solids coatings being developed include
epoxy, acylic, polyester, and alkyd.56 Most contain reactive hydroxyls
or carboxyles, which allow cross linking with ami no compounds such as
hexamethoxy methylmelamine. These coatings are baked at temperatures
similar to their low-solids counterparts - nominally 150 to 175°C (300
to 350°F).
The most significant problem with high-solids coatings is the high
working viscosity of the solution (i.e., 60 to 80 volume percent).54
The viscosity can be controlled to some degree by reducing the molecular
weight of the base polymer or by using reactive diluents, but these
techniques can result in a greatly altered product with inferior
properties. A more effective means of reducing viscosity is to heat the
coating during the application. ^
Heated high solids can be applied as airless, air, or
electrostatically sprayed finishes from heated equipment,55 and can be
roll-coated. While it is generally agreed that high-solids coatings hold
a great deal of promise, they are still an emerging technology and must be
considered to be still in their infancy.56 Of the approximately 1514
million liters (400 million gallons) of industrial finishes consumed in
1975, less than 1 percent were high solids.57
Major uses for high-solids coatings are in coil and can
coating.57 High-solids coatings are not used in the automotive industry
at this time.
4.2.6 Carbon Adsorption
Carbon Adsorption as a technique for solvent recovery has been in
use commercially for several decades. Applications include recovery of
solvent from dry cleaning, metal degreasing, printing operations, and
4-18
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rayon manufacture58 - as well as industrial finishing.59'60'61 While
the recovery of coating solvents from industrial finishing operations
using adsorption is not without some technical problems, the process is
essentially no different from any other being used for solvent recovery.
In the automobile and light-duty truck industry, the emissions of
greatest concern come from two general areas: spray booths for
solvent-borne primers, guide coats (primer surfacer, used over EDP
primer), and topcoats, and their respective bake ovens.
Automotive spray booths present unique adsorber design
considerations because of the very high air flow rates that are employed.
Flow rates as high as 94 to 188 cubic meters per second (200,000 to
400,000 cfm) are required for operator safety in manned booths and for
prevention of cross contamination of adjacent car and light-duty truck
bodies from overspray.62'63 According to one report, three adsorbers
6.1 meters (20 feet) in diameter would be sufficient to handle air flows
CO
of this magnitude.oc While no such units are presently in use in the
auto industry, systems of this size have been constructed.64 Lacquers
may require even larger systems.
One consequence of this high air flow is that the solvent vapors
are diluted to a very low level, normally 50 to 200 ppm, which is
equivalent to or less than 2 percent of the lower explosive limit (LEL).
This low concentration lowers the adsorption capacity of the carbon
thereby necessitating a larger adsorber unit to remove the same quantity
of solvent than from a more concentrated air stream with lower air flow.
Reduction in air flow with increased vapor concentration is technically
feasible, however. DuPont conducted a study to reduce air flow and their
results were summarized as follows:65
4-19
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"By maximizing use of automatic painting, reducing booth length,
avoiding longitudinal mixing between manual and automatic painting
zones, and staging of solvent-laden air exhausted from manual zones
through automatic zones, it has been demonstrated on a commercial
automotive production line that only close to 10 percent of the
currently discharged air needs to be treated to meet this 3,000
Ib/day limitation per source."
Adsorption systems for spray booth emissions also must be designed
to handle air with a high water vapor content. This high humidity results
from the use of water curtains on both sides of the spray booths to
capture overspray. Although carbon preferentially adsorbs organics, water
will compete for available sites on the carbon surface. Generally the
relative humidity should be kept below 80 percent to minimize this
problem.66
The exhaust from the spray booths, particularly during periods of
cool ambient temperatures, can reach saturation with moisture.6^ One
solution to this problem would be to preheat the moisture-laden air to
lower the relative humidity to below 80 percent; a 4 to 5°c (7 to 9°F)
heating would be sufficient.68
Prior to adsorption, particulates from oversprayed coating should
be removed from the air streams, since this material coats the carbon
and/or plugs the interstices between carbon particles. Such plugging
reduces adsorption efficiency and increases pressure drop through the
bed. Such particulates can be removed by using either a fabric filter66
or the combination of a centrifugal wet separator plus prefilter and bag
filter.65
4-20
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Another variable that should be considered in designing an adsorber
for this application is the potential variability of the solvent systems
between different grades or types of coatings. Although all automotive
spray coatings contain the same families of solvents (i.e., glycol ethers,
esters, Cg and Cg aliphatics, etc.), the various coatings used can
differ widely with regard to specific compounds and relative proportions.
Solvent systems therefore differ in their adsorptive characteristics and,
as a result, their ability to be removed by the adsorber. On lines where
different coatings are periodically used, adsorbers will probably have to
be overdesigned in adsorptive capacity.
Ovens are the second major source of solvent emissions.
Approximately 10 to 15 percent of the volatiles from solvent-based
coatings are emitted in ovens.67 The remaining 85 to 90 percent
volatilizes in the spray booth and flash-off area.
Individual solvents in a spray booth evaporate at different rates.
The 90 percent of the solvent that is emitted in the spray booth and
flash-off area comprises a large percentage of low boilers, such as
acetone, butanol, toluene, etc. The 10 percent that remains in the film
as it enters the oven contains, primarily, less volatile solvents.
Therefore, adsorbers for ovens will have to be designed to handle a
different solvent mix than is found with spray booths and flash-off
areas. High-boiling solvents may not be consistently and completely
stripped during activated carbon regeneration, thus more frequent
replacement of the carbon would be likely. In any case, hot gas or
superheated steam regeneration would probably be required.69
In the oven, high temperatures and flame contact can cause
polymerization of the volatiles into high molecular weight resinous
4-21
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materials that can deposit on and foul the carbon bed. Various high
molecular weight volatiles in the coatings, such as oligomers, curing
agents, or plasticizers, can cause a similar problem. Filtration and/or
condensation of the oven exhaust air would be necessary prior to
adsorption in order to remove these materials.
In order to get satisfactory performance, it will also be necessary
to cool the oven exhaust to a temperature no greater than 38°C. Without
cooling, many of the more volatile organics will not adsorb but will pass
through the adsorber. ^»^1
Carbon adsorption can't be considered as a viable control option at
this time because design of this auxiliary equipment has not been demon-
strated.
4.2.7 Incineration
4.2.7.1 General
Incineration is the most universally applicable technique for
reducing the emission of volatile organics from industrial processes. In
the industrial finishing industry these volatile organic emissions consist
mostly of solvents made up of carbon, hydrogen, and oxygen. Such solvents
can be burned or oxidized in specially constructed incinerators into
carbon dioxide and water vapor.
Industrial incinerators or afterburners are either noncatalytic
(commonly called thermal or direct fired) or catalytic.7^ There are
sufficient differences between these two control methods to warrant a
separate discussion for each.
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4.2.7.2 Thermal Incinerators
Direct-fired units operate by heating the solvent-laden air to near
its combustion temperature and then bringing it in direct contact with a
flame. A typical unit is shown schematically in Figure 4.2. In general,
high temperature and organic concentration favor combustion; a temperature
of 760°c (1400°F) is generally sufficient for nearly complete
combustion.
To prevent a fire hazard, industrial finishing ovens are seldom
operated with a concentration of solvent vapor in the air greater than 25
percent LEL (Lower Explosive Limit). Ovens in the automobile and
light-duty truck industry achieve concentrations of only 5 to 10 percent
LEL. These low concentrations are the result of high air flows necessary
to prevent escape of oven gas from oven openings and to prevent
condensation of high-boiling organics on the inner surfaces of the
oven.73
Although there is potential for more concentrated air streams from
spray booths (see paragraph 4.2.6), most currently operate at no more than
2 percent of LEL. Because of the low concentrations from both ovens and
spray booths, auxiliary heating is required to burn the vapors. Natural
gas combustion usually provides the heat and direct flame contact in
thermal incinerators, but propane and fuel oil are also used.7^'76
The quantity of heat to be supplied is dependent on the concentration
of the organics in the air stream; the higher the concentration the lower the
auxiliary heat requirement because of the fuel value of the organic.
For most solvents the fuel value is equivalent to 4.45 gram-
kilocalories per cubic meter (0.5 Btu/scf), which translates into a
temperature rise of approximately 15.3°c (27.5°F) for every percentage
4-23
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Cooled
Clean
Gas
Process
Vapors
Gombustor
Fan
Hot Clean
Gas
i
t
Single-Pass
Heat Exchanger
Stack
Preheated Process Vapors
Figure 4-2. Forced-Draft System eliminating solvent vapors
from surface coating process 74.
4-24
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point of LEL that is incinerated. For an air stream with a solvent
content of 25 percent of LEL, the contribution from the heat of combustion
of the solvent would be approximately 115 gram-kilocalories per cubic
meter (13 Btu/scf),77 equivalent to a temperature rise of 345°C
(620°F) at 90-percent combustion efficiency.
If the desired exhaust temperature is 816°C (1500°F), then the
inlet air stream would have to be heated to only 471°C (880°F). On
the other hand, if the process air contains only 10 percent LEL, as is the
case with the exhaust from automobile bake ovens, then the solvent would
contribute only 138°C (280°F) and the air entering the incinerator
would have to be preheated to 679°c (1220°F) in order to attain the
same final temperature, 817°c (1500°F).
To make thermal incineration less expensive, heat transfer devices
are often used to recover some of this heat of combustion. Primary heat
recovery is often in the form of a recuperative heat exchanger, either
tube or plate type, which is used to preheat the incoming process vapors
as illustrated in Figure 4.2.78 Units of this type are capable of
recovering 50 to 70 percent of the heat from the original fuel
input.78'79
A more satisfactory type of heat recovery device and one that finds
wide use in vapor incineration equipment is the regenerative heat
exchanger, both refractory and rotary plate types.78 Units of these
types are capable of heat recoveries of 75 to 90 percent.80,81,82 In
some cases secondary recovery is also used to convert additional exhaust
7ft
heat into process steam or to warm make-up air for the plant.'0
4-25
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There are several operating parameters that affect the emission
reduction potential of thermal incinerators. The following are the most
significant ones:
• For efficient combustion of the hydrocarbons in the air stream,
it is necessary to have sufficient temperature and residence
time in the incinerator. Figure 4.3 shows the combined effect
of these two parameters. Insufficient temperature and/or
residence time results in incomplete combustion and the
generation of carbon monoxide. From the table it can be seen
that for typical residence times of 0.3 to 1 second
temperatures on the order of 700°C (1290°F) are ncessary
for complete combustion to occur.
t If the air stream to the incinerator contains sulfur-,
nitrogen-, or halogen-containing organics there will be a
secondary pollution problem. Incineration of these materials
will produce sulfur and nitrous oxides and acids, such as
hydrochloric and hydrobromic. Fortunately, none of the
solvents used for automotive finishing contain these elements.
t Solvent type also can influence incinerator performance. While
593 to 677°C (1100 to 1250°F) is adequate to combust most
solvent vapors, certain organics require temperatures of 760 to
816°C (1400 to 1500°F) for nearly complete oxidation.72
In the automobile and light-duty truck industry, the two potential
areas for the use of incinerators are on the spray booths and on the ovens
used for applying and baking body primers, surfacers, and topcoats.
The use of incinerators on bake ovens presents no significant
problem. Such add-ons are in place on ovens in several assembly plants,
4-26
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100
0)
u
o
3
20
(316)
(427)
(538)
(649) (760)
Temperature, 9C(°F)
(871)
(983)
(1094)
Figure 4-3. Coupled effects of temperature and time on rate of
-------
particularly in California.83,84,63 Typical emission reduction with
such units is over 90 percent. Since the air existing the ovens is
generally at a temperature of 120 to 1500C (250 to 300°F), the air
preheating requirements are less than they would be for the exhaust air
from spray booths.
Incinerators on bake ovens would control approximately 10 percent
of the solvent emissions. The remaining 90 percent of the volatiles are
emitted in the spray booth.
Although incineration of the air from spray booths is possible,
there has been no application in the automobile and light-duty truck
industry. Because of the large air flow in the spray booths, as much as
94 to 188 cubic meters per second (200,000 to 400,000 cfm), and the
resulting low solvent content of the air, 2 percent LEL or less, large
quantitities of natural gas or equivalent fuel would be required to heat
the vapor-laden air from near ambient to the 700 to 760°C (1300 to
1400op) necessary to effect near complete combustion.
Reduction of the air flow with a resulting increase in vapor
concentration is technically feasible as was discussed previously in
paragraph 4.2.6. However, this has not been technically demonstrated in
the industry.
To handle the volume of air flow, several large incinerators would
probably be required. This could present problems of excessive weight and
lack of available space - particularly in cases where an existing source
is being retrofitted.
There is a potential legal conflict with incineration of spray
booth exhaust air. NFPA No. 33-1973, Section 4.2, (also OSHA regulation
Part 1910.107 FR, which is similar) specifically prohibits open flames in
4-28
-------
any spraying area; and Section 1.2 defines a spraying area as: "(b) The
interior of ducts exhausting from spray processes." However, Section
4.2.1 states: "Equipment to process air exhausted from spray operation-
for removal of contaminants shall be approved by the authority having
jurisdiction." Section 4.2.1 would allow the use of incineration for
spray booth exhaust air so long as the local authority approved.
4.2.7.3 Catalytic Incineration
This add-on control method makes use of a metal catalyst to promote
or speed combustion of volatile organics. Oxidation takes place at the
surface of the catalyst to convert organics into carbon dioxide and
water. No flame is required.72
A schematic of a typical catalytic afterburner is shown in Figure 4.4.
The catalysts, usually noble metals such as platinum and palladium, are
supported in the hot gas stream so that a large surface area is presented
to the waste organics. A variety of designs are available for the
catalyst, but most units use a noble metal electrodeposited on a high-area
support, such as ceramic rods or honeycombed alumina pellets.72,85
As with thermal incinerators, the performance of the catalytic unit
is dependent on the temperature of the gas passing across the catalyst and
the residence time. In addition, the efficiency of the afterburners
varies with the type of organic being oxidized.85 These effects of
temperature and organic type are shown in Figure 4.5. While high
temperatures are desirable for good emission reduction, temperatures in
excess of 593 to 649°C (1100 to 1200°F) can cause serious erosion of
7? RR
the catalyst through vaporization./d»o;>
4-29
-------
Catalyst
Elements
Process Vapors
Preheater
Figure 4-4. Schematic Diagram of Catalytic Afterburner using
torch-type preheat burner with flow of preheated
process vapors through a fan to promote mixing 77.
4-30
-------
The use of a catalyst permits lower operating temperatures than are
used in direct-fired units. Temperatures are normally in the range of 260
to 316°C (500 to 600°F) for the incoming air stream and 399 to 538°C
(750 to 1000°F) for the exhaust. The exit temperature from the catalyst
depends on the inlet temperature, the concentration of organic, and the
percent combustion. The increase in temperature results from the heat of
combustion of the organics being oxidized.
As with thermal incinerators, primary and secondary heat recovery
can be used to minimize auxiliary heating requirements for the inlet air
stream and to reduce the overall energy needs for the plant (see paragraph
4.2.7.2). Although catalysts are not consumed during chemical reaction,
they do tend to deteriorate, causing a gradual loss of effectiveness in
oxidizing the organics. This deterioration is caused by poisoning with
chemicals, such as phosphorous and arsenic, which react with the catalyst;
by coating the catalyst with particulates or condensates; and by high
operating temperatures, which tend to vaporize the noble metal. In most
cases, catalysts are guaranteed for 1 year by the equipment supplier,87
but with proper filtration cleaning and attention to moderate operating
temperatures the catalyst should have a useful life to 2 to 3
Catalytic incinerators have the potential for reducing volatile
on
organic emissions and are used in the automotive industry.03
While catalytic incinerators can probably be adapted to baking
ovens with relatively little difficulty, the use of these add-ons for
controlling spray booth and flash-off area emissions will present
4-31
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the same design considerations that were discussed for thermal
incinerators. These factors include high air flow, low vapor
concentration, and the need to incorporate a highly efficient heat
recovery system in order to minimize the need for auxiliary heating
of inlet air.
4.3 EMISSION REDUCTION PERFORMANCE OF CONTROL TECHNIQUES
4.3.1 General
Emissions can be controlled either through the use of new coatings
or add-on control devices. The emission reduction associated with add-ons
is related to the ability of the technique to either capture or destroy
the solvent emissions.
The emission reduction potential for new coatings, however, is
related to the quantity of volatile organic material in the coating before
application and cure. The relative emissions of any coating can be
expressed quantitatively in terms of the amount of solvent or other
volatile organic compound emitted per unit of dry coating resin applied to
the substrate. This can be derived from the weight percent solids of the
coating materials as the ratio of solvent to solids. Thus relative
solvent emissions are not only dependent on the solids content of the
coating but rise exponentially as the solids content is lowered.^
An improvement on this method, used here, considers also the
transfer efficiency. The Relative Solvent Emissions (RSE) of any coating
application method is also related to the transfer efficiency; i.e., the
percentage of the paint used that actually deposits on the substrate. For
spray application, transfer efficiencies of 30 to 60 percent are normal
4-32
-------
100
80
-------
when using air spray, while electrostatic spray will permit depositions of
60 to 90 percent. The RSE then can be expressed as:
RSE = ((% Solvent)(100))/((X Solids)(%Transfer Efficiency))
In the paragraphs that follow, the following techniques are
discussed: electrodeposition of water-borne coatings, water-borne spray
coating, powder coating, higher solids coatings, carbon adsorption, and
incineration. Powder coating and carbon adsorption are included for
information only since they are not considered as currently viable control
options. Powder coating has not been demonstrated for metallic coatings,
and the technology of carbon adsorption for use in this industry has not
been demonstrated.
4.3.2 Electrodeposition of Water-Bornes
The electrodeposition process (EDP), as described in paragraph
4.2.2, has four potential sources of solvent emissions: the coated
substrate as it is baked, evaporation from the surface of the coating in
the EDP tank, evaporation from the cascading rinse water, and evaporation
from the ultrafilter permeate sent to the drain.
The coatings on the substrates are approximately 95 percent solids
as they emerge from the bath. The remaining 5 percent is predominantly
water with only 3 to 5 percent of the volatiles as solvent.9^
Therefore, solvent emissions from this source are quite minimal.
A likelier source of fugitive emissions is evaporation of solvent
from the rinse water. During operation, a portion of the coating from the
EDP tank is pumped through an ultrafilter. The permeate is used for
rinsing, while the coating concentrate is returned to the EDP tank. Since
ultrafiltration removes nothing smaller than a molecular weight of
4-34
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500,91»92 a significant portion of water-miscible solvents, such as
alcohols and glycol ethers,90 which have molecular weights under 150,
end up in the permeate.
The permeate is then used for spray rinsing where the high surface
area of the spray is conducive to evaporation. Depending on the water
requirements for the closed-loop system, some of the permeate is sent to
the drain. It is possible that some of the solvent may be lost from the
process and, subsequently, emitted to the atmosphere in this manner.
Since the quantities of solvent involved with EDP are quite small
by comparison with solvent-borne finishes, there has been no known effort
to quantify these fugitive emissions.
Since the discussions have been limited in this chapter to emission
control techniques rather than overall systems, the impact of guidecoat or
primer surfacer on the emissions from a typical primer operation have not
been included (see Chapter 6 - Emission Control Systems).
The RSE, regardless of the source of the emissions, can be related
to the solvent content of the coating. Most EDP coatings are supplied
with an sol vent-to-sol ids ratio of 0.06 to 0.12 by weight. Since transfer
efficiency is essentially 100 percent, the RSE is also 0.06 to 0.12.
These RSE translate into percent emission reductions of 97.7 to 99.4
percent when compared against conventional enamels and lacquers (Table 4.2)
4.3.3 Water-borne Spray
In considering emission reduction for water-borne spray coatings,
it is necessary to assess the effect of solvent content and solids content
of the paint as well as transfer efficiency for not only the water-borne
but also the solvent-borne coating that it is replacing.
4-35
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TABLE 4.2. THEORETICAL EMISSION REDUCTION POTENTIAL
ASSOCIATED WITH VARIOUS NEW COATING MATERIALS
FOR USE AS AUTOMOTIVE BODY COATINGS
Percent Emission Reduction
Coating Type and
Percent Solids
By Volume
Solvent-borne
enamel, 28 v/oa
Solvent-borne
lacquer, 16 v/o
Powder coating,
97 to 98 v/o
- Water-borne
i
co
OT Water-borneb, 25 v/o
Water-bornec, 25 v/o
High-solids, 60 v/o
High-solids, 70 v/o
High-solids. 80 v/o
Application
Method
Air spray
Air spray
Electrostatic
spray
Electro-
deposition
A1r spray
Electrostatic
spray
Air spray
Air spray
Air spray
Transfer
Efficiency,
Percent
50
50
98
100
50
65-80
50
50
50
RSE,
Sol vent /Dry
Solids
5.14
10.50
0.021-0.032
0.06-0.12
1.44
up to
0.96
1.33
0.86
0.50
When
Lacquer,
16 v/o
solids
51.0
-
99.7-99.8
98.9-99.4
86.3
up to
90.6
87.3
91.8
95.2
Compared Against:
Enamel,
28 v/o
solids
-
-
99.4-99.6
97.7-98.8
72.0
up to
81.3
74.1
83.3
90.3
a v/o = volume percent
b Assumed 82/18 water/organic solvent ratio by volume
c Assumed 88/12 water/organic solvent ratio by volume
-------
Table 4.3 presents four representative comparisons. If a 25 volume
percent solids water-borne coating with an 82/18 water/organic solvent
ratio by volume, applied by air spray, were used to replace a 28 volume
percent solids solvent-borne enamel, also applied by air spray; there
would be a potential emission reduction of only 72 percent. On the other
hand, if a 25 volume percent solids water-borne coating with an 88/12
water/solvent ratio by volume, applied by electrostatic spray, were used
to replace a 16 volume percent solvent-borne lacquer, applied by air
spray; there would be an emission reduction of over 90 percent.
General Motors estimates that when using an acrylic lacquer
topcoat, its two plants at Van Nuys and South Gate emitted a total of 5.31
million Kg (11.70 million pounds) of solvent per model year2^ from
topcoat alone. When these plants converted to water-borne topcoats, the
emissions for the topcoating operations were reduced to 1.30 million Kg
(2.86 million pounds) . This represents an emission reduction of
approximately 75 percent.
One coating supplier estimates that an emission reduction in the
range of 72 to 84 percent will result from substituting water-bornes for
solvent-borne enamels in spray applications. See Table 4.3.
4.3.4 Powder Coating - Electrostatic Spray
There is a tremendous emission reduction potential associated with
the use of powder coatings that are nearly 100 percent solids.
Although powder coatings contain a small amount of volatile organic
material, the quantity does not usually exceed one-half of 1 percent,94
which is equivalent to an RSE of approximately 0.005. The volatile
organic emissions can be as high as 2 to 3 percent from baked polyvinyl
4-37
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TABLE 4.3. REDUCTION OF ORGANIC SOLVENT EMISSIONS
92,400 Square Meters (1,000,000 Square Feet)
Sprayed at 65 Percent Efficiency
Approximately 30 Percent Volume Solids
Liters (Gallons) of
Coating Type Organic Solvent Percenta
Emitted Reduction
Conventional enamel 10,931 (2,888)
Water-borne, 33 percent 2,861 ( 756) 72
organic solvent
Water-borne, 18 percent 1,560 ( 412) 84
organic solvent
Source: SME Technical Paper FC74-639, 1974. Page 3.
a Further reductions of emissions are possible through the use of
incineration. Refer to Chapter 6, page 6-2.
4-38
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chloride and epoxy coatings because of the partial evaporation of
plasticizers and co-reactants, respectively.^5 These percentage losses
translate into RSE of from 0.020 to 0.031.
With electrostatic spray of powder coatings, the powder that does
not deposit on the part is contained mostly in the spray booth. With
properly designed equipment, if the over-sprayed powder can be recovered,
overall transfer efficiencies can be as great as 98 percent. This level
is difficult to reach for automobile or light-duty truck coatings because
of the many colors and the difficulty of segregation. The RSE when
adjusted for transfer efficiency becomes 0.021 to 0.032. When compared
against conventional solvent-borne lacquers and enamels, there is a
potential emission reduction of greater than 99 percent (Table 4.2).
4.3.5 Higher Solids Coatings
To determine the emission reduction potential associated with
higher solids coatings, the RSE of various solids content paints in the
range of 30 to 80 volume percent were compared against the RSE of both
lacquer and solution enamel topcoats (Figures 4.6 and 4.7). In preparing
these estimates, the transfer efficiency was also taken into
consideration. Application by air spray (50 percent transfer efficiency)
and electrostatic spray (80 percent transfer efficiency) was compared
against application of conventional solvent-borne paints with air spray.
Figure 4.6 shows that if a 16 volume percent solvent-borne lacquer
were replaced by a 35 volume percent solids NAD or solution enamel (both
applied by electrostatic spray), there would be a potential emission
reduction of nearly 80 percent.
4-39
-------
100-
80-
u
3
"S
DC
. C
/I
-t*
OJ
u
Ol
Q.
40-
20
30 40 50 60
Volume Percent Solids Content of Coatings
70
00
Figure 4-6. Emission reduction potential (percent) with use of higher sol Ids
coatings 1n place of 16 volume percent lacquers (50 percent
deposition efficiency).
-------
At the present most high-solids coatings are being developed to
achieve 70 percent solids or greater. If the above solvent-borne lacquer
were replaced by a 50-60 percent high-solids coating applied by air spray,
then a potential emission reduction of over 80 percent could be realized.
Figure 4.7 shows that if a 28 volume percent NAD coating was
replaced by a higher solids coating of 60 volume percent solids, then an
emission reduction of 74 to 84 percent would be possible depending on the
method of application.
With the relatively high level of solvent dilution that would be
associated with a 50 to 60 volume percent high-solids coating, it is
conceivable that such coatings could be sprayed without heated equipment
and with relatively little modification of existing equipment.
Further comparisons have been presented in Table 4.2. If an 80
volume percent high-solids coating were used to replace a 16 volume
percent solvent-borne lacquer, then an emission reduction as great as 95
percent would be possible.
4.3.6 Carbon Adsorption
Carbon adsorption is being used successfully in the paper and
fabric industry for controlling solvent emissions. 6>97,98,99 Although
pilot studies have been conducted,10° no full-scale carbon adsorption
units are in place in the automotive industry at this time. While it is
generally acknowledged that an emission reduction of 85 percent or better
is possible in the automotive industry for the control of solvent vapors
from spray booths and ovens,101'102'103 this is not off-the-shelf
technology and would require considerable pilot work prior to use.
4-41
-------
100
-pt
ro
o
3
•o
&
c
o
m
•I—
E
Ol
o
OJ
a.
30
40 50 60
Volume Percent Solids Content of Coatings
Figure 4-7. Emission reduction potential (percent) with use of higher sol Ids
coatings 1n place of 28 volume percent enamels (50 percent
deposition efficiency).
-------
4.3.7 Incineration
Incineration is currently being used to control solvent emissions
in such finishing industries as paper, fabric, wire, can and coil coating,
as well as the automotive finishing industry.104'109'75'83"84 Field
investigations indicate that incineration, both thermal and catalytic, is
capable of removing at least 90 percent of the solvents from exhaust air
streams.106'107'84'80'111'112'113
Catalytic incinerators are in routine use in the automotive
89
industry at this time, and several bake ovens in Ford Motor Company
plants in California are equipped with thermal incinerators. »°'
Typical units operating at 760°C to 815°C (1400 to 1500°F) have
operating efficiencies of at least 90 percent.114
4-43
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4.4 REFERENCES
1. Schrantz, J. "Off-Line Cleaning and Electrocoating of Truck
Cabs." Industrial Finishing. 52.(6) :40-46, June 1976.
2. Bardin, P.C. "Chevrolet Primes Truck Parts in Two
60,000-Gallon EDP Tanks." Industrial Finishing. 49(2):58-65,
February 1973.
3. "Primer Electrodeposition at GM South Gate Plant." Products
Finishing. March 1968.
4. Jones, F.N. "What Properties Can You Expect from Agueous
Solution Coatings?" SME Technical Paper. FC74-641:3-4, 1974.
5. Loop, F.M. Automotive Electrocoat. Preprints, NPCA Chemical
Coatings Conference, Electrocoat Session. 81, April 22, 1976.
6. Koch, R.R. "Electrocoating Materials Today and Tomorrow." SME
Technical Paper. FC75-563:4, 1975.
7. Paolini, A. and M.A. Glazer, "Waterborne Coatings, A Pollution
Solution." Preprints for ACS Division of Environmental
Chemistry. 98, Fall 1976.
8. Steinhebel, F.W. "Water-Soluble Primer with Electro-coating."
Industrial Finishing. August 1967.
9. Pitcher, E.R. "Electrocoating Electrical Raceways,"
Industrial Finishing. March 1969.
10. "Electrocoat System Speeds Truck and Tractor Seat Painting."
Products Finishing. May 1969.
11. Anderson, J.E. "Electrocoating Aluminum Extrusions." Products
Finishing. September 1967.
4-44
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12. Schrantz, J. "How Ultrafiltration Benefits Equipto."
Industrial Finishing. 48(9):28-32, September 1972.
13. Schrantz, J. "UF Benefits Conveyorized, Batch-Type EDP
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DeBell & Richardson, Inc., Enfield, Connecticut. Trip Report
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22. Gabris, T. Trip Report - General Motors, Van Nuys Plant.
DeBell & Richardson, Inc., Enfield, Connecticut. Trip Report
110, April 6, 1976.
4-45
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23. Gabris, T. Trip Report - Ford Motor Company Plant, Oakville,
Ontario. DeBell & Richardson, Inc., Enfield, Connecticut.
Trip Report 56, February 10, 1976.
24. Henning, C.C. and J.J. Krupp. "Compelling Reasons for the Use
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FC74-639:3-6, 1974.
25. Halstead, M. "Conversion to Water Borne Enamel." Preprints,
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26. Schrantz, J. "Water-Reducible Electrostatic Spray Brings Cost
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27. "Electric Wheel converts to Water-Borne Alkyd Enamel."
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28. Schrantz, J. "Truck Wheels Get Water-Base Aluminum-Colored
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30. "The Latest in Water-Borne Coatings Technology." Industrial
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31. Pegg, F.E. "Applying Plastic Coatings with the Fluidized Bed
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32. Sevinson, S.B. "Powder Coat." Journal of Paint Technology.
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4-46
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33. Poll, 6.H., Jr. "High-Production Acrylic Powder Coating."
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34. "Iverson Powder Coats Bicycles in 20 Colors." Industrial
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35. Cole, E. N. "Coatings and Automobile Industries Have Common
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36. Gabris, T. Trip Report - Ford Motor Company, Metuchen Plant.
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37. Schrantz, J. "Powder Coating Brings Advantages to Baldwin."
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38. "Automotive Powder Under the Hood." Products Finishing.
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39. Cehanowicz, L. "The Switch is on for Powder Coating."
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41. "How Nylon Powder Coatings Help." Products Finishing.
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42. Mazia, J. "Technical Developments in 1976." Metal Finishing.
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43. "Powdered Automobile Paints Make a Strong Inroad." Chemical
Engineering. 83(14):33, July 5, 1976.
44. Miller, E.P. and D.D. Taft, Fundamentals of Powder Coating,
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45. Levinson, S.B. "Radiate." Journal of Paint Technology.
44(571):32-36, August 1972.
46. North, A.G. "Progress in Radiation Cured Costings." Pigment
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47. Nickerson, R.S. "The State of the Art in UV Coating."
Industrial Finishing. 50(2):10-14, February 1974.
48. Dowbenko, R. and D.P. Hart. "Nonaqueous Dispersions as
Vehicles for Polymer Coatings." Industrial Engineering
Chemistry Product Research and Development. 12(l):14-28, 1973.
49. Conversation with Mr. Noone, Product Manager, Automotive
Finishes Department, DuPont Company, Southfield, Michigan.
February 23, 1977.
50 Conversation with A. Little, Ditzler, Automotive Finishing
Division, PPG Industries, Inc., Detroit, Michigan.
February 23, 1977.
51. Rule 66, Organic Solvents. Los Angeles, California. Air
Pollution Control District, County of Los Angeles. July 28,
1966. Amendments of November 2, 1972, and August 31, 1974.
52. Young, R.G. and W.R. Howell. "Epoxies Offer Fulfillment of
High Performance Needs." Modern Paint and Coatings.
65(3):43-47, March 1975.
53. Lunde, -D.I. "Acrylic Resins Defy Conventional Relationships in
New Technology Coatings." Modern Paint and Coatings.
66(3):51-53, March 1976.
4-48
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54. Mercuric, A. and S.N. Lewis. "High Solids Coatings for Low
Emission Industrial Finishing." Journal of Paint Technology.
47(607):37-44, August 1975.
55. Baker, R.D. and J.J. Bracco. "Two Component Urethanes: Higher
Solids Systems at Lower Cure Temperatures." Modern Paint and
Coatings. 66(3):43-48, March 1976.
56. Larson, J.M. and D.E. Tweet. "Alkyds and Polyesters Readied
for Market Entry." Modern Paint and Coatings. 65(3):31-34,
March 1975.
57. Mazia, J. "Technical Developments in 1976." Metal Finishing.
75(2):74-75, February 1977.
58. Mantell, C.L. Adsorption. New York. McGraw-Hill, 1951.
237-248.
59. Kanter, C.B., et. al. "Control of Organic Emissions from
Surface Coating Operations." Proceedings of the 52nd APCA
Annual Meeting, June 1959.
60. Elliott, J.H., N. Kayne, and M.F. Leduc. Experimental Program
for the Control of Organic Emissions from Protective Coating
Operations. Report No. 7. Los Angeles APCD, 1961.
61. Lund, H.F. Industrial Pollution Control Handbook. New York.
McGraw-Hill, 1971. 13-13 and 19-10.
62. Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold. Evaluation
of a Carbon Adsorption/Incineration Control System for Auto
Assembly Plants. Radian Corporation; Austin, Texas. EPA
Contract 68-02-1319, Task 46, May 1976. p. 54-58.
4-49
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63. Atherton, R.B. Trip Report - Automobile Manufacturers in
Detroit, Michigan; Dearborn and Wayne, Michigan. EPA, Industry
Survey Section, Research Triangle Park, North Carolina. April
16, 1973.
64. Lee, D. Vic Manufacturing Company; Minneapolis, Minnesota.
Letter to Bob Wetherold, Radian Corporation, dated March 17, 1976.
65. Roberts, R.E. and J.B. Roberts. "An Engineering Approach to
Emission Reduction in Automotive Spray Painting." Proceedings
of the 57th APCA Meeting. 26(4):353, June 1974.
66. Cavanaugh, E.C., G.M. Clancy, and R.G. Wetherold. p. 32.
67. Sussman, Victor H. Ford Motor Company; Dearborn, Michigan.
Letter to R.G. Wetherold, Radian Corporation, dated March 15, 1976.
68. Handbook of Chemistry and Physics. Weast, R.C. (ed.)
Cleveland. The Chemical Rubber Company. 1964. E-26.
69. Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold., p. 27.
70. Grandjacques, B. Air Pollution Control and Energy Savings with
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July 19, 1975.
71. Lee, D.R. "Activated Charcoal in Air Pollution Control."
Heating, Piping and Air Conditioning. 76-79, April 1970.
72. Lund, H.F. p. 5-27 to 5-32.
73. Conversation between Fred Porter, Ford Motor Company, Dearborn,
Michigan, and EPA-CTO, Research Triangle Park, North Carolina.
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74. Benforado, D.M. "Air Pollution Control by Direct Flame
Incineration in The Paint Industry." Journal of Paint
Technology. 39(508):265, May 1967.
75. Gabris, T. Trip Report - Roll Coater, Inc., Kingsbury,
Indiana. DeBell & Richardson, Inc., Enfield, Connecticut.
Trip Report 76. February 26, 1976.
76. Hydrocarbon Pollutant Systems Study. MSA Research Corporation;
Evans City, Pennsylvania. MSAR 72-233, October 20, 1972. VI-4.
77. Stern, A. C. Air Pollution; Vol. Ill, Sources of Air Pollution
and Their Control. New York. Academic press, 1968,
78. Lund, H.F.P. 7-8 to 7-11.
79. "Heat Recovery Combined with Oven Exhaust Incineration."
Industrial Finishing. 52(6):26-27.
80. Re-Therm Oxidation Equipment. Product Bulletin
REE-1051-975-15M. Reeco Regenerative Environmental Equipment
Company, Inc., Morris Plains, New Jersey.
81. Young, R.A. "Heat Recovery: Pays for Air Incineration and
Process Drying." Pollution Engineering. 7J9):60-61, September
1975.
82. "Can Ceramic Heat Wheels Do Industry a Turn?" Process
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83. Gabris, T. Trip Report - Ford Motor Company, Truck Plant,
Milpita-s, California. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 120. April 8, 1976.
84. Gabris, T. Trip Report - Ford Motor Company, Auto Plant,
Milpitas, California. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 112. April 7, 1976.
4-51
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85. Danielson, J.A. Air Pollution Engineering Manual. Cincinnati,
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178-184.
86. Stern, A.C. Air Pollution. New York. Academic Press. Volume
II, Second Edition, Chapter 16. 1968.
87. Kent, R.W. "Thermal Versus Catalytic Incineration." Products
Finishing. 40(2):83-85, November 1975.
88. Fuel Requirements, Capital Cost and Operating Expense for
Catalytic and Thermal Afterburners. Combustion Engineering,
Air Preheater Division, Wellsville, New York. EPA Contract
68-02-1473, Task 13.
89. Bullett, Orville H., E.I. duPont de Nemours in Comments to
National Air Pollution Control Techniques Advisory Committee,
9/27/77.
90. Koch, R.R. Electrocoating Materials Today and Tomorrow. SME
Technical Paper. Fc75-563:4, 1975.
91. Blatt, W.F. Hollow Fibers: A Transition Point in Membrane
Technology. American Laboratory. 78, October 1972.
92. Mahon, H.I. and B.J. Lipps. "Hollow Fiber Membranes." In:
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John Wiley and Sons, 1971, 269.
93. Finish for the Future with Nordson Electrostatic Powder Spray
Systems. Product Bulletin 306-18-70. Nordson Corporation;
Amherst, Ohio.
94. Automatic Powder Coating System Design. Technical Bulletin 2.
Interred Corporation; Stamford, Connecticut.
4-52
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95. Prane, J.W. "Nonpolluting Coatings and Energy Conservation."
ACS Coatings and Plastics Preprints. 34_(1):14, April 1974.
96. Oge, M.T. Trip Report - Fasson Company, Painesville, Ohio. -
DeBell & Richardson, Inc., Enfield, Connecticut. Trip Report
141. July 21, 1976.
97. Oge, M.T. Trip Report - Brown-Bridge Mills, Troy, Ohio. DeBell
& Richardson, Inc., Infield, Connecticut. Trip Report 140.
July 20, 1976.
98. Solvent Recovery Installations. Supplier Bulletin.
Vulcan-Cincinnati, Incorporated; Cincinnati, Ohio.
99. McCarthy, R.A. Trip Report - Raybestos-Manhattan, Incorporated,
Mannheim, Pennsylvania. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 77. February 26, 1976.
100. Reinke, J.M. Ford Motor Company, Dearborn, Michigan. Letter to
James McCarthy, EPE-CTO, dated November 1, 1976.
101. Sussman, Victor H. Ford Motor Company; Dearborn, Michigan.
Letter to James McCarthy, EPA-CTO, August, 6 1976.
102. Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold. Evaluation
of a Carbon Adsorption/Incineration Control System for Auto
Assembly Plants. Radian Corporation; Austin, Texas. EPA
Contract 68-02-1319, Task 46, May 1976.
103. Johnson, W.R. General Motors Corporation; Warren, Michigan.
Letter to Radian Corporation commenting on Reference 63; letter
dated March 12, 1976.
104. Oge, M.T. Trip Report - Hazen Paper Company; Holyoke,
Massachusetts. DeBell & Richardson, Inc., Enfield, Conn. Trip
Report 134. May 19, 1976.
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105. McCarthy, R.A. Trip Report - DuPont Corporation, Fabric and
Finishes Department; Fairfield, Connecticut. DeBell &
Richardson, Inc., Enfield, Connecticut. Trip Report 130.
April 30, 1976.
106. Kloppenburg, W.B. Trip Report - Phelps Dodge Magnet Wire; Fort
Wayne, Indiana. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 113. April 7, 1976.
107. Kloppenburg, W.B. Trip Report - General Electric Company;
Schenectady, New York. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 106. April 6, 1976.
108. Gabris, T. Trip Report - National Can Corporation; Danbury,
Connecticut. DeBell & Richardson, Inc., Enfield, Connecticut.
Trip Report 128. April 27, 1976.
109. Gabris, T. Trip Report - Continental Can Company, Inc.;
Portage, Indiana. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 80. March 3, 1976.
110. Gabris, T. Trip Report - Litho-Strip Company, South Kilburn,
Illinois. DeBell & Richardson, Inc., Enfield, Connecticut.
Trip Report 35. January 22, 1976.
111. Fisher, J.R. Trip Report - Supracote, Inc., Cucamonga,
California. DeBell & Richardson, Inc., Enfield, Connecticut.
Trip Report 31. January 16, 1976.
112. Gabris, T. Trip Report - American Can Company, Plant 025,
Edison, New Jersey. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 6. December 29, 1975.
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113. Kloppenburg, W.B. Trip Report - Chicago Magnet Wire, Elks Grove
Village, Illinois. DeBell & Richardson, Inc., Enfield,
Connecticut. Trip Report 124. April 9, 1976.
114. Sussman, Victor H. Ford Motor Company. Dearborn, Michigan.
Letter to James McCarthy, EPA-CTO, dated March 16, 1976.
115. Scharfenberger, J.A. "New High Solids Coating Equipment Offers
Eco logy/Energy Advantages." Modern Plastics. 53_(2) :52-53,
February 1976.
116. Price, M.B. "High Solids Coatings - Where Can They Be Used."
Preprints, NPCA Chemical Coatings Conference, High Solids
Session. 37, April 22, 1976.
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5. MODIFICATIONS AND RECONSTRUCTIONS
5.1 BACKGROUND
This chapter identifies and discusses possible or typical changes to
automobile and light-duty truck surface coating operations which could be
termed modifications or reconstructions. Modified or reconstructed existing
facilities must comply with standards of performance for new sources. A
modification is defined as ". . . any physical change in, or change in the
method of, operation of an existing facility which increases the amount of
any air pollutant (to which a standard applies) emitted into the atmosphere
by that facility or which results in the emission of any air pollutant (to
which a standard applies) into the atmosphere not previously emitted." An
"existing facility" is defined as one which would be required to conform to
a standard of performance, if it were new, but which was, in fact, con-
structed or modified before the date of proposal of the standard of per-
formance.
The regulation on modifications requires the owner or operator of any
source—an automobile and light-duty truck surface coating operation in
this case—classified as an "existing facility" to notify EPA of changes
which could cause an increase in emissions of an air pollutant for which a
"o
standard of performance applies. These changes are not "modifications"
(i.e., the existing facility would not have to meet the standards of perfor-
mance) if the owner or operator demonstrates that no increase in emissions
for which a regulation applied resulted from the alteration.
5-1
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The term "reconstruction" is defined as the ". . . replacement of a
substantial majority of the existing facility's components irrespective of
any change of emission rate." Reconstruction occurs when components of an
existing facility are replaced to such an extent that:
• The fixed capital cost of the new components exceeds 50 percent
of the fixed capital cost that would be required to construct a
comparable entirely new facility, and
• It is technologically and economically feasible to meet the appli-
cable standards.
The purpose of this provision is to discourage the perpetuation of a fa-
cility which, in the absence of a regulation, would normally have been
4
replaced. The owner or operator must notify EPA to provide information
concerning the construction or reconstruction of an existing facility.
5.2 POTENTIAL MODIFICATIONS
The following potential modifications would apply to both passenger
car and light-duty truck body painting operations, since both operations
are similar. The only real difference is that automobile body lines generally
run faster than light-duty truck lines. This difference, however, does not
affect the types of changes that might be made to a coating line, the
reasons for the change, or the nature of its impact on emissions. Therefore,
for purposes of this chapter, the two operations can be considered similar.
Certain circumstances exist under which an increase in emissions does
not result in a modification. If a capital expenditure less than the most
recent annual asset guideline repair allowance published by the Internal
Revenue Service (Publication 534) is made to increase capacity at an exist-
ing facility and also results in an increase in emissions of a regulated
5-2
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pollutant to the atmosphere, a modification is not considered to have
occurred.
The following changes in materials or formulations could increase
solvent emissions but would be considered as a change in raw material and,
therefore, not a modification. If associated capital expenditures exceed
the minimum for reconstructions, the facility could be considered to have
been reconstructed and thus subject to the proposed regulation.
• Lower Solids Coatings. If a change is made from a higher to a
lower solids coating (e.g., from an enamel to a lacquer), more
material, and hence more solvent, will be used to maintain the
same dry coating thickness. While a change in the direction of
lower solids is unlikely, it could occur in any one plant as a
result of changing paint systems, colors, models, or use of
metallics. It is unlikely, however, that any major capital
expenditures to equipment would be required.
• Use of Higher Density Solvent. Regulations normally restrict the
number of pounds of solvent that can be emitted. An increase in
the density of the solvents used, even if the volumetric amounts
used were the same, would result in more mass of solvent being
emitted. Again, this could be construed as a raw material sub-
stitution and hence not a modification, as no major capital
expenditures would be involved. Such substitutions might come
about as a result of solvent shortages, attempts to cut paint
costs, or efforts to incorporate less photoreactive solvents.
• Increased Thinning of Coatings. A change to a higher viscosity
coating could result in an increased use of solvents for thinning
the coating to proper application consistency.
5-3
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An increase in working hours (i.e., from one- to two-shift operation
or from 8 hours to 10 hours per shift) does not increase solvent emissions
per hour and, hence, is not considered a modification.
Other possible changes that could result in increased solvent emissions
include:
• Change to Larger Parts. If body size were increased, more coating
materials could be used per vehicle, hence, emissions could
increase even if production rates were maintained constant.
While the overall trend is toward smaller sized automobiles, any
one facility could switch from a smaller sized automobile to a
larger model. It is felt, however, that such a change would not
qualify as a modification per se, since automobile or light-duty
truck assembly lines normally can accept more than one size of
vehicle.
t Increased Film Thickness. A change to a thicker coating, if
other factors remain constant, could result in increased solvent
emissions. An effort is under way in the automotive industry to
increase corrosion resistance, which could call for increased
coverage or thicker coatings in corrosion-prone areas. If these
changes are made only for the purpose of improved product relia-
bility, and no increases in production rate occurs, they will
will not be considered modifications.
• Reduced Deposition Efficiency. Increased overspray because of a
process modification, such as a switch from electrostatic spray
to conventional spray, would result in increased emissions. For
economic reasons, however, a switch in such a direction is un-
likely except possibly as a temporary measure.
5-4
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• Additional Coating Stations. If for any reason additional coat-
ing stations were added, emissions could increase. Such a change
would likely involve costly alterations or a new facility and, as
such, would be subject to regulation.
• Annual Model Changeovers. Model changes are normally handled
with existing equipment and do not require process changes.
Slight increases in emissions could occur, however, due to a
change in configuration of the vehicle. For example, transfer
efficiencies are usually lower for coating small vehicles than
for larger ones. Therefore, a switch to production of smaller
vehicles could cause an increase in emissions. However, such
changes, made only for model changeovers and not intended to
increase production rate, will not be considered modifications.
• Changes in Coating Specifications. Changes in coating materials
to produce new colors or surfaces, increase corrosion resistance,
or otherwise improve the quality of the surface coating, could be
associated with an increase in solvent emissions. When these
coating changes cause an increase in emissions, they will be
examined by the Administrator on a case-by-case basis to deter-
mine if they will be considered a modification of an existing
facility.
Of the potential modifications listed above, only those involving
production increases which require excessive capital expenditures will
normally be considered as modifications. The installation of additional
coating stations is the only change listed which would usually subject the
source to regulation.
5-5
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5.3 RECONSTRUCTION
Automotive spray booths and bake ovens usually last 20 to 25 years and
are normally not replaced before that time unless process changes require
their replacement. When spray booth and bake oven replacements are made,
however, the capital expenditures involved are normally sufficient to be
considered reconstructions.
The trend toward electrodeposition (EDP) of water-based primer coatings
may have an impact on the issue of reconstruction. Both Ford and General
Motors use this system quite extensively, and Chrysler is now considering
it. International Harvester uses the system for priming light-duty truck
bodies. Increased corrosion resistance is an advantage of the EDP coating
system and a principal reason for its use; considerably lower solvent
emissions (even with a guidecoat) are an important secondary effect.
Hence, if a primer paint line were to be replaced, an EDP system would
likely be installed even without emission regulations. The fact that 50
percent of U.S. passenger car bodies are already prime-coated by this
method would support such a conclusion. Installation of an EDP system,
however, could be a potential reconstruction due to the costs involved in
adding the tank, bake oven, and auxiliary equipment. But, since electrode-
position of water-based coatings achieves the lowest emissions of any
control system identified in Chapter 4 for prime coat operations, any
existing facility that changes to an EDP system should automatically meet a
standard of performance.
5-6
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REFERENCES FOR CHAPTER 5
1. FEDERAL REGISTER, Volume 40, Number 242, "Standards of Performance for
New Stationary Sources: Modification, Notification, and Reconstruction,"
Subpart A, 40 CFR 60.14, Tuesday, December 16, 1975.
2. Ibid.. Subpart A, 40 CFR 60.7.
3. Ibid.. Subpart A, 40 CFR 60.15.
4. Ibid., Reconstruction.
5. Ibid.. Subpart A, 40 CFR 60.7.
6. Gabris, T. DeBell & Richardson, Inc., Enfield, Connecticut. Telephone
conversation with R. Flaherty, Chrysler Corporation.
7. Gabris, T. DeBell & Richardson, Inc., Enfield, Connecticut. Telephone
conversation with T.B. King, International Harvester Corporation.
March 2, 1977.
5-7
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6. EMISSION CONTROL SYSTEMS
6.1 GENERAL
Chapter 4 described and evaluated the performance of the individual
emission control technologies which can be used to reduce VOC emissions
from coating operations in the automotive industry. This chapter identi-
fies alternative emission control systems for typical automobile and light-
duty truck surface coating operations. A system can be either a coating
material and application technique, an add-on control device, or a combina-
tion of the two. The choice of the system depends on the particular coating
operation and the desired level of control.
This chapter presents a number of alternative emission control systems
to be used in analyzing the range of environmental (Chapter 7) and economic
(Chapter 8) impacts associated with various alternative regulatory options.
Primer, surfacer (when used) and topcoat operations are each considered as
separate emission sources. Surfacer is considered with the topcoat.
Although there are many alternatives for controlling or reducing primer,
guide coat, and topcoat emissions for both automobile and light-duty truck
surface coating operations, only those shown in Table 6-1 were investi-
gated. These were chosen because they are representative of the options
available.
The model plant for automobile bodies produces 55 bodies per hour,
3,840 hours per year (basis: 240 days at two 8-hour shifts). The model
plant for light-duty truck bodies operates at 38 bodies per hour, 3,840
hours per year. These model plants produce 211,200 automobiles or 145,920
light-duty trucks annually, and are typical of automotive assembly plants.
6-1
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6.2 BASE CASE
The application of a water-based primer by electrodeposition (EDP) is
currently in widespread use in the automobile and light-duty truck industry,
primarily because of the increased corrosion protection it affords. Thus,
EDP is considered the base case for the prime coat. At the present time
automobile and light-duty truck coating lines usually spray an additional
coat on the vehicles between the primer and the topcoat. This additional
coat, the primer surfacer, or guide coat, provides a smoother surface for
the topcoat application. Most plants currently use solvent-based guide
coat and topcoat, and, in the absence of air pollution regulations, new
plants would likely continue this practice. Therefore, the use of organic
solvent-based coatings is properly considered the base case for the guide
coat and topcoat operations.
6.3 REGULATORY OPTIONS
There are three sources of emissions from the coating of automobiles
and light-duty trucks:
• Primer
• Guide coat or (surfacer)
• Topcoat
For primer, electrodeposited coating is the best control option and
also the best coating. Therefore, as explained in Section 6.2, this can be
considered the base case.
For guide coat and topcoat two control methods are available:
t Use of water-based coatings
• Use of solvent-based coatings with incineration
6-2
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Incinerators have been used by some automobile and light-duty truck plants
for ovens, and, although not currently in use, incineration for spray
booths presents no technical problem.
The availability of these control methods leads to the three regula-
tory options described below:
• OPTION I(A) involves the electrodeposition of water-based primer
and the air spraying of water-based topcoat. When water-based
topcoats are used, the surfacer used over the EDP primer is
normally a water-based coating and is so assumed in this option.
This option does not include any add-on controls.
• OPTION I(B) adds incineration of the guide coat and topcoat
emissions from the bake ovens to the base case. The incinerator
achieves a 90 percent reduction in the VOC concentration of the
stream passing through it.
• OPTION II adds 90 percent effective incineration of the emissions
from both the spray booths and ovens on the guide coat and topcoat
operations to the base case.
Emissions from these options are summarized and compared to the base
case in Table 6-1. Options I(A) and I(B) achieve between 75 and 80 percent
reduction from the base case, while Option II achieves almost 90 percent
reduction.
6-3
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Table 6-1. AUTOMOBILE AND LIGHT-DUTY TRUCK COATING LINES -
EMISSION CONTROL OPTIONS EVALUATED
Emission Control System
Base Case
1. Primer - water-based coatings applied by EDP
2. Guide coat - solvent-based coatings applied by air spray
3. Topcoat - solvent-based coatings applied by air spray
Option I(A)
1. Primer - water-based coatings applied by EDP
2. Guide coat - water-based coatings applied by. air spray
3. Topcoat - water-based coatings applied by air spray
Option I(B)
1. Primer - water-based coatings applied by EDP
2. Guide coat - solvent-based coatings applied by air spray
3. Topcoat - solvent-based coatings applied by air spray with incineration of spray booth and
oven exhaust1
Option II
1. Primer - water-based coating applied by EDP
2. Guide coat - solvent-based coatings applied by air spray with incineration of spray booth and
oven exhaust1
3. Topcoat - solvent-based coatings applied by air spray with incineration of spray booth and oven
exhaust1
Emissions from Model
Plant
(Metric Tons/Year)
Light-Duty
Automobile Truck
1775
373
435
212
1273
278
301
147
% Reduction
From Base Case
Light-Duty
Automobile Truck
—
79
76
88
—
78
76
88
Emissions based on incineration with 90% efficiency.
-------
7. ENVIRONMENTAL IMPACT
7.1 AIR POLLUTION IMPACT
7.1.1 General
Automobile and light-duty truck assembly lines are major point
sources of solvent emissions. Most of these emissions result from coating
the automobile and/or light-duty truck body on the assembly line(s) within
the plant. For example, an automobile assembly line operating 3,840 hours
per year (two 8-hour shifts, 240 days per year) at 55 cars per hour
creates uncontrolled volatile organic emissions from solvent-borne primer
of approximately 1,000 tonnes (2,200,000 pounds) per year. Emissions from
solvent-borne topcoat operations of this line add about 1,500 tonnes
(3,300,000 pounds) per year. This equals slightly more than 10.4 tonnes
(23,000 pounds) of solvent emissions per work day from the total finishing
process.
In 1973 (a very high production year), U.S. consumption of solvents
in paints and coatings was about 1,900,000 tonnes or 4,190,000,000
pounds. Of this, approximately 680,000 tonnes (1,500,000,000 pounds)
were aliphatic, and 400,000 tonnes (882,000,000 pounds) were aromatic;1
thus establishing the following solvent distribution for paints and
coatings:
7-1
-------
Tonnes
Category (x 103) Percent
Oxygenated solvents 801 42
Aliphatic hydrocarbons 680 36
Aromatic hydrocarbons 400 21
Other 17 1
Total -1900 100
In 1973, excluding maintenance coatings and exports, 1247 million
liters (330 million gallons) of industrial finishes were made and applied
on a variety of products. Of this 1247 million liters of coatings,
170 million liters (45 million gallons) were used on automobiles and
approximately 75 million liters (20 million gallons) on other
transportation units. !t is estimated that the coating of light-duty
trucks used some 40 million liters (10.5 million gallons) of these
75 million liters. Solvents included in these 1247 million liters
(330 million gallons) of industrial product finishes are estimated at
about 756 million liters or 200 million gallons.
The objective of New Source Performance Standards is to limit the
emission of pollutants by imposing standards that reflect the degree of
emission reduction achievable through the application of the best
system(s) of emission reduction, that is (are) determined by the
Administrator to be adequately demonstrated in achieving such reduction.
Several alternative solvent emission control systems (hereinafter referred
to as options) have been identified for automobile and light-duty truck
finishing.
7-2
-------
In assessing the environmental impact and the degree of emission
control achieved by each alternative that could serve as the basis for
standards, these alternatives need to be compared. Also, other facets of
environmental impact — such as potential water pollution and solid waste
generation — need to be assessed. Similarly, state regulations and
controlled emissions should be considered. These are discussed in the
following paragraphs.
7.1.2 State Regulations and Controlled Emissions
In August 1971, Los Angeles County in California adopted Rule 66,
Section C, specifying that effective August 31, 1974, the maximum
allowable organic non-photochemically reactive emissions per facility was
to be 3,000 pounds per day. The rule allowed only 40 pounds per day from
sources using photochemically reactive solvents and 15 pounds per day from
ovens under certain circumstances. Emissions above this limit required
control. This rule was eventually supplanted by a district regulation
with similar provisions.
Very few coatings users other than automobile and/or light-duty
truck assembly plants (and some heavy-duty truck plants) consume enough
coating to generate more than 3,000 pounds of total solvent emissions per
day. The regulation also provides exemptions for 85 percent emission
control and for water-borne coatings where the volatile content consisted
of 80 percent water, and the solvent was a nonphotochemically reactive
solvent as defined in the regulation.
As of 1977, only 13 states had statewide regulations dealing with
hydrocarbon emissions. Approximately half of these states' regulations
were the same as or similar to Rule 66 of Los Angeles. These regulations
carefully limited the amount of photochemically reactive solvent volatiles
7-3
-------
that could be emitted within a given time period, from coating
applications, baking ovens, and curing operations in an automotive plant.
There are many difficulties in understanding and interpreting Rule
66-type regulations. While many states have Rule 66-type regulations,
many have variations such as in the maximum limit per day. Even those
states that have the same regulation seem to interpret it differently.
The interpretation of the definition of an affected facility has great
impact on the stringency of a regulation. The situation is complicated
even more by the simultaneous activity of rewriting state regulations.
The economic, environmental, and energy impacts of the proposed stan-
dards are difficult to assess. Normally these impacts are expressed as
incremental differences between a facility complying with a proposed new
source performance standard and a typical State Implementation Plan (SIP)
emission standard. In the case of automobile and light duty truck surface
coatings, all of the existing facilities are located in areas which are
considered nonattainment areas for purposes of achieving the National
Ambient Air Quality Standard (NAAQS) for ozone. New facilities are also
expected to locate in similar areas.
The states are in the process of revising their SIP's for these areas
and are expected to include revisions to their emission limitations appli-
cable to automobile and light duty truck surface coatings. EPA has issued
a control techniques guideline document on automobile and light duty truck
surface coatings which the states are using as a guideline in revising
their SIP's. The recommended control systems provided in the guideline
document are essentially the same as the systems on which the standards
proposed herein are based. The actual incremental impacts of the proposed
standards will be determined by the final emission limitations adopted by
the States. For the purposes of this rulemaking, however, the environmen-
7-4
-------
tal, energy, and economic impacts of the proposed standards are based on
emission control levels contained in existing SIP's.
7.1.3 Uncontrolled and Controlled Emissions (Options)
7.1.3.1 Automobiles
The following paragraphs discuss which control methods on certain
processes would allow substantial reductions in solvent emissions.
The model automobile assembly line produces 55 automobiles per hour
and operates two (8-hour) shifts per day. This line produces 880
automobiles per day or 211,200 automobiles per year (240 work days per
year). This is representative of the industry.
The worst case assumes that all coatings are solvent-borne, and no
add-on controls are used. Primer is 24 percent solids by volume, and
topcoat is 19 percent solids by volume. No surfacer is used with organic
solvent-borne primer. These amounts, converted into daily emissions, add
up as follows for the model assembly line:
Emissions (Volatile Solvents) Tonnes Per Year
From solvent-borne primer operation 1,020
From solvent-borne topcoat operation 1,489
Total 2,509
The base case replaces the solvent-borne primer with an
electrodeposited water-borne primer on the model line. Primer emissions
are thereby reduced to 37 tonnes or 81,600 pounds per year. The use of
the solvent-borne surfacer increases primer emissions to 286 tonnes or
631,000 pounds per year. The emission value for electrodeposition is
derived from actual plant visits. The emissions for surfacer and topcoat
7-5
-------
are calculated based on the assumption that an enamel with 24 percent
solids by volume is used for both.
Emissions for the model assembly line under this base case are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 37
From solvent-borne surfacer 249
From solvent-borne topcoat 1,489
Total 1,775
Option 1 replaces the solvent-borne surfacer and topcoat with
water-borne surfacer and topcoat. Emissions for the model assembly line
under this option are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 37
From water-borne surfacer 41
From water-borne topcoat 295
Total 373
Option 2 is identical to the base case except that emissions from
the topcoat are incinerated. Emissions for the model assembly line under
this option are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 37
From solvent-borne surfacer 249
From solvent-borne topcoat with incineration 149
Total 435
Option 3 is identical to the base case except that emissions from
the surfacer and topcoat are both incinerated. Emissions for the model
plant under this option are:
7-6
-------
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 37
From solvent-born surfacer with incineration 26
From solvent-borne topcoat with incineration 149
Total 212
7.1.3.2 Light-Duty Trucks
The model light-duty truck assembly line produces 145,920 bodies
per year (in 240 workdays). As in the automobile base case, the model
being discussed here does not represent a specific line nor is it intended
to indicate that all light-duty truck finishing lines have these
parameters. This model, however, is typical or representative of the
industry.
The worst case assumes that a model plant uses all solvent-borne
coatings. Primers are 30 percent solids by volume, and topcoat is 28
percent solids by volume. Emissions are as follows:
Emissions (Volatile Solvents) Tonnes Per Year
From solvent-borne primer operation 649
From solvent-borne topcoat operation 1,080
Total 1,729
The base case replaces the solvent-borne primer with
electrodeposited water-born primer. A surfacer is required when using
electrodeposition. Emissions under this base case are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 21
From solvent-borne surfacer 172
From solvent-borne topcoat 1,080
Total 1,273
7-7
-------
Option 1 replaces the solvent-borne surfacer and topcoat with
water-borne surfacer and topcoat. Emissions under this option are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 21
From water-borne surfacer 28
From water-borne topcoat 229
Total 278
Option 2 assumes the base case with incineration of the emissions
from the topcoat. The solvent-borne surfacer is 25 percent solids by
volume. Emissions under this option are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 21
From solvent-borne surfacer 172
From solvent-borne topcoat with incineration 108
Total 301
Option 3 assumes the base case with incineration of emissions from
both the surfacer and topcoat. Emissions under this option are:
Emissions (Volatile Solvents) Tonnes Per Year
From electrodeposition of water-borne primer 21
From solvent-borne surfacer with incineration 18
From solvent-borne topcoat with incineration 108
Total 147
7.1.4 Estimated Hydrocarbon Emission Reduction in Future Years
7.1.4.1 General
After a record production of 9,667,118 automobiles in 1973, sales
declined in 1974 and 1975. In 1976 the auto industry staged a comeback
and production returned to over 8 million automobiles, with further gains
7-8
-------
in 1977 to 9,200,000. A recent study estimates U.S. production will be
?1
11 million units in 1985.
These figures and the yearly emissions (and emission reductions),
that could occur in the coming years as a result of any standards set
(based on the alternatives discussed in this section), are discussed in
the following paragraphs.
The truck industry manufactures a wide range of vehicles designed
for personal and commercial application. Different models of vehicles are
classified by gross vehicle weight and body types. Trucks with gross
vehicle weights up to and including 8500 pounds are included under
light-duty trucks. Approximately 75 percent of the total truck production
is accounted for by trucks of less than 8500 pounds gross vehicle
weight. 19-29
As with, the automobile industry, the truck industry was affected by
the recession. After the record production of 3,007,495 units in 1973,
production slackened in 1974 and 1975. However, truck production in 1976
increased 37 percent over 1975 production and exceeded the record high of
1973 by about 8000 units.22'24 Short-range (to 1980) expansion rates
22
are projected at approximately 4 percent per annum. More modest
growth (1 percent average annual rate) is projected for 1980 to 1985.
Based on these figures, light-duty truck production is estimated to reach
2,580,000 in 1979, 2,600,000 in 1980, and 2,740,000 units in 1985.
7.1.4.2 Automobiles
The technological merits of the electrodeposition of water-borne
primers have been discussed elsewhere in this report. All indications are
that the automobile industry will continue to explore these advantages.
The expected result is an annual growth of 4 to 5 percent for this
7-9
-------
technology. Since this would occur even without air pollution control
regulations, use of electrodeposition is included in the base case.
Therefore, it can be assumed that by 1979, 60 percent of automobile
primers will be water-borne; and by 1985 a 90 percent conversion will
occur. The wider use of water-borne primers alone, however, will barely
offset the emissions from uncontrolled topcoats. Tables 7.1 through 7.4
show projected emission impacts for the years 1979 and 1985 produced by
alternative pollution control technologies. These tables show the effect
of the phase-in of new technology under each option. It is assumed that 5
percent of the plants per year will come under the new standards.
7U.4.3 Light-duty Trucks
As with automobiles, it is assumed that electrodeposition of
water-borne primers will be the preferred technology, even if no controls
are used. Tables 7.5 through 7.8 show the projected emission impacts for
the years 1979 and 1985 produced by the alternative pollution control
technologies.
7.2 WATER POLLUTION IMPACTS
Water-borne electrodeposited primers are prepared by neutralizing
highly acidic polymers with an alkali (e.g., amines) so that these
polymers can be dissolved or suspended in water. Small amounts of
solvents are also added to increase the dispersibility of polymers in
water.
During electrodeposition the solids coat the automobile or
Hght-duty truck body, leaving alkali coalescing solvents behind in the
dip tank. These solvents must be removed. In modern installations,
ultrafiltration is used to automatically remove water-solubles and
chemical agents that are left behind during the process (see details in
7-10
-------
TABLE 7-1. AUTOMOBILES BASE CASE — EMISSIONS PROJECTIONS'
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surfaced
Uncontrolled Solvent-borne
Water-borne
Topcoat
Uncontrolled Solvent-borne
Water-borne
Totals
1979
% of
Autos
40
60
60
very
small
100
very
small
Emissions
(tonnes/year)
20,090
1,070
7,190
0
72,200
0
-101,000
1985
% of
Autos
10
90
90
very
small
100
very
small
Emissions
(tonnes/year)
5,410
1,730
11,620
0
77,550
0
-96,200
aAssumes no effect of state or local regulations.
''Used with electrodeposition only.
7-11
-------
TABLE 7-2. AUTOMOBILES OPTION 1 — EMISSIONS PROJECTIONS9
Primer
Uncontrolled Sol vent -borne
Electrodeposited Water-borne
Surfaced
Uncontrolled Sol vent -borne
Water-borne
Topcoat
Uncontrolled Solvent-borne
Water-borne
Totals
1979
% of
Autos
40
60
55
5
95
5
Emissions
(tonnes/year)
20,090
1,070
6,590
100
68,600
710
-97,200
% of
Autos
10
90
55
35
65
35
1985
Emissions
(tonnes /year)
5,410
1,730
7,100
750
50,400
5,380
-70,800
aAssumes no effect of state or local regulations.
bUsed with electrodeposition only.
7-12
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TABLE 7-3. AUTOMOBILES OPTION 2 — EMISSIONS PROJECTIONS3
Primer
Uncontrolled Sol vent -borne
Electrodeposited Water-borne
Surfaced
Uncontrolled Solvent-borne
Water-borne
Topcoat
Uncontrolled Sol vent -borne
Incinerated Solvent-borne
Totals
1979
% of
Autos
40
60
60
0
95
5
Emissions
(tonnes/year)
20,090
1,070
7,190
0
68,600
360
-97,300
1985
% of
Autos
10
90
90
0
65
35
Emissions
(tonnes/year)
5,410
1.730
11,620
0
50,400
2,720
-71,900
aAssumes no effect of state or local regulations.
with electrodeposition only.
7-13
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TABLE 7-4. AUTOMOBILES OPTION 3 — EMISSIONS PROJECTIONS3
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surfacerb
Uncontrolled Solvent-borne
Incinerated Solvent-borne
Topcoat
Uncontrolled Solvent-borne
Incinerated Solvent-borne
Totals
1979
% of
Autos
40
60
55
5
95
5
Emissions
(tonnes/year)
20,090
1,070
6,590
60
68,600
360
-96,800
1985
% of
Autos
10
90
55
35
65
35
Emissions
(tonnes/year)
5,410
1.730
7,100
450
50,400
2,720
-67,800
aAssumes no effect of state or local regulations.
bused with electrodeposition only.
7-14
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TABLE 7-5. LIGHT-DUTY TRUCKS BASE CASE — EMISSIONS PROJECTIONS9
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surf acerb
Uncontrolled Solvent-borne
Water-borne
Topcoat
Uncontrolled Solvent-borne
Water-borne
Totals
1979
% of
Autos
40
60
60
very
small
100
very
small
Emissions
(tonnes/year)
3,190
160
1,270
0
13,280
0
-17,900
1985
* of
Autos
10
90
90
very
small
100
very
small
Emissions
(tonnes/year)
1,150
340
2,750
0
19,160
0
-23,400
aAssumes no effect of state or local regulations.
bUsed with electrodeposition only.
7-15
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TABLE 7-6. LIGHT-DUTY TRUCKS OPTION 1 — EMISSIONS PROJECTIONS3
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surf acerb
Uncontrolled Solvent-borne
Water-borne
Topcoat
Uncontrolled Solvent-borne
Water-borne
Totals
1979
X of
Autos
40
60
55
5
95
5
Emissions
(tonnes/year)
3,190
160
1,160
20
12,620
140
-17,300
1985
% of
Autos
10
90
55
35
65
35
Emissions
(tonnes/year)
1,150
340
1,680
180
12,460
1,410
I
-17,200
aAssumes no effect of state or local regulations.
bUsed with electrodeposition only.
7-16
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TABLE 7-7. LIGHT-DUTY TRUCKS OPTION 2 - EMISSIONS PROJECTIONS3
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surfacerb
Uncontrolled Solvent-borne
Water-borne
Topcoat
Uncontrolled Solvent-borne
Incinerated Solvent-borne
Totals
1979
* of
Autos
40
60
60
0
95
5
Emissions
(tonnes/year)
3,190
160
1,270
0
12,620
70
-17,300
1985
% of
Autos
10
90
90
0
65
35
Emissions
(tonnes/year)
1,150
340
2,750
0
12,460
670
-17,400
aAssumes no effect of state or local regulations.
with electrodeposition only.
7-17
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TABLE 7-8. LIGHT-DUTY TRUCKS OPTION 3 ~ EMISSIONS PROJECTIONS3
Primer
Uncontrolled Solvent-borne
Electrodeposited Water-borne
Surfaced
Uncontrolled Solvent-borne
Incinerated Solvent-borne
Topcoat
Uncontrolled Solvent-borne
Incinerated Solvent-borne
Totals
1979
% of
Autos
40
60
55
5
95
5
Emissions
(tonnes/year)
3,190
160
1,160
10
12,620
70
~17,200
1985
X of
Autos
10
90
55
35
65
35
Emissions
(tonnes/year)
1,150
340
1,680
110
12,460
670
-16,400
aAssumes no effect of state or local regulations.
bUsed with electrodeposition only.
7-18
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Section 7.3). Effluent originating from a properly operated
ultrafiltration unit can be adequately handled in municipal or in-house
sewage treatment facilities.
Pollution can result if the electrocoating system allows rinse
water and/or coating to drip or be spilled on the floor and the rinse
and/or clean-up water is not. automatically placed in a reservoir for
treatment. Dragout is especially important in this instance. At the end
of the coating operation, the dipped body is covered with an additional
film of adhering paint called dragout. This film is more porous than the
electrodeposited coating; therefore, it is usually rinsed off. Dragout
also occurs as the body leaves the dip tank. All dragout is returned to
the dip tank or the ultrafiltration system.
Surfacer and topcoats are both applied by spraying. Spraying
operations are carried out in spray booths. With increased attention to
air pollution, the efficiency of particulate removal from spray booths is
of great importance to the automotive industry. Consequently, waterfall
type spray booths of advanced design are becoming more and more prevalent.
Regarding the amount of overspray in a given automotive finishing
operation, expert opinions and estimates vary over a very wide range. The
reason for this is the high dependency of this operation on personal
efficiency; a given operator may work with a high or low overspray
percentage from one occasion to the next. Estimates for overspray run
9 13
from 20 percent to 50 percent*. ' As an average, 35 percent is taken
*Chrysler, realizing the contradictory nature of these figures, puts it at
50 percent as a rule of thumb.
7-19
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as realistic for overspray, with the understanding that water-borne
topcoats tend to yield a higher amount of overspray than do their
solvent-borne counterparts.
Waterfall type booths remove overspray coating particles by means
of a flow of water passing down the face of a sheet of steel located at
the rear and/or sides of the booth — the so-called waterfalls. These
waterfalls flow between 25 and 50 gallons per minute per foot. Thus,
a 20-foot section would have a water flow of approximately 600 gallons per
14
minute. In actual practice, this means that a spray booth 180 feet
long would need between 4,500 and 9,000 gallons of water per minute. A
typical finishing line with four spray booths would need between 18,000
and 36,000 gallons of water per minute.
Solvent-borne topcoats and their overspray are composed primarily
of solvents, which separate readily from water. Water-borne topcoats,
however, are made with water-miscible solvents to assure good suspension
of the resin binder into the water phase of the coating. These various
water-miscible solvents (glycols, and certain esters and alcohols) in
water-borne coatings are extremely miscible with water and actually act as
coupling agents between suspended particles and the water.
The problem with solvents in water is the chemical oxygen demand
(COO). COD Is not, strictly speaking, a pollutant. It is a problem, and
consequently a pollutant, only if it is discharged to a stream in
sufficient concentration and quantity to deplete the oxygen in the stream
and, thereby, affect fish and other aquatic life. Almost all assembly
plants discharge spray booth effluent, following solids removal, to
municipal sewers — some of which have restrictions on COD. The effluent
7-20
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from the two General Motors (California) plants using water-borne topcoats
is acceptable to sewer authorities. If necessary, treatment can be used
tp lower the COD.
No water pollution impact is associated with the other emission
control systems considered as options.
7.3 SOLID WASTE DISPOSAL IMPACT
Water-borne primer EDP operations can have impact on solid waste
disposal. In older installations the dragout and rinse were discarded,
resulting in a waste disposal problem. This also causes coating loss.
Improvements have been made, however,.to reduce coating loss by returning
the coating to the dip tank.
In modern operations, ultrafiltration is used to automatically
remove the amine(s), solvents, and water-solubles, which are left behind
during the electrocoating. Consequently, it is possible to set up almost
a completely closed system with practically no waste problem.
Once a year there is a regular cleaning of the ultrafiltration
system. Otherwise, cleaning is not needed except on such occasions as
when a paper cup or other foreign object is aceidently dropped into the
dip tank. Such a minor cleaning job, however, does not involve more than
a few gallons of paint.
There are no serious solid waste disposal problems associated with
electrocoating. Sludge may develop in the dip tank, leading to a minor
solid waste disposal problem; however, sludge is generally the result of
improperly controlled chemistry in the tank or poor housekeeping (such as
• »
allowing parts to accumulate in the tank). In any case, the amount of
such solid waste is not excessive.
7-21
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Estimates of the exact amounts and compositions of the sludge by
various automotive Industry spokesmen vary over a wide spectrum. This Is
especially true for water-borne topcoats.
There are some basic differences between the treatment of sludge
from solvent-borne coatings and that of water-borne topcoats. Sludge from
water-borne topcoats, in order to break the suspension system and to
remove the particles, is treated with slightly acidic compounds like
calcium acetate at a pH of 3-4. Ultrafiltration could be used to
remove the colloidal particles, but this method is an expensive solution
to the problem.
Actually, the solid waste problem associated with the use of
water-borne coatings is minor when compared with the solid waste
considerations of the total automotive plant. There is little solid waste
impact associated with alternatives other than water-borne coatings.
7.4 ENERGY IMPACT
Automobile and light-duty truck coating operations consume
significant amounts of energy. With the exception of catalytic
incinerators — with primary and secondary heat exchangers used on the
curing oven — all alternative emission control systems require additional
energy. The chief adverse effect of incinerating spray booth exhaust is
the high energy consumption.
The energy impacts associated with each of the alternative emission
control systems outlined in Chapter 6 and discussed in this Chapter are
summarized in Tables 7-9 through 7-16. These tables are a compact
representation and summary of energy balances prepared for the purpose of
comparing the energy required for a base-case finishing model to the
7-22
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TABLE 7-9. ENERGY BALANCE — BASE CASE MODEL AND PROCESS MODIFICATION
Automobile Body Primer Application
Model Description
Solvent-borne primer spray
Base case —
Electrodeposition of
water-borne primer with
solvent-borne surfacerC
Option to base case —
Electrodeposition of
water-borne primer with
water-borne surfacerC
Energy Requirements/211,200 Cars a
Primer
Application
Electricity
kw-hr
1,516,759
7,339,035
8,052,420
Primer Cure Oven
Electricity
kw-hr
383,827
756,045
997,660
Fuel
106 Btu
72,349
142,350
162,600
Total Energy
Requirements
106 Btu
91,354"
223,300
253,101
a211,200 cars -- the yearly output of a model finishing line
bSample calculation: (1,516,759 kw-hr x 10,000 Btu/kw-hr) + (383,827 kw-hr x
10,000 BtuAw-hr) + 72,349 x Ifl6 Btu = 91,354 x 10* Btu.
cEnergy values include energy associated with the surfacer.
7-23
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TABLE 7-10. ENERGY BALANCE -- ADD-ON EMISSION CONTROL SYSTEMS
Automobile Body Primer Application
Model Description
Incinerator on oven only, 10X LEL
Thermal ~ primary heat exchanger
Thermal — primary and secondary
heat exchanger
Catalytic ~ primary heat
exchanger
Catalytic -- primary and
secondary heat
heat exchanger
Incinerator on spray booths onlyd
Thermal — primary heat recovery
Catalytic — primary heat
recovery
Energy Requirements/211,200 Cars a
Emission Control Equipment
Primer Application
Electricity
kw-hr
—
~
«
2,977,920
3,146.880
Fuel
106 Btu
. —
~
—
—
1,267,200
464,640
Primer Cure Oven
Electricity
kw-hr
69,120
80,640
72,960
84,480
—
~
Fuel
106 Btu
9,600
3,070b
1,536
(2,304)c
—
—
Total Energy
Requirements
106 Btu
10,291
3,876
2,266
(1,459)
1,296.979
496,109
a211,210 cars — the yearly output of a model finishing line
^Energy credit from secondary heat recovery is included.
cThe parentheses indicate that the shown amount of energy is a credit.
not include energy for comfort heating of spray booth air
7-24
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TABLE 7-11. ENERGY BALANCE — BASE CASE MODEL AND PROCESS MODIFICATION
Automobile Body Topcoat Application
Model Description
Base Case —
Solvent-borne spray topcoat
Option to Base Case —
Waterborne-spray topcoat
Energy Requirements/211,200 Cars *
Topcoat
Application
Electricity
kw-hr
3.901,555
6,506,737
Topcoat Cure Oven
Electricity
kw-hr
990,624
1,662,798
Fuel
106 Btu
186,041
238,130
Total Energy
Requirements
106 Btu
234,963
319,825
a211,200 cars -- the yearly output of a model finishing line
7-25
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TABLE 7-12. ENERGY BALANCE — ADD-ON EMISSION CONTROL SYSTEMS
Automobile Body Topcoat Application
Model Description
Incinerator on oven only, 10X IEL
Thermal ~ primary heat exchanger
Thermal -- primary and secondary
heat exchanger
Catalytic -- primary heat
exchanger
Catalytic -- primary and
secondary heat
heat exchanger
Incinerator on spray booths onlyd
Thermal -- primary heat recovery
Catalytic — primary heat
recovery
Energy Requirements/211,200 Cars a
Emission Control Equipment
Primer Application
Electricity
kw-hr
--
~
—
~
4,060,800
4,273.920
Fuel
106 Btu
—
«
—
--
1,728,000
633,600
Primer Cure Oven
Electricity
kw-hr
99,840
115,200
103,680
122,880
—
Fuel
106 Btu
13,440
3,840^
2,380
(3.380)C
--
—
Total Energy
Requirements
106 Btu
14,438
4,992
3,417
(2,151)
1,768,608
676,339
•211,210 cars — the yearly output of a model finishing line
^Energy credit from secondary heat recovery is included.
cThe parentheses indicate that the shown amount of energy is a credit.
dDoes not include energy for comfort heating of spray booth air
7-26
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TABLE 7-13. ENERGY BALANCE — BASE CASE MODEL AND PROCESS MODIFICATION
Light-Duty Truck Body Primer Application
Model Description
Solvent-borne primer spray
Base Case --
Electrodeposition of
Mater-borne primer
water-borne surfaced
Option to Base Case —
Electrodeposition of
water-borne primer
water-borne surf acerb
Energy Requirements/145,920 Trucks3
Primer
Application
Electricity
kw/hr
1,240,258
5,153,750
5,8.12,760
Primer Cure Oven
Electricity
kw/hr
349,253
678,250
818,240
Fuel
106 Btu
36,325
82.000
92,100
Total Energy
Requ i rements
106 Btu
52,221
140,321
158.410
a!45,920 trucks — the yearly output of a model finishing line
^Energy values include energy associated with the surfacer.
7-2i7
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TABLE 7-14. ENERGY BALANCE — ADD-ON EMISSION CONTROL SYSTEM
Light-Duty Truck Body Primer Application
Model Description
Incinerator on oven only,
10 X LEL
Thermal — primary heat
exchanger
Thermal — primary and
secondary heat
exchanger
Catalytic -- primary heat
exchanger
Catalytic -- primary and
secondary heat
exchanger
Incinerator on spray booths
Thermal — primary heat
recovery
Catalytic — primary heat
recovery
Energy Requirements/145,920 Trucks3
Primer Application
Electricity
kw/hr
«
~
--
—
1,739,904
1,825,152
Fuel
106 Btu
~
—
~
~
748,800
278,784
Primer Cure Oven
Electricity
kw/hr
46,080
53,760
53,760
61,440
_.
—
Fuel
106 Btu
6,720
2,120t>
1,152
(960)C
__
—
Total Energy
Requirements
106 Btu
7,181
2,658
1,690
(346)
766,199
299,035
a!45,920 trucks -- the yearly output of a model finishing line
"Energy credit from secondary heat recovery is included.
parentheses indicate that the shown amount of energy is a credit.
not include energy for comfort heating of spray booth air
7-28
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TABLE 7-15. ENERGY BALANCE — BASE CASE MODEL AND PROCESS MODIFICATION
Light-Duty Truck Body Topcoat Application
Model Description
Base Case
Sol vent -borne spray
topcoat
Option to Base Case
Water-borne spray topcoat
Energy Requirements/145, 920 Trucks3
Primer
Application
Electricity
kw/hr
3,179,607
5,314,920
Primer Cure Oven
Electricity
kw/hr
«98,329
1,499,080
Fuel
106 Btu
93,405
96,291
Total Energy
Requirements
106 Btu
134,184
164,431
a!45,920 trucks — the yearly output of a model finishing line
7-29
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TABLE 7-16. ENERGY BALANCE — ADD-ON EMISSION CONTROL SYSTEMS
Light-Duty Truck Body Topcoat Application
tl
Model Description
Incinerator on oven only,
10 1 LEL
Thermal — primary heat
exchanger
Thermal — primary and
secondary heat
exchanger
Catalytic — primary heat
exchanger
Catalytic -- primary and
secondary heat
exchanger
Incinerator on spray booths
Thermal — primary heat >
recovery
Catalytic — primary heat
recovery
Energy Requirements/145,920 Trucks3
Primer Application
Electricity
kw/hr
—
--
—
—
2,977,920
3,134,208
Fuel
106 Btu
T™
—
—
~
1,267,200
464,640
Primer Cure Oven
Electricity
kw/hr
69,120
80.640
72,960
84,480
._
--
Fuel
106 Btu
9,600
3,070°
1,536
(2,304)0
..
—
Total Energy
Requirements
106 Btu
10,291
3,876
2,266
(1,459)
1,296,979
495,982
>145,920 trucks -- the yearly output of a model finishing line
^Energy credit from secondary heat recovery is included.
CThe parentheses indicate that the shown amount of energy is a credit.
^Does not include energy for comfort heating of spray booth air
7-30
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energy required when pollution reduction coatings and/or add-on emission
controls are used.
7.5 OTHER ENVIRONMENTAL IMPACTS
Electrodeposited water-borne coatings contain amines that are
driven off during the curing step. Some plants have found it necessary to
incinerate the oven exhaust gas to eliminate the visible emission and
malodors associated with these amines; whereas, other plants have
e •)•)
installed scrubbers for the same purpose. '
No other environmental impacts are likely to arise from standards
of performance for automobile or light-duty truck coating operations,
regardless of which alternative emission control system is selected as the
basis for standards.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Irreversible and Irretrievable Commitment of Resources
The alternative control systems will require the installation of
additional equipment, regardless of which alternative emission control
system is selected. This will require the additional use of steel and
other resources. This commitment of resources will be small compared to
the national usage of each resource. A good quantity of these resources
will ultimately be salvaged and recycled. There are expected to be no
significant amounts of space (or land) required for the installation of
control equipment and/or new coating technology, because all control
systems can be located within little additional space. Therefore, the
commitment of land on which to locate additional control devices and/or
application equipment is expected to be minor.
7-11
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As has been noted, the use of primary and secondary heat recovery
•
Mould enhance the value of Incineration. Without heat recovery,
significant energy would be lost.
7.6.2 Environmental Impact of Delayed Standards
Delay of standards proposal for the automobile and/or light-duty
truck industry will have major negative environmental effects on emissions
of hydrocarbons to the atmosphere and minor, or no, positive impacts on
water and solid waste. Furthermore, there does not appear to be any
emerging emission control technology on the horizon that could achieve
greater emission reductions or result in lower costs than that represented
by the emission control alternatives under consideration here.
Consequently, delaying standards to allow further technical developments
appears to present no trade-off of higher solvent emissions in the near
future for lower emissions in the distant future.
7.6.3 Environmental Impact of No Standards
Growth projections have been presented in earlier sections. It is
obvious that the increased production of automobiles and light-duty trucks
will add to national solvent emissions.
There are essentially no adverse water and solid waste disposal
Impacts associated with the alternative emission control systems proposed
1n this section. Therefore, as in the case of delayed standards, there is
no trade-off of potentially adverse impacts in these areas against the
negative result on air quality which would be inherent with not setting
sTandards.
7-32
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7.7 REFERENCES
1. less, Roy W. "Chemistry and Technology of Solvents; Chapter 44
1n Applied Polymer Science." American Chemical Society,
Organic Coatings and Plastics Division. 1975.
2. DeBell and Richardson Trip Report 102.
3. DeBell and Richardson Trip Report 110.
4. OeBell and Richardson Trip Report 9.
5. DeBell and Richardson Trip Report 112.
6. Strand, R. C. "Waterborne Coatings in Metal Packaging." Paper
presented at NPCA Chemical Coatings Conference, Cincinnati,
Ohio (April 23, 1976).
7. Prane, J. W. "Waterborne Coating Usage ~ Current and Future."
Paper presented at NPCA Chemical Coatings Conference,
Cincinnati, Ohio (April 23, 1976).
8. Brown, R. A. "Water as a Compliance Coating — EPA/OSHA/Waste
Disposal." Paper presented at NPCA Chemical Coatings
Conference, Cincinnati, Ohio (April 23, 1976).
9. DeBell and Richardson Trip Report 56.
10. DeBell and Richardson Trip Report 5 (Overprint Varnishing).
11. EPA Trip Report by V. N. Gallagher (call made with T. Gabris,
September 26, 1975).
12. DeBell and Richardson Trip Report 3.
13. One of the estimated figures given to T. Gabris by Ford Motor
Company representative.
14. Gabris, T. Telephone interview with George Koch Sons, Inc.,
Evansville, Indiana (October 29, 1976).
15 DeBell and Richardson Trip Report 120.
16. Gabris, T. Telephone conversation with one of the California
General Motors plants (October 29, 1976).
17. Gervert, Phil. General Motors Water Pollution Section,
November 2, 1976.
18. DeBell & Richardson, Enfield, Connecticut. Second Interim
Report to EPA to Contract 68-02-2062. Air Pollution Control
Engineering and Cost Study of the Transportation Surface
Coating Industry.
19. Auto News. 1975 Almanac Issue (April 23, 1975). Page 55.
20. Auto News (June 28, 1976).
21. DeBell & Richardson, Enfield, Connecticut. Plastics in the
Automotive Industry., 1975-1985.
22. DeBelland Richardson Trip Report 13.
23. Product Finishing. June 1976. Page 166.
24. Automotive News, Yearbook Issue, 1978.
7-33
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8.0 ECONOMIC IMPACT
Chapter 8 contains four sections. In section one, the role of the
motor vehicle industry in the U.S. economy and the structure of the industry
are described. Two segments of the motor vehicle industry, passenger cars
and light-duty trucks, are identified and characterized. Several aspects
of the two segments are discussed: geographic distribution, concentration
and integration, import/export considerations, demand determinants, price
determination, price leadership, price uniformity, non-price considerations,
price-cost relationships, projected demand, determination of existing capa-
city and of projected capacity needs.
In the second section, control costs and cost effectiveness for alter-
native VOC control systems are developed. Included are costs for controls of
three variations of line speed for cars, and for light-duty trucks.
Section three describes briefly other cost considerations and their
impact on the economic analysis of hydrocarbon emission control systems.
In the final section, the economic impact of alternative emission
control systems is analyzed. Included is an assessment of relative control
oust magnitudes and their impact on prices in the industry.
The major conclusion of Chapter 8, is that the economic impact of
each considered alternative control system is small and that the cost of
NSPS should not preclude construction of new grass roots assembly lines.
8-1
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8.1 Industry Economic Profile
8.1.1 Role of Motor Vehicle Industry in the U.S. Economy
The motor vehicle industry* occupies a key pivotal position in the
U.S. economy. As a substantial consumer of steel, rubber, iron, aluminum,
copper, zinc, lead, and glass, it determines to a certain extent the economic
viability of these major U.S. manufacturing industries. In addition, the
marketing and servicing of motor vehicles has created an infra-structure
equally essential to other segments of the domestic economy, such as the
petroleum industry.
About 2% of the Gross National Product and about 14% of the national
income from durable goods is generated by the motor vehicle industryJ
According to a recent report by a Federal task force, the industry provides
direct employment for 955,000 members of the U.S. labor force. The magnitude
of indirect employment is even more substantial; an additional 3.4 million
Americans owe their livelihood, at least in part, to the existence of the
motor vehicle.2
As a result of increased governmental requirements regarding environ-
mental, safety, and fuel economy standards, the motor vehicle industry has
entered a period of unprecedented technological change. Concommitantly,
strong competition is present from the import sector of the market. The
ability of the industry to cope with these and other exogenous constraints,
*The term "motor vehicle industry" is used in this section to denote machine
tool, parts and components, and assembly segments of the industry, regardless
of vehicle type; in the following sections of this chapter the vehicle types
considered are only passenger cars and light trucks, and the industry seg-
ments are broadened to include marketing and servicing.
8-2
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such as changes in consumer taste, will determine whether the present role
of the motor vehicle industry remains the same or is altered.
8.1.2 Structure of the Industry
8.1.2.1 Coiicentration
The production of automobiles and light-duty trucks in the United
States represents one of the nation's most concentrated industries. Three
companies, General Motors Corporation, Ford Motor Company, and Chrysler
Corporation, have accounted for most of the industry's production almost
since its inception. The merger of two independents in 1954 resulted in
the formation of American Motors Company, which subsequently became the
fourth-ranking firm in the industry. Whether measured by capitalization,
sales, profits, breadth of product line, or number of distribution outlets,
General Motors is the dominant firm in the industry, followed by Ford,
Chrysler, and American Motors, in that order.
Historically, many other firms have attempted to enter the market
but have not been successful in the long-run. Checker Motors, Interna-
tional Harvester, and Volkswagen currently participate in the market, but
only on the periphery.
The automobile and light-duty truck industry is of such magnitude
that it could conceivably accomodate a number of competitive firms in its
structure. The fact that four firms have consistently comprised almost
the entire industry suggests that they have acquired resources that have
not only permitted them to survive, but have also forestalled the success-
ful entry of other firms into the industry. However, a Canadian task force
8-3
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reviewing the North American automotive industry reached the conclusion
that there is no evidence that there has been any attempt to limit compe-
tition despite the fact that it is virtually impossible for a new company
to enter the motor vehicle market because of very high development and
start-up costs.3 Nevertheless, the degree of vertical and horizontal
integration present within the industry reflects the influence of these
resources.
8.1.2.2 Integration
i
Vertical integration within the industry is obvious and well-defined,
Pre-production integration for some of the firms extends as far as captive
iron and steel foundries, which provide the raw materials for component
parts. Integration at the production level is largely achieved through
captive establishments that supply many of the engines, transmissions,
fabricated parts, and other major components required for body and final
assembly. Post-production integration extends to franchised dealers who
distribute the product and to subsidiary companies that finance consumer
purchases. Post-market integration exists in the form of franchised repair
and supply facilities.
Horizontal integration is reflected in the firms' interests in the
manufacture of non-automotive products such as boats and farm equipment.
Revenue from these activities does not constitute a significant portion
of total revenues, however.
8-4
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8.1.2.3 The U.S.-Canada Automotive Agreement
The working relationship between the United States and Canada that
began with implementation of the U.S.-Canada Automotive Products Agreement
in 1965, in essence established a free trade zone between the two countries.
It allowed the then-established U.S. automotive firms freedom of access to
Canadian labor and consumer markets, and, through restrictive clauses in the
Agreement, ensured the perpetuation of the Canadian automotive* industry. In
effect, only General Motors, Ford, Chrysler, and American Motors are partici-
pants in the Agreement; Canada holds the right to impose tariffs on any other
firms seeking to establish trade in the Canadian sector. To the extent that
Canada chooses to exercise that right, Volkswagen's entry into the Canadian
sector of the industry is constrained. The Agreement has no time limit, but
either government may terminate it on 12 months' notice. The net effect of
the Agreement has been to provide an integrated North American motor vehicle
industry and market. Consideration of the U.S. domestic motor vehicle indus-
try in this study takes into account available Canadian resources and the
reciprocal drain on U.S. production by Canadian demand.
8.1.2.4 Geographic Distribution
At the beginning of 1978, passenger cars and light-duty trucks** were
*The term "automotive industry" as used here includes both automobile and
truck production.
**The term "light-duty truck" is defined in Chapter 3 of this report as: "all
vehicles with ratings of 8,500 pounds or less GVW". Included in this classi-
fication are pick-up trucks, vans, panel trucks, station wagons built on pick-
up truck chassis, multi-stop trucks, and off-road vehicles.
8-5
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being assembled at 51 and 31 locations, respectively, in the United States
and Canada. Total reported outputs from these plants in 1977 were 10,095,364
passenger cars and 3,455,504* light-duty trucks.4 A listing of North American
passenger car assembly locations by firm, is shown in Table 8-1 and light-duty
truck locations, by firm, in Table 8-2.
Traditionally, production facilities have been centered in the Great
Lakes region because of the availability of transportation for component
parts to production facilities, and for finished products from production
facilities. However, differentials in labor costs and overhead have resulted
in more recently built plants being located in non-traditional areas such as
the southwestern part of the United States.
Recent industry growth continues to follow this pattern. Volkswagen.,
a newcomer to the domestic passenger car industry, began operations in New
Stanton, Pennsylvania in March of 1978. In Oklahoma, General Motors has
begun construction of its first new car assembly plant in 14 years. This
plant is scheduled to become operational for model-year 1980. Another
plant being constructed by General Motors in Shrevesport, Louisiana, is
expected to be producing light-duty trucks by 1981.
Extensive retooling of existing plants by several of the firms in
the industry is planned in response to the need for compliance with energy,
safety, and environmental standards set by the government.
*Lack of specificity in Canadian data required estimation of light-duty
truck production. This figure assumes light-duty truck production to
be 90% of total truck.production.
8-6
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Table 8-1
NORTH AMERICAN AUTOMOBILE ASSEMBLY LOCATIONS
1977
Manufacturer
General Motors Corporation
Plant Location
Arlington, Texas
Baltimore, Maryland
Detroit, Michigan
Doravilie, Georgia
Fairfax, Kansas
Flint, Michigan (2)
Framingham, Massachusetts
Fremont, California
Janesvill.e, Wisconsin
Lakewood, Georgia
Lansing, Michigan
Leeds, Missouri
Linden, New Jersey
Lordstown, Ohio
Norwood, Ohio
Pontiac, Michigan
South Gate, California
St. Louis, Missouri
N. Tarrytown, New York
Van Nuys, California
Willow Run, Michigan
Wilmington, Delaware
Oshawa, Ontario
St. Therese, Quebec
Ford Motor Company
Atlanta, Georgia
Chicago, Illinois
Dearborn, Michigan
Kansas City, Missouri
Lorain, Ohio
Los Angeles, California
Louisville, Kentucky
Mahwah, New Jersey
Metuchen, New Jersey
San Jose, California
St. Louis, Missouri
Twin Cities, Minnesota
Wayne, Michigan
Wixom, Michigan
Oakville, Ontario
St. Thomas, Ontario
8-7
-------
Table 8-1 (continued)
Manufacturer
Chrysler Corporation
American Motors Company
Checker Motors Company
Plant Location
Belvidere, Illinois
Hamtramck, Michigan
Detroit, Michigan (2)
Newark, Delaware
St. Louis, Missouri
Windsor, Ontario
Kenosha, Wisconsin
Brampton, Ontario
Kalamazoo, Michigan
Source: Ward's Automotive Yearbook, 1978.
8-8
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Table 8-2
NORTH AMERICAN LIGHT-DUTY TRUCK ASSEMBLY LOCATIONS
1977
General Motors
Arlington, Texas
Baltimore, Maryland
Doraville, Georgia
Fremont, California
Janesville, Wisconsin
Lakewood, Georgia
Leeds, Missouri
Lordstown, Ohio
St. Louis, Missouri
Flint, Michigan
Oshawa, Ontario
Scarborough, Ontario
American Motors
Toledo, Ohio
South Bend, Indiana*
International Harvester
Fort Wayne, Indiana
Ford
Atlanta, Georgia
Avon Lake, Ohio
Kansas City, Missouri
Lorain, Ohio
Louisville, Kentucky
Mahwah, New Jersey
Wayne, Michigan
San Jose, California
Norfolk, Virginia
Ontario Truck, Ontario
Oakville, Ontario
Chrysler
Warren, Michigan
Fenton, Michigan
Pilette Road, Ontario
Tecumseh Road, Ontario
*This plant, operated by A.M. General Corp., a subsidiary of American
Motors, is used for military and postal vehicle production.
Source: Ward's Automotive Yearbook, 1978, pp. 74, 126.
8-9
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8.1.2.5 Import/Export Considerations
8.1.2.5.1 Imports
Import penetration of the United States new car market began in
earnest with the introduction of the Volkswagen Beetle in the late 1950's.
By 1958, the economic climate resulting from the 1957-1958 recession, and a
lack of small car production on the part of the domestic manufacturers,
combined to make possible the capture of over 10% of the market by foreign
imports.* This initial success was almost immediately offset, however, by
a series of events that, for.a time at least, returned the competitive edge
to domestic manufacturers. One of these events was the introduction of com-
petitively designed small cars into the domestic automobile lines. Another
event was the recovery of the U.S. economy from the 1957-1958 recession,
which brought with it an increased demand for larger, more expensive cars.
The third event was the entry into the U.S. market of imports that proved .
unsatisfactory for American driving habits, and for American standards of
maintenance and service. This resulted in a severe setback in the American
public's confidence in, and acceptance of, foreign cars in general.
Throughout the 1960's the trend in consumer purchases was toward large
cars. ' Domestic manufacturers virtually abandoned the small-car concept. As
a result, the share of the market for imports increased steadily. Japan's
successful entry into the market in 1965 was a major milestone in import
growth. Volkswagen sales had peaked by 1970, but Japanese imports continued
*For purposes of this study, the term "foreign imports" is used to denote
vehicles manufactured outside of North America.
8-10
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to grow. Despite Detroit's attempts to fight back by introducing subcompacts
such as the Pinto and Vega in 1971, and despite the devaluation of the dollar
relative to Japanese and German currency after 1971, the trend in favor of
imports continued. Market share for imports peaked at 18.2% in 1975, declined
to 14.8% in 1976, and rose again to 18.5% in 1977.
Imports have had a lesser impact on the light-duty truck market than
on the new car market. In five of the last eight years, the import share of
the light-duty truck market has hovered between 8% and 9%, never rising above
11.2%. The inability of foreign manufacturers to penetrate the domestic market
more extensively may be explained to some degree by restrictive tariffs that
have been imposed on the importation of fully assembled light-duty trucks.
The degree of import penetration in the light-duty truck market becomes
even less pronounced when the behavior of captive imports is considered. These
have been commanding a larger share of the import market for several years.
However, there is some doubt as to whether this trend will continue as the
upcoming fuel economy standards for light-duty trucks raises the question of
whether the required method of computing corporate mileage will include or
exclude captive imports.
Recently, importers who have done well with light-duty trucks have
begun exploring the possibilty of making, new breakthroughs in the heavy-
duty truck market, based on an anticipated changeover from gas to diesel
power. This poses a new threat to Ford and International Harvester, who
are currently the leaders in heavy-duty truck production, and might well
lead to their more aggressive participation in the light-duty truck market.
The future of the import influence on the domestic market has two
perspectives. Some analysts predict that the import share of the market
8.-11
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will continue to rise because foreign manufacturers, reassured by continued
positive sales performance, will consider establishing manufacturing opera-
tions in the U.S. This prediction would appear to be supported by the fact
that in September, 1977, Honda Motor Company of Japan revealed plans for the
construction of a motorcycle plant in the United States, with car assembly
the obvious next step.5 The manufacturers of Toyota and Datsun, two leading
Japanese imports, are also studying the possibility of establishing U.S.
assembly facilities.
Critics of this viewpoint believe that the establishment of new
facilities in the U.S. by foreign manufacturers need not imply further
erosion of domestic market shares. They contend that the market share
attributable to the new facility may come from the present share held by
the same manufacturer. Some critics go even further and argue that import
penetration is transient. The influence of government regulations regarding
emission control, passenger safety, and fuel economy, and the narrowing of
price competition between imports and domestic cars are seen as factors that
will return a portion of the import market share to existing domestic manu-
facturers. In support of this contention, a review of the North American
auto industry undertaken by the Canadian government in 1977 came to the con-
clusion that the tide of imports in the .North American market "has peaked
and the global industry has reached equilibrium."6
8.1.2.5.2 Exports
United States exports of finished cars to any country other than
Canada are practically negligible. Not only have most other countries
8-12
-------
erected and maintained formidable trade barriers in this regard, but there
is also little evidence that, even without these barriers, there would be
any significant market there for United States cars. Therefore, U.S. car
manufacturers have so far elected to put little emphasis on exports, per
se, preferring instead to invest directly in car production plants, located
within the countries themselves, for the production of European-type cars.7.
Exports are only a minor portion of U.S. truck sales, never having exceeded
100,000 units in any single year.8
8.1.2.6 Demand Determinants
Demand for new cars and light-duty trucks is a fluctuating pheno-
menon that reflects the influence of several classical determinants of
demand. Consumer personal disposable income, consumer expectations, price,
the availability of substitute goods, and consumer taste may all influence
demand.
Income. The conclusion of most reseachers has been that personal
disposal income is the most important demand determinant.9 when consu-
mers are prosperous, car and light-duty truck sales tend to increase. When
recession, inflation, high unemployment, and general economic uncertainty
have been present, consumers have hesitated to purchase vehicles. A rise
in car ownership by household tends to accompany a rise in real income.
At high income levels, a saturation in the demand for additional automobiles
is evident, with further income increases producing very little change in
auto ownershipJO
8-13
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Expectations. Closely related to income is the consumer's expecta-
tions regarding the behavior of prices in relation to his anticipated income.
Reflected in the increasing volume of car and light-duty truck sales is the
expectation that prices will escalate more rapidly than personal income. To
the extent that this is so, consumers tend to replace vehicles before antici-
pated price increases.
Price. Price also influences consumer demand for new vehicles. If
price is increased, the quantity of cars or trucks demanded in the short
run will fall as consumers postpone their purchase or turn to a substitute
goodJ1
It should be noted that the demand for high-priced cars is less
responsive to increased prices than is the demand for lower-priced carsJ2
The consumer of the high-priced car will, as a general rule, postpone his
purchase, but will not turn to a substitute good. However, consumers of
lower-priced cars may downgrade their purchase^ or may substitute a used
car or a lower-priced import. Therefore, price differentials are extremely
important in this area of the new car market. Price differentials are also
extremely important in the light-duty truck market, since consumers can
substitute either used or imported vehicles.
Substitute Goods. Viable substitutes for passenger cars and light-
duty trucks include imported vehicles, used vehicles, and substitutions
within and among model classes. Within certain settings, the accessibility
of public transportation is also a factor. Imports and substitutions within
and among model classes provide perfect substitutes for new vehicles. Used
8-14
-------
cars provide the consumer with a wide range of close substitutes. Public
transit systems, taxicabs, rental vehicles, and commercial delivery services
substitute only in metropolitan settings.
Taste. As a determinant of demand, consumer taste is the most fickle,
subjective, and non-quantifiable. Taste is comprised, among other things,
of design, styling, size, brand loyalty, self-image, and status. Its influ-
ence is demonstrated by the recent trend away from the purchase of family
cars and toward the purchase of vans and other light trucks for recreational
use and leisure activities. It has been estimated that approximately 500,000
light-duty truck sales represent substitution sales for passenger cars in this
past model year.14
8.1.2.7 Pricing Procedures
8.1.2.7.1 Price Determination
Pricing practices in the industry appear to substantiate the post-
Keynesian economic theory that "the pricing behavior of oligopolistic firms
in the manufacturing sector of industrialized capitalist economies can be
explained by the demand for funds from internal sources for purposes of
investment expenditures."15 in theory, current actual costs are not
used in pricing, and no attempt is made to maximize the rate of return in
any single year. Demand is a factor in production rather than pricing,
in that the immediate response to either increased or decreased demand is
accelerated or decelerated production rather than higher or lower price.
Thus, pricing to achieve a target rate of return is concerned with funding
8-15
-------
requirements for planned investment expenditures rather than current cost
or demand conditions.
Over the years, General Motors has had the discretionary power to
establish prices for its products that have generated sufficient cash flow
to finance internally much of the investment expenditures it has undertaken.
The pricing method used by General Motors is to project unit costs (direct
labor and materials, plus unit overhead) on the basis of a "standard" volume
(about 80% of capacity) and then add on a profit margin designed to yield
a target rate of return sufficient to support long-range capacity and expan-
sion objectivesJ6
Ford, Chrysler, and American Motors consider cost plus a reasonable
profit as their base selling price. Ceiling prices have been set by pricing
as close to the competition as possible.17
8.1.2.7.2 Price Leadership
The dominance of General Motors in the industry is evident in the
\
40% to 50% share of the domestic market it has held since 1931. This strong
market share provides a basis for price leadership in the industry. While the
role of first announcing price appears to be about equally divided between
General Motors, Ford, and Chrysler, it is apparent that Ford and Chrysler
frequently attempt to anticipate and follow the pricing actions of General
Motors, and, when necessary, to back-adjust.
A clear example of the latter type of movement occurred in September,
1956, when Ford announced a suggested price list for 1957 models that en-
tailed an average 2.9% increase over 1956 models, ranging from $1 to $104
8-16
-------
per model. Two weeks later, General Motors announced an average 6.1%
increase over 1956 prices for its Chevrolet models, with price increases
ranging from 550 to $166 per model. Within the week, Ford had revised
its prices upward so that on ten models the price differential with Chev-
rolet was only SI to $2. A week later, Chrysler announced the price of
Plymouths at approximately $20 higher than Chevrolet, consistent with
Chrysler's traditional pricing patternJS
More recently, in response to the government's voluntary price decel-
eration program, General Motors announced that it would move away from the
industry's usual practice of raising car prices once a year, and v/ould, in-
stead, raise prices whenever it was deemed appropriated9 In setting this
new pricing trend, General Motors suggested that it would be able to keep
price rises over the 1978 model year at about 5% to 5.5% compared with the
6% average boosts of the past two years. While neither Chrysler nor Ford
has made any such commitment, a spokesman for Chrysler stated that "any
pricing action in the future would continue to depend on the competitive
situation and other factors."
8.1.2.7.3 Price Uniformity
Historically, list price differentials among different manufacturers'
models in the same model class have tended to be small. Similarly, price
differentials in the cost of accessories, options, and the hundreds of pos-
sible combinations of models/accessories are slight. The uniformity in
pricing in these areas reflects the fact that General Motors has nearly
half of the total market and twice the share of its nearest competitor,
thereby effectively ruling out price competition within the industry.
8-17
-------
8.1.2.8 Non-Price Competition
In the North American automobile and light-duty truck market, much of
the demand for vehicles is replacement demand. Because the purchase of a new
vehicle is a deferrable item, and because perfect and close substitutes are
available, manufacturers have had to develop strategies that ensure the con-
stant stimulation of replacement sales. With the virtual disappearance of
price differentials as a factor of competition, these strategies take the
form of non-price competition such as frequent design and styling changes,
aggressive and imaginative marketing techniques, and dealer-buyer incentive
programs.
Major design and styling changes are introduced by manufacturers every
few years, with more modest changes in trim and styling occurring in the inter-
vening years. To the extent that consumers see their vehicles as symbols of
affluence, as a means of acquiring distinction, or as an expression of person-
ality, these changes move them toward vehicle replacement.
Aggressive marketing techniques are evident in the public image each
firm has established. Over the years, General Motors has maintained the
strategy of advertising a "car for every price and purpose", and with its
breadth of product line and range of options and accessories, it has managed
to capture approximately 60% of the full-sized and intermediate-sized car
markets and to capture about 30% of the compact and sub-compact market.
Ford's marketing strategy has been built on the concept of "basic
transportation". Although Ford produces competitive models in all model
classes, its greatest successes have been realized in the small car market.
However, in recent years, Ford has elected to maintain a line of full-sized
and luxury cars as competitive alternatives to General Motor's downsizing
8-18
-------
of all of its models. Ford's marketing strategy is apparently aimed at
capturing that portion of the consumer market that elects to remain with
a full-sized car or that refuses to pay a full-size price for an inter-
mediate-sized car. Recently, Ford's share of the full-sized market has
ranged between 25% and 30%.
Chrysler's traditional marketing stance has been to build its image
on superior engineering. While its products cover all model classes, Chrys-
ler's historical appeal has been to the luxury and full-sized car market. It
has consistently priced its vehicles higher than those of its competitors,
maintaining that they "are worth more, perform better, and have better engi-
neering". In recent years, Chrysler's share of the full-sized market has
declined from 15% to about 10%, and this year, for the first time, Chrysler
has moved into the domestic production of subcompacts with the introduction
of the Omni and Horizon models.
American Motors' historical strategy has been to produce cheap, eco-
nomical, small cars. In the years in which the firm has departed from this
strategy, sales have declined radically. Currently, American Motors has
begun to concentrate its efforts in the compact and subcompact areas and
to increase advertising of its Jeep products, which have consistently been
successful.
Dealer-incentive programs include special sales campaigns that provide
cash bonuses to dealers who exceed their sales quotas, special product promo-
tions in which optional equipment is sold at reduced prices, and merchandise
or trip prizes to outstanding salesmen or sales managers. Buyer-incentive
programs include cash rebates on new vehicle purchases, special pricing on
optional equipment, expansion of warranty items, and extensions of warranty
periods.
8-19
-------
8.1.2.9 Price-Cost Relationships
The price-cost margin, or profitability of sales, depends upon factors
such as vehicle mix and the ability of the firm to recover cost increases.
Because the industry is capital-intensive, fixed costs are high. Therefore,
even a small change in unit volume will cause revenues to vary. As sales
decline, the profit margin becomes narrower. Characteristically, the industry
does not respond with a decrease in price in order to stimulate sales. To
the extent that prices are held constant, increases or decreases in quantity
of the product demanded will widen or narrow the profit margin.
In the 1972-1973 model year, sales in the industry peaked, and the
profit position of the industry was maximized as the difference between costs
and revenues widened. The subsequent decline in the market in response to
the energy crisis produced by the Arab oil embargo did not result in a price
decrease to induce greater sales volume. The industry practice of costing on
a constant input basis, coupled with volume production, causes the implemen-
tation of price changes to take as long as two years. Therefore, the sales
decline in 1974-1975 did not occasion a cut-back in prices to stimulate sales.
Rather, production was cut back, and the industry waited for the market to
recover. As a result, that year was characterized by a substantial narrowing
of the profit margin, and reduced profitability.
It becomes apparent that the wider the profit margin of a manufacturer,
the more flexibility he has in dealing with fluctuations in demand, changes
in the costs of inputs, and in establishing prices. However, profit margins
become critical for companies that hold smaller shares of the market, such
as American Motors and Chrysler Corporation. To the extent that prices must
8-20
-------
remain competitive, and because of the cost-revenue relationship, profit-
ability for these companies becomes a matter of achieving a delicate balance.
At the point where costs and revenues converge, or when costs exceed revenues,
the long-run financial position of both companies will need to be such that
long-run target profits can be met or external funds can be generated to
finance capital expenditure demands of the company.
8.1.3 Projected Demand
Using current market shares and number of U.S. new car and light-
duty truck registrations as the basis, United States demand for new cars
and light-duty trucks was projected through 1983 for each individual firm.
For passenger cars, an annual industry growth of 3% was accepted as
the "most likely" value from a range of estimated rates encountered in the
course of research for this project. The upper limits of the range were 3.5
- 4% and the lower limits were 1.8 - 2%. For trucks, an annual growth rate
of 4.5% was accepted as the "most likely" value in a range of values from 3%
to 6% suggested by authorities from both the public and private sectors of
the economy.
Historical demand in Canada for new cars and for new light-duty trucks
was examined in relation to historical demand in the United States. On the
basis of the observed relationship, Canadian demand through 1983 was projected
for the same time period as 10% of the United States demand for new cars,
and 11% of United States demand for light-duty trucks. Existing shares of
the Canadian market were assumed to remain constant over the next five
years for both cars and light-duty trucks.
8-21
-------
United States demand and Canadian demand were combined to obtain
total North American projected demand for new passenger cars (see Table
8-3) and for light-duty trucks (see Table 8-4).
8.1.4 Determination of Existing Capacity
Estimates of existing production capacity for cars and for light-
duty trucks were derived for each of the firms in the industry and are
shown in Tables 8-5 and 8-6. For both cars and trucks, the basic formula
used to measure production capacity for each firm was: (optimal line
speed x number of final assembly lines) x (number of shifts x number of
working days per year).
Optimal line speed is considered to be the optimal rate at which an
automobile or truck assembly line can produce vehicles when the production
rates of components and subassemblies are adjusted to-be totally compatible.
In accordance with the findings described in earlier chapters of this study,
constant line speeds of 55 cars per hour and 38 trucks per hour were entered
into the capacity formula. It is recognized that not every line in every
company will operate at the accepted line speed; some will operate at a
higher rate ana others at a lower rate. Endogenous constraints such as the
age of plants and equipment and the type and complexity of vehicle mix on a
line are present. Also present are exogenous constraints such as the seasonal
and cyclical nature of consumer demand. The accepted values represent best
estimates of average car and truck optimal line speeds for the industry.
8-22
-------
Table 8-3
U.S. AND CANADIAN PROJECTED DEMAND
oo
1
ro
u>
FOR
NORTH AMERICAN-MADE PASSENGER CARS*
(Thousands of Units)
Manufacturer** 1978 1979 1980
General Motors Corp. 5,576 5,743 5,916 6
Ford Motor Co. 2,731 2,812 2,896 2
Chrysler Corp. 1,428 1,471 1,515 1
American Motors Co. 211 218 225
Totals 9,946 10,244 10,552 10
1978-1983
1981 1982
,093 6,277
,983 3,073
,561 1,608
232 238
,869 11,196
1983
6,464
3,165
1,657
245
11,531
*Exports by U.S. manufacturers have not been included.
**Checker Motors, which produces for a specialized market, has a projected demand of 5,576
units in 1983.
Volkswagen's new car assembly plant in New Stanton, PA, became operative in March, 1978;
sufficient sales data to project demand for 1983 is not yet available.
-------
00
f\i
-p.
Table 8-4
PROJECTED U.S. AND CANADIAN DEMAND
FOR
NORTH AMERICAN-MADE
LIGHT-DUTY TRUCKS
1978-1983
Manufacturer
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
American Motors Co.
Internat'l Harvester Co.*
Totals
(Thousands
1978 1979
1,526 1,598
1,220 1,276
544 568
128 135
34 36
3,453 3,609
of Units)
1980 1981 1982
1,666 1,741 1,819
1,333 1,396 1,455
593 619 648
141 147 154
37 39 41
3,771 3,939 4,117
1983
1,902
1,521
676
160
43
4,302
^Estimates are for U.S. demand only.
-------
Table 8-5
ESTIMATED PASSENGER CAR PRODUCTION CAPACITY
IN NORTH AMERICA
1978
Manufacturer
No. of Final Assembly Lines
in U.S. and Canada
Estimated Capacity
(Thousands of Units)
CO
l\3
U1
General Motors Corp.
Ford Motor Co.
Chrysler Corp.
American Motors Co.
29*
16
7**
2**
6,124
3,379
1,478
422
Checker Motors Corp.
Volkswagen of America, Inc.
211
211
*A new passenger car assembly plant in Oklahoma, presently under construction, is planned
for 1980. Total capacity is estimated to increase by 211,200 units, bringing the total
to 6,336,000 units.
**Allowance has been made in this Table for the 1978 conversion to light-duty truck assembly
of one Mne each for Chrysler and American Motors, and capacity estimates have been reduced
accordingly.
-------
a\
Table 8-6
ESTIMATED LIGHT-DUTY TRUCK PRODUCTION CAPACITY
IN NORTH AMERICA
1978
Manufacturer No. of Final Assembly Lines Estimated Capacity
in U.S. and Canada (Thousands of Units)
General Motors Corp. 11* 1,605
Ford Motor Co. 9 1,313
Chrysler Corp. 5** 729
American Motors Co. 3*** 437
Internat'l Harverster Co. 1 145
*A new General Motors plant in Shrevesport, Louisiana has been planned for 1981. Estimated
capacity should increase by 145,000 units, bringing the total to 1,750,000 units.
**Chrysler will cease light-duty truck production in its Tecumseh Road plant in 1979; this
plant will be used for sub-assembly operations. The Jefferson Avenue plant will be con-
verted in 1978 to light-duty truck production. It is assumed one change will offset the
other.
***American Motors will retool its Brampton, Ontario plant in 1978 for light-duty truck
production. The estimate presented here reflects this change.
-------
Number of lines per company is proprietary information. Data used
for this component of the formula were estimated from public .sources such
as Ward's Automotive Yearbook and Automotive News, and the results were
compared with other studies reporting similar information. Estimated
number of lines per company reflects line usage for both automobile and
light-duty truck production.
Number of shifts was established as a constant value of 2. It is
understood that number of shifts may vary in response to consumer demand.
This value was entered into the formula as representative of the industry.
Number of working days per year was established as a constant value
of 240. This number is consistent with findings in earlier chapters, of this
study and reflects downtime required for maintenance, inventory, retooling
for model changeover, vacation, and variations in labor skill.
a
8.1.5 Determination of New Sources
A company-by-company determination of new source requirements* was
made, and it was concluded that General Motors will require an additional
passenger car line by 1983 and one additional light-duty truck line by
1982; Ford will need one additional light-duty truck line by 1980; and
Chrysler will need one additional passenger car line by 1980.
*"Mew source", as used in this study, is defined as the new grass roots
capacity necessary to fill the gap between projected demand and existing
capacity.
8-27
-------
As demand at each firm exceeds present capacity, the firm may elect
to build a new line. Alternatively, a firm may increase capacity by modi-
fying or reconstructing an existing line. For example, Chrysler may choose
to continue its announced program of gutting and refitting existing plants
in order to increase production capacity to meet projected demand.20
A second alternative for each firm would be to construct the new
line in Canada, where environmental standards are currently somewhat less
stringent. However, the economic analysis in this study assumes that if
new lines are built, they will be built in the United States and will be
impacted by New Source Performance Standards.
8-28
-------
REFERENCES
1. Impact of Environmental, Energy, and Safety Regulations and of Emerging
Market Factors Upon the United States Sector of the North American Auto-
motive Industry, Office ofBusiness Research and Analysis, Bureau of
Domestic Commerce, Domestic and International Business Administration,
U.S. Department of Commerce, Washington, DC, August 1977, p. 3-1.
2. Review of the North American Automotive Industry, Automotive Task Force,
Department of Industry, Trade and Commerce, Ottawa, Canada, April 1977,
p. 72.
3. Ibid., p. 26.
4. Automotive News: 1978 Market Data Book Issue, pp. 37, 42, 43.
5. Hard's Automotive Yearbook, 1978, p. 16.
6. Department of Industry, Trade and Commerce, Op. Cit., p. 199.
7. Impact of Trade Policies on the U.S. Automobile Market, Charles River
Associates, October 1976, pp. 33, 34.
8. U.S. Industrial Outlook 1978, Department of Commerce, p. 159.
9. "The Automobile Industry", Robert F. Lanzillotti, The Structure of
American Industry, 4th Edition, Walter Adams, Editor, The Macmillan
Company, New York, 1971, pp. 276, 277.
10. Office-of Business Research and Analysis, U.S. Department of Commerce,
Op. Cit., p. 8-3.
11. Data and Analysis for 1981-1984 Passenger Automobile Fuel Economy
"STandards: Document 1, Automobile Demand and Marketing, Office of
Automotive Fuel Economy, U.S. Department of Transportation, February
28, 1977, p. A-l.
12. Marketing and Mobility: Report of a Panel of the Interagency Task
Force on Motor Vehicle Goals Beyond 1980, The Panel on Marketing
and Mobility, Office of the Secretary of Transportation, Washington,
DC, March 1976, p. 2-196.
13. Ibid.
14. U.S. Industrial Outlook 1978, Department of Commerce, p. 157.
15. "Pricing in Post-Keynesian Economics", Peter Kenyon, Challenge,
July-August 1978, p. 45.
8-29
-------
16. Office of Automotive Fuel Economy, U.S. Department of Transportation,
Op. Cit., pp. 3-71/3-75.
17. Ibid., pp. 3-75/3-79.
18. Robert F. Lanzilloti, Op. Cit., p. 282.
19. The Wall Street Journal, June 27, 1977, p. 1.
20. "Chrysler's Downhill Plunge in Market Shares", Fortune, June 19, 1978,
p. 58.
8- 30
-------
8.2 COST ANALYSIS
8.2.1 Introduction
To determine the costs of controlling.emissions.of volatile
organic compounds (VOC) associated with the painting of automo-
biles and light-duty trucks, alternative control systems were
applied to selected typical plant sizes. Estimated costs were
then plotted on graphs to represent the control option costs for
varying plant capacities. The costs of the control options rep-
resent those additional expenditures over the base case, in which
electrodeposition (EDP) is used for the prime coat, solvent-borne
coatings are used in the guide-coat and topcoat operations, and
VOC emissions are not controlled. Figure 8-1 shows the available
control options. The cost estimates developed herein are study
estimates with an expected range of ± 30 percent. They are
limited to new coating facilities.
To represent the varying capacities of the assembly plants,
the following three line speeds were selected from a range of
actual industry production rates for automobiles and light-duty
trucks:
Vehicle type
Automobile
Light-duty truck
Line speed, vehicles/h
3-31
-------
OPTIONS
CO
CO
r>o
VOC EMISSIONS
REDUCTION, %
ENAMEL
LACQUER
PRIME
COAT
GUIDE-COAT
SPRAY BOOTHS
OVENS
TOPCOAT
SPRAY BOOTHS
OVENS
BASE
CASE
0
0
ELECTRO-
DEPOSITION
1
UNCONTROLLED
1
UNCONTROLLED
1
UNCONTROLLED
1
UNCONTROLLED
IAa
81
92
ELECTRO-
DEPOSITION
1
USE OF
WATERBORNE
PAINT
1
USE OF
WATERBORNE
PAINT
1
USE OF
WATERBORNE
PAINT
1
USE OF
WATERBORNE
PAINT
IB-Ta
77
85
ELECTRO-
DEPOSITION
1
UNCONTROLLED
1
UNCONTROLLED
1
THERMAL
INCINERATOR
1
THERMAL
INCINERATOR
IB-Ca
77
as
ELECTRO-
DEPOSITION
UNCONTROLLED
UNCONTROLLED
CATALYTIC
INCINERATOR
CATALYTIC
INCINERATOR
II-T
90
90
ELECTRO-
DEPOSITION
1
THERMAL
INCINERATOR
1
THERMAL
INCINERATOR
1
THERMAL
INCINERATOR
1
THERMAL
INCINERATOR
II-C
90
90
ELECTRO-
DEPOSITION
1
CATALYTIC
INCINERATOR
1
CATALYTIC
INCINERATOR
1
CATALYTIC
INCINERATOR
1
CATALYTIC
INCINERATOR
Figure 8-1. Available options for control of VOC emissions
due to the painting of automobiles and light-duty trucks.
Emissions reductionc are rounded and vary from automobile to light-duty truck facilities,
-------
It is assumed that vehicle manufacturers using solvent-borne
lacquers require three topcoat lines, those using solvent-borne
enamels require two topcoat lines, and those using waterborne
paints requires two topcoat lines. For a given plant it is also
assumed that all the topcoat lines are identical in length.
Because vehicle size directly affects potential VOC emissions,
emission calculations are based on an average body size and paint
thickness. Table 8-7 presents average solvent-borne paint usage.
Uncontrolled VOC emissions during guide-coat and top-coat
application range from approximately 1.26 Gg (1400 tons/yr) (at
an automobile assembly plant using enamel coatings and producing
40 vehicles/h) to more than 6.35 Gg (7000 tons/yr) (at a plant
using lacquer coatings and producing 85 vehicles/h).
8.2.2 Capital Cost of Control Options
The five control options incorporate two basic technologies:
a change in coating material (from solvent-borne to waterborne
paint) and incineration of the exhaust gases (by thermal and
catalytic incineration). All capital costs reflect 4th quarter
1977 prices of equipment and installation.
8.2.2.1 Change to Waterborne Paint—
Control option IA involves the use of waterborne coatings.
These coatings generally require longer spray booths, flash
tunnels, and ovens than solvent-borne enamels, hence increased
capital costs. These increased capital costs are somewhat less
when compared with solvent-borne lacquers, however, because a
8-33
-------
TABLE 8-7. AVERAGE SOLVENT-BORNE PAINT USAGE FOR AUTOMOBILE AND LIGHT-DUTY TRUCK BODIES
Vehicle
Automobile
Light-duty truck
Coating
Enamel guide coat
Enamel topcoat
Lacquer guide coat
Lcicquer topcoat
Enamel guide coat
Enamel topcoat
Lacquer guide coat
Lacquer topcoat
Solvent content,
percent by vol .
69
75
69
87
69
72
69
87
Paint usage per vehicle.
liters
2.0
11.2
2.0
25.3
2.0
12.2
2.0
31.1
gal
0.54
2.95
0.54
6.67
0.54
3.23
0.54
8.22
CO
I
co
-------
third (shroud) coat of lacquer is required. For a given line
speed, no cost distinction is made between automobiles and
light-duty trucks. Any differences that may exist are too small
to consider in a study estimate. Table 8-8 lists the coating
equipment requirements for the various types of coatings in a
plant producing 55 vehicles/h.
TABLE 8-8. COATING EQUIPMENT REQUIREMENTS IN A PLANT PRODUCING
55 VEHICLES/HOUR3
Coating and
number of lines
Equipment
Length per
line, m(ft)
Waterborne guide
coat (1 line)
Solvent-borne guide
coat (lacquer and enamel)
(1 line)
Waterborne
topcoat (2 lines)
Solvent-borne
enamel topcoat (2 lines)
Solvent-borne
lacquer topcoat (3 lines)
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
Spray booth
Flash-off tunnel
Oven
85 (280)
85 (280)
316 (1036)
67
51
316
94
85
128
30
9
76
(220)
(168)
(1036)
(308)
(280)
(420)
(100)
(30)
(250)
68 (224)
51 (168)
128 (420)
Reference 1
The turnkey costs of booths, tunnels, and ovens are shown
in Table 8-9. Costs include such items as air handling and
conditioning, lighting, sprinklers, spray equipment, conveyors,
and water-treatment equipment. In addition to the equipment .
costs, the land and building costs must be considered. Each
8-35
-------
TABLE 8-9.
TURNKEY COSTS OF AUTOMOBILE AND LIGHT-DUTY
TRUCK COATING EQUIPMENT COSTS
(4th quarter 1977 dollars)
Equipment
Estimated cost
Cost used in
this study
Waterborne paint
spray booth
Solvent-borne paint
spray booth
Flash-off tunnels
Ovens
$36,000 - 39,000/m
($11,000 - 12,000/ft)
$39,000/m .
($12,000/ft)D
a,b
$32,800/m
($10,000/ft)
$32,800/m
($l,000/ft)a
$6,600 - 7,800/m .
($2,000 - 3,000/ft)D
$1,200 - 1,400/m3
($35 - 40/ft3)a
$6,600 - 9,800/m .
($2,000 - 3,000/ft)
$3,900/m
($12,000/ft)
$32,800/m
($10,000/ft)
$6,600/m
($2,000/ft)
$9,800/m
($3,000/ft)
Reference 3
^Reference 4
8-36
-------
unit is 6.1 m (20 ft) wide, and for purposes of estimating
costs, it is assumed that a 1.5-m (5-ft) aisle is required on
each side of the booths, tunnels, and ovens. Ten percent was
added for space between coating lines. A building cost of
$29'1.10/m2 ($26.20/ft ) was used to calculate costs.2 The real
2 2
estate is assumed to cost $24.80/m ($2.30 ft ) .
Table 8-10 presents the incremental capital costs of a
waterborne system versus conventional solvent-borne systems for
application of guide coat and topcoat at plants of various line
speeds. The capital costs of comparable systems are assumed to
be directly proportional to line speed because the lengths of
the spray booths, flash-off tunnels, and ovens are a function of
line speed. A line speed that produces 70 vehicles per hour
travels twice as fast as one which produces only 35 vehicles per
hour. Thus, the ovens, for example, must be twice as long at •
the facility producing 70 vehicles per hour to achieve the same
retention time.
8.2.2.2 Incineration—
Control options IB-T, IB-C, II-T, and II-C require the use
of thermal and catalytic incinerators. All exhaust gases are
incinerated at 430°C (800°F) in the catalytic incinerators and
760°C (1400°F) in the thermal incinerators. Incinerators for
oven and flash tunnel exhausts are designed for 35 percent pri-
mary and 55 percent secondary heat recovery. Only 35 percent
primary heat recovery is considered for the spray booth exhausts.
8-37
-------
TABLE 8-10. INCREMENTAL CAPITAL COSTS OF WATERBORNE SYSTEM VERSUS
CONVENTIONAL SOLVENT-BORNE SYSTEMS, GUIDE COAT AND TOPCOAT
Type of coating
Solvent-borne enamel
Solvent-borne lacquer
Vehicles per hour
Capital Cost, $10(
30 38 40 48 55 85
5.65 7.15 7.53 9.05 10.3 16.0
30 38 40 48 55 85
0.39 0.50 0.52 0.63 0.72 1.11
co
(A)
00
-------
The units are shop-assembled packages complete with burners,
fan, controls, heat exchanger, and stack. Maximum unit size is
23.5 Nm /s (50,000 scfm). If exhaust volumes exceed this rate,
multiple units are used. Utility requirements consist of elec-
trical power to drive the fans and No. 2 fuel oil for the incin-
erator. Tanks with capacity for a 15-day fuel supply and ancil-
lary facilities such as dikes for aboveground tanks are included
in the costs.
Direct capital cost items included in incinerator installa-
tion are foundations, rigging, structural steel, ductwork, damp-
ers, electrical work, piping, temperature monitoring equipment,
and painting. Indirect costs of system startup, performance
testing, engineering, and the constructor's overhead and profit
were also included. No allowance is made for stack monitors.
Because VOC emissions are a function of the temperature in the
firing chamber, however, the cost of temperature monitoring
equipment is included.
Because costs are estimated, on a turnkey basis, cost of
construction money is not specifically considered. Company
philosphy and accounting methods have an impact on this. For
purposes of this study, it is assumed that the cost of construc-
tion money is accounted for in the 25 percent allotted for the
constructor's overhead and profit. The parameters used in
developing the costs for incineration systems are shown in Table
8-11.
8-39
-------
TABLE 8-11. TECHNICAL PARAMETERS USED IN DEVELOPING
COSTS OF INCINERATORS FOR CONTROL SYSTEM
Parameter
Value
a
Temperature, °C (°F)
Ovens and flash tunnels
Spray booths
Volumetric flow rate,
Nmvs (scfm) per vehicle/h
Guide coat spray booth
Guide coat ovens and flash tunnels
Topcoat spray booth, enamel
Topcoat ovens and flash tunnels,
enamel
Topcoat spray booth, lacquer
Topcoat ovens and flash tunnels,
lacquer
Hydrocarbon concentration, % LEL
Spray booths
Ovens and flash tunnels
4. Control efficiency, %
149 ( 300)
21 ( 70)
0.645 ( 1,370)
0.087 ( 18.5)
3.82 ( 8,100)
0.105 ( 222)
10.0 ( 21,200)
0.273 (
1.0
10.0
90.0
580)
Reference 5
LEL = lower explosive limit
8-40
-------
Table 8-12 presents delivered cost of incinerators. The
estimated costs of dampers, oil storage, electric service,
rigging, structural steel, foundations, ductwork, piping, painting,
startup, and testing are based on engineering judgment. Installed
costs include allowance of 25 percent for the constructor's
overhead and profit and 12 percent for engineering. Tables 8-13
through 8-21 show the capital cost of each of the control options
that incorporate exhaust gas incineration.
8.2.3 Annualized Cost of Control Options
- The total annualized cost is divided into three categories:
direct operating cost, capital charges, and (when applicable)
credit'for heat recovery. Operating and maintenance costs fall
into the first category and include the following:
° Utilities (including electric power, fuel, and process
water)
0 Operating labor
0 Maintenance and supplies
0 Solid waste disposal
Capital charges include depreciation, interest, administra-
tive overhead, property taxes, and insurance. Depreciation and
interest are computed by use of a capital recovery factor (CRF),
the value of which depends on the operating life of the building
or equipment and the interest rate. Table 8-21 lists the cost
factors used in computing the annualized costs.
8-41
-------
TABLE 8-12. DELIVERED COST OF EXHAUST GAS INCINERATORS'
Type of incinerator
Thermal - 35% primary and 55%
secondary heat recovery.
149°C (300°F) inlet
temperature
Catalytic - 35% primary and
55% secondary heat recovery.
149°C (300°F) inlet
temperature
Thermal - 35% primary heat
recovery, 21°C (70°F)
inlet temperature
Catalytic - 35% primary heat
recovery, 21"C (70°F) inlet
temperature
0.24 (500)
$75,500
$56,000
$70,000
$53,000
1.18 (2,500)
$85,000
$68.000
$78,000
$60,000
Nm3
2.36 (5,000)
$105,000
$86,100
$89,000
$70,000
/s (scfm)
4.72 (10,000)
$138.000
$117,500
$106,000
$85,500
14.1 (30,000)
$176,000
S237.000
$142.500
$203.500
23.5 (50,000)
$226,000
$357,000
$170,000
$301.000
CO
4=>
r>o
Coats are based on those reported in Reference 6 and updated to 4th-quarter 1977 prices.
Freight is included.
-------
TABLE 8-13. CAPITAL COSTS OF CONTROL OPTION IB-T FOR SURFACE COATING OF AUTOMOBILES
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
40
Unc.
Unc.
3,220
320
3,540
55
Unc.
Unc.
4,280
350
4,630
85
Unc.
Unc.
6,610
395
7,000
Solvent-borne lacquer
40
Unc.
Unc.
8,080
425
8,500
55
Unc.
Unc.
11,300
475
11,800
85
Unc.
Unc.
17,340
585
17,900
CO
*.
OJ
Unc.- Uncontrolled
-------
TABLE 8-14. CAPITAL COSTS OF CONTROL OPTION IB-C FOR SURFACE COATING OF AUTOMOBILES
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
40
Unc.
Unc.
4,080
276
4,350
55
Unc.
Unc.
5,530
320
5,850
85
Unc.
Unc.
8,550
385
8,940
Solvent-borne lacquer
40
Unc.
Unc.
10,400
440
10,800
55
Unc.
Unc.
14,500
529
15,000
85
Unc.
Unc.
22,300
724
23,000
CO
Unc. - Uncontrolled
-------
TABLE «-15. CAPITAL COSTS OF CONTROL OPTION II-T FOR SURFACE COATING OF AUTOMOBILES
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
40
745
170
3,220
320
4,460
55
835
180
4,280
350
5,640
85
1,260
190
6,610
395
8,460
Solvent-borne lacquer
40
745
170
8,080
425
9,420
55
835
180
11,300
475
12,800
85
1,260
190
17,300
585
19,300
00
Ol
-------
TABLE 8-16. CAPITAL COSTS OF CONTROL OPTION II-C FOR SURFACE COATING OF AUTOMOBILES
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
40
817
142
4,080
276
5,320
55
997
150
5,530
320
7,000
85
1,520
162
8,550
385
10,620
Solvent-borne lacquer
40
817
142
10,400
440
11,800
55
997
150
14,500
529
16,200
85
1,520
162
22,300
724
24,700
CD
k
-------
TABLE 8-17% CAPITAL COSTS OF CONTROL OPTION IB-T FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
Total capital costs (rounded)
Solvent-borne enamel
30
Unc.
Unc .
2,620
292
2,910
38
Unc .
Unc.
3,610
320
3,930
48
Unc .
Unc.
4,080
345
4,420
Solvent-borne lacquer
30
Unc.
Unc.
7,420
413
7,830
38
Unc.
Unc.
8,740
485
9,220
48
Unc.
Unc.
12,100
562
12,700
00
Unc.- Uncontrolled
-------
TABLE 8-18. CAPITAL COSTS OF CONTROL OPTION IB-C FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
30
Unc.
Unc.
3,260
254
3,510
38
Unc.
Unc.
4,060
278
4,340
48
Unc.
Unc.
5,140
310
5,450
Solvent-borne lacquer
30
Unc.
Unc.
9,680
420
10,100
38.
Unc.
Unc.
12,200
485
12,700
48
Unc.
Unc.
15,500
628
16,100
00
Unc.- Uncontrolled
-------
TABLE 8-19.
CAPITAL COSTS OF CONTROL OPTION II-T FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
i
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
30
437
172
2,620
292
3,520
38
730
172
3,610
320
4,830
48
786
172
4,080
345
5,380
Solvent-borne lacquer
30
437
172
7,420
413
8,440
38
730
172
8,740
485
10,100
48
786
172
12,100
562
13,600
ex
-U
1C
-------
TABLE 8-20. CAPITAL COSTS OF CONTROL OPTION II-C FOR SURFACE COATING
OF LIGHT-DUTY TRUCKS
(1000 dollars)
Type of coating
Vehicles per hour
Emission Source
Guide-coat spray booths
Guide-coat flash tunnels and
ovens
Topcoat spray booths
Topcoat flash tunnels and
ovens
Total capital costs (rounded)
Solvent-borne enamel
30
537
145
3,260
254
4,200
38
790
145
4,060
278
5,270
48
907
145
5,140
310
6,500
Solvent-borne lacquer
30
537
145
9,680
420
10,800
38
790
145
12,200
485
13,600
48
907
145
15,500
620
17,200
00
Ul
o
-------
TABLE 8-21.
COST FACTORS USED IN COMPUTING ANNUALIZED
COSTS FOR CONTROL OPTIONS
Operating factor
Maintenance labor rate
Operating labor rate
Supervisory labor rate
Utilities
Electric power
Fuel oil
Capital recovery factor
Air pollution control equipment
Production equipment
Buildings
Taxes and insurance
Administrative overhead
Catalyst allowance
16 h/day
240 days/yr
3840 h/yr
$12.07/h
$10.97/h
$12.07/h
$0.0242/kWh
$0.107/liter ($0.396/gal)
16.28% of capital cost
13.14% of capital cost
11.02% of capital cost
2% of capital cost
2% of capital cost
$2120/yr per Nm3/s
($1.00/yr per scfm)
8-51
-------
8.2.3.1 Waterborne Paints—
Waterborne coating systems reportedly require more operating
and maintenance labor than solvent-borne coating systems.
Estimates of additional labor needed for waterborne guide and
topcoats are as follows:
Solvent-borne Solvent-borne
lacquer enamel
Operating labor 10 20
Maintenance labor 7 7
Supervision 1 2
The cost of maintenance materials and supplies is assumed to be
equal to the cost of maintenance labor.
Waterborne painting facilities require considerably more
energy than solvent-borne coating facilities. Most of this
additional energy is used to evaporate the water and condition
the incoming air to the spray booths.
Factors used in calculating the annualized costs of water-
borne coating facilities are shown in Table 8-21.
The cost of controlling water pollution associated with
waterborne coating facilities is estimated to be comparable to
that at solvent-borne coating facilities. Waterborne paints are
believed to cost more than conventional coatings, but they also
have a higher solids content, Although a comparison of paint
prices was not available from the paint manufacturers or the
automobile industry, the above would seem to indicate that the
net applied paint cost is comparable for enamel and lacquer
8-52
-------
coatings and waterborne coatings. General Motors uses waterborne
paint at two of its three California plants. Their response to
an inquiry by the California Air Resources Board did not mention
any net cost difference between waterborne and solvent-borne
coatings.
Figures 8-2 and 8-3 show annualized cost differentials of
waterborne coating operations compared with solvent-borne opera-
tions at various line speeds. Tables 8-22 and 8-23 present
annualized costs and cost-effectiveness of this control option
for automobiles and light-duty trucks.
8.2.3.2 Incineration—
Cost factors used to compute the annualized costs of con-
trolling VOC emissions from the guide-coat and topcoat operations
are shown in Table 8-21. Operating labor for each incinerator,
regardless of size [maximum size 23.5 Nm /s (50,000 scfm)],
includes 1.0 man-hour for each startup and shutdown and 0.25
man-hour per shift for monitoring. Each incineration unit must
be tuned up and the heat exchangers must be cleaned twice
yearly. These items, together with miscellaneous maintenance,
require an estimated 64 man-hours/year per incinerator. Operating
and maintenance labor is independent of incinerator size.
It is estimated that the catalyst in catalytic incinerators
must be replaced yearly at a cost of $2120/Nm per second ($1.00/
scfm).
8-53
-------
u
a
<0
tr
I/)
u
fl
F^
"o
TJ
O
I
I
30 40 SO 60 70
LINE SPEED, vehicles/h
80
90
Figure 8-2. Cost differential - control option IA
for guide coat and topcoat, waterborne enamel vs.
solvent-borne enamel .
8-54
-------
i-
Ł 5
cr
o
•o 2
o
30 40 50 60 70
LINE SPEED, vehicles/h
80 90
Figure 8-3. Cost differential - control option IA
for guide coat and topcoat, waterborne enamel vs.
solvent-borne lacquer.
8-55
-------
TABLE 8-22. COMPARABLE COSTS OF CONTROL OPTION IA
FOR SURFACE COATING OF AUTOMOBILES
coating with which
option is compared
Enamel
Lacquer
Line speed.
vehiclea/h
40
55
85 '
40
55
85
Uncontrolled
Mg/yr
(tons/yr)
1260
(1390)
1740
(1920)
2700
(2970)
3010
(3310)
4140
(4560)
6390
(7040)
efficiency,
percent
80.7
80.7
80.7
91.9
91.9
91.9
VOC emission
Mg/yr
(tons/yr)
1020
(1120)
1410
(1550)
2170
(2390)
2780
(3060)
3810
(4200)
5880
(6480)
Annual! zed
Direct
operating
1.38
1.89
2.92
1.04
1.42
2.19
cost. $
Capital
charges
1.28
1.75
2.70
0.10
0.13
0.20
10*
Total
2.66
3.64
5.62
1.14
1.55
2.39
Cost-
S/Mg VOC removed
($/ton VOC removed)
2610
(2370)
2580
(2350)
2590
(2350)
410
( 372)
407
( 369)
406
( 370)
00
I
en
eh
-------
TABLE 8-23. COMPARABLE COSTS OF CONTROL OPTION IA
FOR SURFACE COATING OF LIGHT-DUTY TRUCKS
oo
Ul
Type of conventional
coating with which
option is compared
Enamel
Lacquer
Line speed ,
vehicles/h
30
38
48
30
38
48
Uncontrolled
VOC emissions,
Mg/yr
(tons/yr)
990
(1090)
1250
(1380)
1580
(1740)
2750
(3030)
3480
(3840)
4400
(4850)
Control
efficiency,
percent
79.4
79.4
79.4
92.6
92.6
92.6
VOC emissions
reduction,
Mg/yr
(tons/yr)
785
( 865)
1000
(1100)
1250
(1380)
2550
(2810)
3230
(3560)
4080
(4500)
Annualized costs, $10
Direct
operating
1.03
1.31
1.65
0.78
0.98
1.24
Capital
charges
0.96
1.21
1.53
0.07
0.09
0.11
Total
1.99
2.52
3.18
0.85
1.07
1.35
Cost-
effectiveness,
$/Mg VOC removed
($/ton VOC removed)
2540
(2300)
2540
(2300)
2540
(2300)
333
( 302)
330
( 300)
330
( 300)
-------
Because total exhaust rates differ between solvent-borne
lacquer and solvent-borne enamel operations, the annualized
costs also vary; control of emissions from solvent-borne lacquer
is more costly.
Heat recovered by the primary heat recovery systems with
the incinerators on spray booths is used to preheat the spray
booth exhausts. The resultant savings is not considered a
credit from a cost standpoint; rather it is accounted for in the
decreased fuel rate. On the other hand, the heat obtained from
secondary heat recovery can be considered because it is used for
production facilities. All the incinerators used on flash-off
tunnel and oven exhausts have primary and secondary heat recovery.
The heat recovered in the secondary heat exchanger is credited
at the rate of $2.68/GJ ($2.83/106Btu).
Tables 8-24 through 8-31 present the annualized costs of .
the control options IB-T, IB-C, II-T, and II-C for automobiles
and light-duty trucks.
8.2.4 Cost-effectiveness of the Control Options
In this section a comparison of the annualized costs of the
various alternative control options to the quantities of VOC
removed by them, or a cost-effectiveness analysis, is made on
each of the control options and each of the model coating facili-
ties.
The purpose of this comparison is to determine 1) which is
the most practical control option, 2) whether the options differ
in cost-effectiveness, and 3) whether the expenditure of
8-58
-------
TABLE 8-24. COMPARABLE COSTS OF CONTROL OPTION IB-T
FOR SURFACE COATING OF AUTOMOBILES
Type of conventional
coating with which
option !• compared
Enamel
Lacquer
Line apeed,
vehlclea/h
40
55
as
40
55
85
Uncontrolled
VOC emissions,
M9/yr
(tons/yr)
1260
(1390)
1740
(1920)
2700
(2970)
3010
(3310)
4140
(4S60)
6390
(7040)
Control
efficiency,
percent
77
77
77
85
85
85
VOC emission
reduction,
Mg/yr
(tona/yr)
970
(1070)
1340
(1480)
2080
(2280)
2560
(2820)
3520
(3880)
5420
(5980)
Annuallxed coat, $10
Direct
operating
3.43
4.84
7.27
8.94
12.30
19.00
Capital
charges
0.73
0.95
1.45
1.75
2.42
3.69
Secondary
heat
recovery
credit
(0.05)
(0.07)
(0.11)
(0.14)
(0.18)
(0.28)
rotai*
4.11
5.62
8.61
10.6
14.5
22.4
Cost-
effectiveness,
f/Mg VOC removed
(*/ton VOC removed)
4240
(3840)
4200
(3800)
4150
(3780)
4140
(3760)
4120
(3740)
4130
(3750)
00
en
UD
Rounded
-------
TABLE 8-25. COMPARABLE COSTS OF CONTROL OPTION IB-C
FOR SURFACE COATING OF AUTOMOBILES
Type of conventional
coating with which
option !• compared
Enamel
Lacquer
Line speed,
vehicles/h
40
55
85
40
55
85
Uncontrolled
VOC emissions,
Mg/yr
(tons/yr)
1260
(1390)
1740
(1920)
2700
(2970)
1010
(1110)
4140
(4560)
6390
(7040)
Control
efficiency,
percent
77
77
77
85
85
85
VOC emission
reduction,
M9/yr
(tons/yr)
970
(1070)
1340
(1480)
2080
(2300)
2560
(2800)
3520
(3880)
5430
(5980)
Annuallsed cost, |106
Direct
operating
2.18
'3.00
4.61
5.67
7.78
12.0
Capital
charges
0.89
1.19
1.81
2.22
3.05
4.69
Secondary
heat
recovery
credit
(0.03)
(0.04)
(0.06)
(0.07)
(0.10)
(0.16)
total*
3.04
4.15
6.36
7.82
.0.7
16.5
Cost-
effectiveness,
$/Hg VOC removed
($/ton VOC removed)
3130
(2840)
3100
(2800)
3060
(2770)
3060
(2790)
3040
(2760)
3040
(2760)
CO
Rounded
-------
TABLE 8-26. COMPARABLE COSTS OF CONTROL OPTION II-T
FOR SURFACE COATING OF AUTOMOBILES
Type of conventional
coating with which
option ia compared
Enamel
Lacquer
Line (peed.
vehicles/h
40
55
85
40
SS
as
Uncontrolled
VOC emissions.
Mg/yr
(tons/yr)
1260
(1390)
1740
(1920)
2700
(2970)
3010
(3310)
4140
(4560)
6390
(7040)
Control
efficiency.
percent
90
90
90
90
90
90
VOC emission
reduction,
Mg/yr
(tona/yr)
1130
(1250)
1570
(1730)
2430
(2670)
2710
(2980)
3730
(4100)
5750
(6340)
Annualised coat, $10
Direct
operating
4.02
5.53
8.49
9.52
13.1
20.2
Capital
charges
0.91
1.16
1.75
1.94
2.62
3.99
Secondary
heat
recovery
credit
(0.06)
(0.08)
(0.12)
(0.14)
(0.19)
(0.30)
M
rotal
4.87
6.61
10.1
11.3
15.5
23.9
Cost-
effectiveness,
$/Mg VOC removed
(S/ton VOC removed)
4310
(3900)
4210
(3830)
4160
(3780)
4170
(3800)
4160
(3780)
4160
(3780)
CO
cr>
Rounded
-------
TABLE 8-27. COMPARABLE COSTS OF CONTROL OPTION II-C
FOR SURFACE COATING OF AUTOMOBILES
Type of conventional
coating with which
option la compared
Enamel
Lacquer
Line speed,
vehlclea/h
40
55
85
40
ss
as
Uncontrolled
VOC emissions,
Mg/yr
(tons/yr)
1260
(1390)
1740
(1920)
2700
(2970)
3010
(3310)
4140
(4560)
6390
(7040)
Control
efficiency,
percent
90
90
90
90
90
90
VOC emission
reduction,
Mg/yr
(tons/yr)
1130
(12SO)
1570
(1730)
2430
(2670)
2710
(2980)
3730
(4100)
5750
(6340)
Annuallsed cost, $10
Direct
operating
2.56
3.51
5.39
6.05
8.29
12.8
Capital
charges
1.08
1.42
2.16
2.41
3.28
5.03
Secondary
heat
recovery
credit
(0.03)
(0.04)
(0.07)
(0.08)
(0.10)
(0.16)
rotal*
3.61
4.89
7.48
8.38
1.5
7.7
Cost-
effectiveness.
$/Hg VCX; removed
($/ton VOC removed)
3200
(2900)
3120
(2820)
3080
(2800)
3100
(2810)
3080
(2800)
3080
(2800)
00
at
ro
Rounded
-------
TABLE .8-2& COMPARABLE COSTS OF CONTROL OPTION IB-T
FOR SURFACE COATING OF LIGHT-DUTY TRUCKS
Type of conventional
coating with which
option is compared
Enamel
Lacquer
Line speed,
vehiclea/h
30
38
48
30
38
48
Uncontrolled
VOC emissions,
Mg/yr
(tons/yr)
990
(1090)
1250
(1380)
1580
(1740)
2750
(3030)
3480
(3840)
4400
(4850)
Control
efficiency,
percent
78
78
78
85
85
as
VOC emissions
reduction,
M9/yr
(tons/yr)
770
( 850)
975
(1080)
1230
(1360)
2340
(2580)
2960
(3260)
3740
(4120)
Annualized cost, $10
Direct
operating
2.70
3.42
4.34
8.28
10.4
13.2
Capital
charges
O.SO
0.73
0.90
1.62
2.03
2.55
Secondary
heat
recovery
credit
(0.04)
(0.05)
(0.07)
(0.12)
(0.16)
(0.20)
Total*
3.26
4.10
5.17
9.78
12.3
15.6
Coat-
el fectivenesa,
J/Mg VOC removed
($/ton VOC removed)
4220
(3840)
4200
(3810)
4200
(3810)
4180
. (3810)
4160
(3770)
4170
(3780)
CO
CO
* Rounded
-------
TABLE 8-29. COMPARABLE COSTS OF CONTROL OPTION IB-C
FOR SURFACE COATING OF LIGHT-DUTY TRUCKS
Typ* of conventional
coating with which
option is compared
Enamel
Lacquer
Line spaed,
vehicles/h
30
38
48
30
38
48
Uncontrolled
VOC emissions,
Mg/yr
(tons/yr)
990
(10901
1250
I13BO)
1580
(1740)
2750
(3030)
3480
(3840)
4400
(4850)
Control
efficiency,
percent
78
78
78
85
85
85
VOC emissions
reduction,
Mg/yr
(tons/yr)
770
( 850)
975
(1080)
1230
(1360)
2340
(2580)
2960
(3260)
3740
(4120)
Annuallted cost, $10
Direct
operating
1.72
2.17
2.75
5.25
6.64
8.39
Capital
charges
0.72
0.89
1.11
2.06
2.59
3.29
Secondary
heat
recovery
credit
(0.02)
(0.02)
(0.04)
(0.07)
(0.09)
(0.11)
Total*
2.42
3.04
3.82
7.24
9.14
11.6
Cost-
effectiveness,
J/Mg VOC removed
(S/ton VOC removed)
3140
(2850)
3110
(2820)
3100
(2820)
3100
(2820)
3090
(2800)
3100
(2820)
00
a Rounded
-------
TABLE 8-30. COMPARABLE COSTS OF CONTROL OPTION II-T
FOR SURFACE COATING OF LIGHT-DUTY TRUCKS
Type of conventional
coating with which
option is compared
Ename 1
Lacquer
Line •peed>
vehicles/h
30
38
48
30
38
48
Uncontrolled
VOC emissions.
Mg/yr
Itons/yr)
990
(1090)
1250
(1380)
1S80
•1740)
2750
(3030)
3480
(3840)
4400
(4850)
Control
efficiency.
percent
90
90
90
90
90
90
VOC emissions
reduction.
Mg/yr
(tons/yr)
890
( 980)
1120
(1240)
1420
(1570)
2480
(2730)
3130
(3460)
3960
(4360)
Annualized cost, $10
Direct
operating
3.15
3.98
5.04
8.72
11.0
13.9
Capital
cherges
0.72
0.91
1.10
1.75
2.21
2.74
Secondary
heat
recovery
credit
(0.04)
(0.06)
(0.07)
(0.13)
(0.16)
(0.20)
total*
3.83
4.83
6.07
10.3
13.1
16.4
Cost-
effectiveness,
l/Hg VOC removed
($/ton VOC removed)
4290
(3900)
4300
(3900)
4280
(3870)
4150
(3770)
4180
(1790)
4140
(3760)
CD
I
a\
in
* Rounded
-------
TABLE 8-31. COMPARABLE COSTS OF CONTROL OPTION II-C
FOR SURFACE COATING OF LIGHT-DUTY TRUCKS
Typa of conventional
coating with which
option la compared
Enamel •
Lacquer
Line speed,
vehlclea/h
30
38
48
. 30
31
48
Uncontrolled
VOC emlaalona.
Hg/yr
(tona/yr)
990
11090)
12SO
(1380)
1580
(1740)
2750
(3030)
3480
(3840)
4400
(48SO)
Control
efficiency,
percent
90
90
90
90
90
90
VOC emissions
reduction
Hg/yr
(tons/yr)
890
I 980)
1120
(1240)
1420
(1570)
2480
(2730)
3130
(3460)
3960
(4360)
Annuallsed coat, $10
Direct
operating
2.0
2.53
3.20
5.53
7.0
8.84
Capital
chargea
0.8S
1.08
1.33
2.20
2.78
3.50
Secondary
heat
recovery
credit
(0.03)
(0.03)
(0.04)
(0.07)
(0.09)
(0.11)
rotal*
2.82
3.58
4.49
7.66
9.69
L2.2
Cost-
•ffectiveneaa,
5/Hg VOC removed
($/ton VOC removed)
3170
(2880)
3200
(2890)
3160
(2860)
3090
(2810)
3100
(2800)
3080
(2800)
CO
en
en
Rounded
-------
additional monies can be justified by the amount of pollutant
controlled.
Tables 8-22 and 8-23 list these cost-effectiveness quotients
for control option IA. It is clear from these tables that the
quotients are virtually identical for automobiles and light-duty
trucks when compared with the base case of solvent-borne enamels,
but there is a spread of approximately 20 percent between the
two when compared with the base case of solvent-borne lacquers.
This spread results from the higher lacquer requirements for
truck bodies; when lacquer is used, a light-duty truck requires
about 23 percent more topcoating than an automobile, but when
enamel is used, the difference is only about 5 percent.
The VOC emitted by coating operations using solvent-borne
lacquers are more than twice those emitted by operations using
solvent-borne enamels. This results partly from the higher
solvent content of lacquers and partly from the additional paint
required for each vehicle. On the other hand, lacquers require
greater volumes of exhaust gases. Although emissions generated
from lacquers cost more to control than those from enamels, more
VOC is removed and the cost-effectiveness remains about the same
for a given control option using incinerators.
There is a large difference, however, in the cost-effective-
ness of waterborne coatings compared with enamels and waterborne
coatings compared with lacquers because waterborne coatings need
less spray booth, flash-off tunnel, and oven facilities than do
solvent-borne lacquer coatings, whereas they need more of these
8-67
-------
facilities than do solvent-borne enamels. Figures 8-4 and 8-5
compare the cost-effectiveness of each of the control options.
Control option IA, the use of waterborne paint, is the most
cost-effective option in all cases.
As the cost-effectiveness curves indicate, no economy-of-
scale occurs in controlling the larger facilities because these
facilities require proportionately higher exhaust gas rates and
the maximum sized incinerator is 23.5 Nm /s (50,000 scfm), thus
necessitating more incinerators. Thus gas incineration costs
are proportional to plant capacity. Neither does control option
IA (a switch to waterborne paint) exhibit an economy-of-scale
for basically the same reason; more pieces of the same size
equipment are required in larger facilities. Finally, for all
control options, the operating costs are larger than the capital
charges. The nature of these costs is such that they are directly
proportional to production rate, which also militates against
economics-of-scale.
The cost-effectiveness of each of the control options may
be summarized as follows:
Option Cost-effectiveness, $/Mg
IA 330 - 410 (lacquer-base case)
2500 - 2600 (enamel-base case)
IB-T 4200
IB-C 3100
II-T 4200
II-C 3100
8-68
-------
(/>
-------
10,000
5000
4000
3000
2000
O>f—
1000
ae,
500
400
300
200
100
1
I
30 40 50 60 70 80
LINE SPEED, vehicles/h
90
— — — — CONTROL OPTIONS IB-T AND II-T - AUTOMBILES AND TRUCKS
(LACQUER AND ENAMEL)
CONTROL OPTIONS IB-C AND II-C - AUTOMOBILES AND TRUCKS
(LACQUER AND ENAMEL)
Figure 8-5. Cost-effectiveness of control
options as applied to different vehicle types
and different types of solvent-borne coatings,
8-70
-------
8.2.5 Control Cost Comparison
It is difficult to compare the estimated cost of waterborne
coating operations with costs reported at actual installations.
For example, cost data presented to the California Air Resources
Board by two of the major automobile manufacturers cannot be
compared directly with the estimated costs of waterborne opera-
tions presented in this report because the figures are aggregated,
include many items not included in Control Option IA. are based
on a "tear-out/redo" premise, and are considered by the staff of
the Air Resources Board to be on .the high side. The turnkey
costs of spray booths, flash-off tunnels, .and ovens for waterborne
paint were provided by vendors, however, and the quoted prices
are substantially lower than the estimate given the California
Air Resources Board. Because no direct cost data could be
extracted from the California report, the vendors' turnkey
prices were used.
Much of the increase in annualized coating costs is due to
increased energy consumption when using waterborne paints. In
this case some comparison can be made with the data that GM
supplied to the California Air Resources Board. The actual
recorded incremental increase at the Van Nuys plant (which has
9
a production rate of 60 vehicles/h) was 89.4 TJ/yr (84.8 x 10
Btu/yr). The study estimate for Control Option IA at a plant
producing 55 vehicles/h includes an incremental increase of 76.5
TJ/yr (72.4 x 109 Btu/yr) for additional fuel oil and 44.6 TJ/yr
(42.3 x 10 ) for additional electricity.
8-71
-------
Incinerator costs used in this study are based on a 1976
report and updated to 4th quarter 1977 prices. These prices
compare reasonably well with older installations as reported in
g
a 1972 report. The prices shown in the 1972 report were also
updated to 4th quarter 1977. Figures 8-6, 8-7, and 8-8 compare
8 9
costs used in this study with costs in other studies. '
Installation costs of the incinerators were estimated inde-
pendently. Installed costs were then compared with the incinera-
tor purchase prices. The ratio of estimated installed cost to
purchase price ranged from 2.1 to 2.8. This compares favorably
g
with previously reported ratios, which ranged from 1.2 to 3.7.
8.2.6 Base Cost of the Facility
For purposes of comparison, a base cost of solvent-borne
painting facilities has been developed under this study. This
base cost includes the complete cost of an electrodeposition
(EDP) prime coating facility, a guide-coat facility, a topcoat
facility, and touch-up facilities. The cost of related support
facilities such as employee parking, material storage, and a
cafeteria is also included.
Because this is a study estimate, costs are not detailed. It
is assumed that the costs o'f painting facilities for automobiles
and light-duty trucks are basically the same for both. Total
costs were estimated for a facility that handles 55 vehicles per
hour. For study purposes, it is assumed that base costs are
proportional to line speed. The base cost of a paint shop that
uses lacquer is higher than the cost of one that uses enamel.
8-72
-------
400
300
C
OCOSTS USED IN THIS STUDY
A COSTS FROM REFERENCE 8
DCOSTS FROM REFERENCE 9
-vj
oo
200
t?
I
50
10
CAPACITY. Nm3/s
15
20
10
20 30
CAPACITY. 1000 scfm
40
50
Figure 8-6. Comparison of purchase prices of catalytic
incinerators with primary heat recovery.
-------
400
300
O COSTS USED IN THIS STUDY
A COSTS FROM REFERENCE 8
X
c
O
•o
A
CD
I
•vl
f
i
200
A
100
A
50
I
I
10 CAPACITY. Nn)3/s 15
I I
20
10
20 30
CAPACITY. 1000 scfra
40
SO
Figure 8-7. Comparison of purchase prices of thermal
incinerators with primary heat recovery.
-------
400
oo
•vj
en
O COSTS USED IN THIS STUDY
COSTS FROM REFERENCE B
Q COSTS FROM REFERENCE 9
10
CAPACITY. Nm3/s
15
20 30
CAPACITY, 1000 scfm
20
40
i
50
Figure 8-8. Comparison of pruchase prices of thermal
incinerators with primary and secondary heat recovery.
-------
Building space was estimated at 17,500 m2 (188,000 ft ) for
lacquer facilities and 11,800 m2 (127,000 ft2) for enamel facil-
ities. These figures include 3,250 m2 (35,000 ft2) for EDP in
both instances. In addition, 835 m2 (9,000 ft ) of building
space for employee services (e.g., cafeteria and dispensary) and
employee parking facilities for 300 vehicles is included in the
base cost estimate. This figure is based on 500 employees
working two shifts. The following unit costs were used for real
estate:
Buildings - $291.10/m2 ($26.20/ft2)
Land - $ 24.80/m2 ($100,000/acre)
Unit costs used for the spray booths, flash-off tunnels,
and ovens are shown in Table 8-9 and the aggregate line lengths
are shown in Table 8-32.
Electrodeposition facilities include rinse tunnels, an
oven, and an EDP tank with ancillary equipment such as conveyors,
electrical equipment, ventilation, and hooding. An industry
representative reported that recent costs of retrofitted EDP
facilities ranged from $11.4 to $14.8 million, and an average
facility cost $12.6 million. One vendor's turnkey estimate for
a facility handling 55 vehicles per hour ranged from $6.5 to
$9.5 million. The following is a breakdown of this estimate:
EDP tank $2.0 to $3.5 million
Rinse tunnels $1.5 to $2.0 million
Oven $6.5 to $4.0 million
8-76
-------
TABLE 8-32. AGGREGATE LENGTHS OF SPRAY BOOTHS,
FLASH-OFF TUNNELS, AND OVENS FOR PAINT SHOPS
HANDLING 55 VEHICLES PER HOUR
[m (ft)]
Facility
Spray booths
Flash-off tunnels
Ovens
Type of
solvent-borne paints
Lacquer
292 (956)
235 (772)b
735 (2408)
Enamel
147 (484)
100 (238) b
502 (1648)
Based on three topcoat lines for lacquer coatings and two
topcoat lines for enamel coatings.
Includes 7.3 m (24 ft) of cooling area.
8-77
-------
The high side of this range ($9.5 million) comports with the
retrofitted average of $12.6 million and was used in preparing
this estimate. Tables 8-33 and 8-34 present total base costs
for various line speeds.
8-78
-------
TABLE 8-33. BASE COST OF AN AUTOMOBILE AND LIGHT-DUTY
TRUCK PAINT SHOP THAT USES SOLVENT-BORNE ENAMEL
Line speed, vehicles/h
Guide, top, and touch-
up coating facilities3
EDP facility3
Ancillary facilities
Totals
6
Installed costs, $10
30
7.2
5.7
0.3
13.2
38
9.1
7.3
0.4
16.8
40
9.6
7.6
0.4
17.6
48
11.5
9.2
0.5
21.2
55
13.2
10.5
0.6
24.3
85
20.4
16.2
0.9
37.5
Includes cost of land and building
8-79
-------
TABLE 8-34. BASE COST OF AN AUTOMOBILE AND LIGHT-DUTY
TRUCK PAINT SHOP THAT USES SOLVENT-BORNE LACQUER
Line speed, vehicles/h
Guide, top, and touch-
up coating facilities3
EDP facility3
Ancillary facilities3
Totals
Installed costs, $106
30
12.5
5.7
0.3
18.5
38
15.8
7.3
0.4
23.5
40
16.6
7.6
0.4
24.6
48
19.9
9.2
0.5
30.6
55
22.8
10.5
0.6
33.9
85
35.1
16.2
0.9
52.2
Includes cost of land and building
8-80
-------
REFERENCES
1. Memorandum from W. Johnson of U.S. EPA, Chemical Application
Section, Durham, North Carolina, to W. Vatavuk of U.S. EPA,
Economic Analysis Branch, Durham, North Carolina, April 12,
1978.
2. Building Construction Cost Data, 1978. Robert Snow Means
Company, Inc., Duxbury, Massachusetts, p. 267.
3. Personal communication between A. Knox of PEDCo Environmen-
tal, Inc., Cincinnati, Ohio, and F. Steinhable of Sinks
Manufacturing Company, Detroit, Michigan. June 21, 1978.
4. Personal communication between D. Henz of PEDCo Environ-
mental, Inc., Cincinnati, Ohio, and J. Dwyer of George Kock
& Sons, Evansville, Indiana. May 25> 1978.
5. Second Interim Report on Air Pollution Control Engineering
and Cost Study of the Transportation Surface Coating Indus-
try. Springborn Laboratories, Inc., Enfield, Connecticut.
EPA Contract No. 68-02-2062. May 6, 1977.
6. Report of Fuel Requirements, Capital Cost and Operating
Expense for Catalytic and Thermal Afterburners. Combustion
Engineering Air Preheater, Industrial Gas Cleaning Institute.
Stamford, Connecticut. EPA-450/3-76-031. September 1976.
7. Proposed Model Rule for the Control of Volatile Organic
Compounds from Automobile Assembly-line Coating Operations.
Presented to the California Air Resources Board on January
26, 1978, as Agenda Item 78-2-2.
8. Rolke, R.W., et al. Afterburner Systems Study. Shell
Development Company. Emeryville, California. NTIS Publica-
tion No. PB-212-560. August 1972.
9. Capital and Operating Costs of Selected Air Pollution' Con-
trol Systems. GARD, Inc., Niles, Illinois. EPA Publica-
tion No. EPA-450/3-76-014. Pp. 4-18 and 19. September
1976.
10. Personal communication between D. Henz of PEDCo Environ-
mental, Inc., Cincinnati, Ohio, and D. Twilley of Ford
Motor Company, Detroit, Michigan. June 21, 1978.
8-81
-------
8.3 Other Cost Considerations
In addition to NSPS, the automotive industry will be impacted by
other safety, fuel economy, and noise-control regulations. However,
the imposition of these other regulations probably will not affect the
results of the analysis contained in Section 8.4.
A comprehensive study to evaluate the combined economic impact of
all government regulations on the automotive industry is presently being
conducted by A. T. Kearney, Inc. Results are not available at this time.
8-82
-------
8.4 Potential Economic Impact
8.4.1 Grass Roots New Lines
Projected new source requirements include: one car and one truck
line for General Motors, one truck line for Ford, one car line for Chrysler,
and no new lines for American Motors, Checker and International Harvester.
The projected economic impact of each considered alternative control option
on the required grass roots new lines is small, and the cost of compliance
with New Source Performance Standards should not, of itself, preclude the
construction of any of these lines.
8.4.2 Control Costs
The absolute and relative magnitude of the estimated alternative
control costs for grass roots new lines, by firm, are shown in Tables
8-43, 8-44, 8-45, and 8-46. In all cases, the estimated incremental
control costs are exceedingly small when viewed as a percentage of list
price for each manufacturer's lowest-priced automobile or light-duty
truck.
The capital investment costs.of the alternative control options
are also exceedingly small in relation to the planned annual capital
expenditures of each firm.
For General Motors, the annualized costs of a new line are, at
most, $3.70 per passenger car and $9.02 per light-duty truck.* These
*The methodology used to derive each manufacturer's annualized costs on
a per-unit basis, in keeping with traditional industry pricing practices,
assumes that the incremental costs attributable to the New Source Perfor-
mance Standard will be distributed by the manufacturer over all units sold
rather than over the production volume of the new line.
8-83
-------
Table 8-43
ABSOLUTE AND RELATIVE INCREMENTAL CONTROL COSTS
CO
(4th Quarter 1977 Dollars)
(Passenger
Car - General Motors)
Alternatives
Line Speed/Cost Category I
40 Passenger Cars/Hour
Annualized Cost
Annualized Cost/Passenger Carl
Annualized Cost/Passenger Car as a % of suggested
Manufact. Retail Price. April, 1978, $3.074.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen- •• *
ditures of $3.400,000,000 in 1983.3
55 Passenger Cars/Hour
Annualized Cost
Annualized Cost/Passenger. Car'
Annualized Cost/Passenger Car as a % of suggested
Manufact. Retail Price, April, 1978, $3,074.2
Investment Cost of Control Alternative •
Investment Cost as a % of Planned Capital Expen-
ditures of $3,400,000,000 in 1983. 3
85 Passenger Cars/Hour
Annualized Cost
Annualized Cost/Passenger Carl
Annualized Cost/Passgener Car as a % of suggested
Manufact. Retail Price, April, 1978, $3.074. 2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $3,400,000.000 in 1983. 3
'Total annualized costs were spread over the 1982 production volume
'consistent with the industry's pricing policies.
2The April 1978 published list price, as reported in Automotive News
IA
$1,140.000
$.18
.01%
$ 520,000
.02%
$1,550,000
$.24
.01%
$ 720,000
.02%
$2.390,000
$.37
.01%
$1,110,000
.03%
of 6,464.000
, was deemed
IB-T
$10,600,000
$1.64
.05%
$8,500,000
.25%
$14,500,000
$2.24
.07%
$11,800,000
.35%
$22,400,000
$3.47
.11%
$17.900,000
.53%
passenger cars.
acceptable as a
IB-C
$7,820,000 $11
$1.21
.04%
$10,900,000 $9
.32%
$10.700,000 $15
$1.66
.05%
$15,000,000 $12
.44%
$16,500,000 $23
$2.55
.08%
$23,000,000 $19
.68%
This was judged
base price for
II-T
,000,000
$1.70
.06%
,470,000
.28%
,500,000
$2.40
.08%
,800,000
.38%
.900,000
$3.70
.12%
,300,000
.57%
II-C
$8,380,000
$1.30
.04%
$11,800,000
.35%
$11,500,000
$1.78
.06%
$16,200,000
.48%
$17,700.000
$2.74
•
.09%
$24,700.000
.73%
comparison purposes. It was assumed that the additional price of optional equipment would offset any price
discount by the dealer.
figure was an estimate provided by C. Cavalieri of the Bank of America.
-------
Table 8-44
ABSOLUTE AND RELATIVE INCREMENTAL CONTROL COSTS
(4th Quarter 1977 Dollars)
(Light-Duty Trucks - General Motors)
Alternatives
Line Speed/Cost Category
30 Trucks/Hour
Annualized Cost
Annualized Cost/Truck'
Annualized Cost/Truck as a X of suggested
Manufact. Retail Price. April, 1978, $4,233.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $3,400,000,000 in 1982.3
38 Trucks/Hour
Annualized Cost
Annualized Cost/Truck!
Annualized Cost/Truck as a % of suggested
°° Manufact. Retail Price, April, 1978, $4,233.2
Co Investment Cost of Control Alternative
*•" Investment Cost as a % of Planned Capital Expen-
ditures of $3,400,000,000 in 1982. 3
48 Trucks/Hour
Annualized Cost
Annualized Cost/Truck!
Annualized Cost/Truck as a % of suggested
Manufact. Retail Price, April, 1978, $4,233.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $3,400,000,000 in 1982. 3
I IA
$ 850,000
$.47
.01%
• $ ,390,000
.01%
$1,070,000
$.59
.01%
$ 500,000
.02%
$1,350,000
$.74
.02%
$ 630,000
.02%
IB-T
$9,780.000
$5.38
.13%
$7,830,000
.23%
$12.300,000
$6.76
.16%
$9,220,000
.27%
$15,600,000
$8.58
.20%
$12,700,000
.37%
IB-C
$7,240,000
$3.98
.09%
$10,100,000
.30%
$9,140,000
$5.02
.12%
$12,700,000
.37%
$11.600,000
$6.38
.15%
$16,100,000
.47%
II-T
$10,340,000
$5.68
.13%
$8,440,000
.25%
$13.100,000
$7.20
.17%
$10,100,000
.30%
$16,400,000
$9.02
'.21%
$13.600,000
.40%
II-C
$7,660,000
$4.21
.10%
$10,800,000
.32%
$9,690,000
$5.33
.13%
$13.600,000
.40%
$12.230,000
$6.72
.16%
$17,200,000
.51%
'Total annualized costs were spread over the 1982 production volume of 1,819,000 trucks. This was judged
consistent with the industry's pricing policies.
2The April 1978 published list price, as reported in Automotive News, was deemed acceptable as a base price for
comparison purposes. It was assumed that the additional price of optional equipment would offset any price
discount by the dealer.
3This figure was an estimate provided by C. Cavalieri of the Bank of America
-------
Table 8-45
ABSOLUTE AND RELATIVE INCREMENTAL CONTROL COSTS
(4th
Quarter 1977 Dollars)
(Light-Duty Trucks -
Ford)
Alternatives
Line Speed/ Cost Category I
30 Trucks/hour
Annualized Cost
Annualized Cost/Truck*
Annualized Cost/Truck as a % of suggested
Manufact. Retail Price, April, 1978, $4,221.2
Investment Cost of Control Alternative
investment Cost as a % of Planned Capital Expen-
ditures of $2,400,000,000 in 1980.3
38 Trucks/Hour
Annualized Cost
Annualized Cost/Truck^
Annualized Cost/Truck as a % of suggested
oo Manufact. Retail Price, April, 1978, $4,221.2
Ł2 Investment Cost of Control Alternative
CTI Investment Cost as a % of Planned Capital Expen-
ditures of $2,400,000,000 in 1980.3
48 Trucks/Hour
Annualized Cost
Annualized Cost/Truck^
Annualized Cost/Truck as a % of suggested
Manufact. Retail Price, April, 1978, $4,221.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $2,400,000.000 in 1980. 3
IA
$1,990.000
$1.49
.04%
$5.650.000
.24%
$2,520.000
$1.89
.04%
$7,150,000
.30%
$3,180,000
$2.39
.06%
$9,050,000
.38%
IB-T
$3,260,000
$2.45
.06%
$2,910,000
.12%
$4,100,000
$3.08
.07%
$3,930,000
. .16%
$5,180,000
$3.89
.09%
$4,420,000
.18%
IB-C
$2,420,000
$1.82
.04%
$3.510,000
.15%
$3,030,000
$2.27
.05%
$4,340,000
.18%
$3,820,000
$2.87
.07%
$5,450,000
.23%
Il-T
$3,830,000
$2.87
.07%
$3,520.000
.15%
$4,830.000
$3.62
.09%
$4,830,000
.20%
$6,070,000
$4.55
.11%
$5,380.000
.22%
1I-C
$2,830,000
$2.12
.05%
$4,200.000
.18%
$3.580.000
$2.69
.06%
$5,270.000
.22%
$4,490,000
$3.37
.08%
$6, SOU, 000
.27%
'Total annualized costs were spread over the 1980 production volume of 1,333,000 trucks. This was judged
consistent with the industry's pricing policies.
2The April 1978 published-list price, as reported in Automotive News, was deemed acceptable as a base price for
comparison purposes. It was assumed that the additional price of optional equipment would offset any price
discount by the dealer.
figure was an estimate provided by C. Cavalieri of the Bank of America.
-------
Table 8-16
ABSOLUTE AND RELATIVE INCREMENTAL CONTROL COSTS
(4th Quarter 1977 Dollars)
(Passenger Car - Chrysler)
Line Speed/Cost Category
10 Passenger Cars/Hour
Annuali zed Cost
Annualized Cost/Passenger Carl
Annualized Cost/Passenger Car as a % of suggested
Manufact. Retail Price, April, 1978, $3,706.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $780,000,000 in 1980.3
55 Passenger Cars/Hour
Co Annualized Cost
• Annualized Cost/Passenger Carl
-5 Annualized Cost/Passenger Car as a % of suggested
Manufact. Retail Price, April, 1978, $3,706.z
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $780,000,000 in 1980. 3
85 Passenger Cars/Hour
Annualized Cost
Annualized Cost/Passenger Carl
Annualized Cost/Passgener Car as a % of suggested
Manufact. Retail Price, April, 1978, $3,706.2
Investment Cost of Control Alternative
Investment Cost as a % of Planned Capital Expen-
ditures of $780,000,000 in 1980. J
I IA
12,660,000
$1.76
.05%
$7,530,000
1.0*
$3,640,000
.$2.40
.06%
$10,300,000
1.3%
$5,620,000
$3.71
.IX
$16,000,000
2. IX
Alternatives
1B-T
$4,110.000
$2.71
.07*
$3,540,000
.5*
$5,620,000
$3.71
.1%
$4,630,000
.6%
$8,610,000
$5.68
.2%
$7,000,000
.9%
IU-C
$3,040,000
$2.01
.05%
$4,350,000
.6%
$4,150,000
$2.74
.07%
$5,850,000
.8%
$6,360,000
$4.20
.1%
$8,940,000
1.1X
II -T
$4,880,000
$3.22
.09%
$4,460,000
.6%
$6.610,000
$4.36
.12%
$5.640,000
.7%
$10.100,000
$6.67
.2%
$8,460.000
1.1X
ll-C
$3,610.000
$2.38
.06%
$5,314,000
.7%
$4,890,000
$3.23
.09%
$7,000,000
.9%
$7,480,000
$4.94
.1%
$10.620,000
1.4%
'Total annualized costs were spread over the 1980 production volumq of 1,515,000 passenger cars. This was judged
consistent with the industry's pricing policies.
^The April 1978 published list price, as reported in Automotive News, was deemed acceptable as a base price for
comparison purposes. It was assumed that the additional price of 'optional equipment would offset any price
discount by the dealer.
^Estimate is based on data appearing in the June, 1978 issue of Fortune.
-------
annualized costs are, respectively, .1% of General Motors suggested list
price for its lowest-priced passenger car and only .2% of the suggested
list price for its lowest-priced light-duty truck. The capital invest-
ment required for controlling both lines, assuming that the highest
annualized cost option was adopted by General Motors, is slightly less
than 1% of the firm's planned annual capital expenditures for 1982.
For Ford, the annualized cost per truck is $4.55 at most. This
is only .1% of the suggested list price for Ford's lowest-priced light-
duty truck. The corresponding capital investment requirement, if Ford
selected this control option and line speed, is less than .3% of-Ford's
planned annual capital expenditures for 1980.
For Chrysler, annualized costs per passenger car would be, at most,
$6.67, which amounts to only a .2% of Chrysler's suggested list price for
its lowest-priced car. Should Chrysler choose this option, 1.1% of its
planned capital expenditures for 1980 would be needed for this purpose.
As is evident in Tables 8-43, 8-44, 8-45, and 8-46, control costs
for each manufacturer tend to become higher as line speeds increase.
However, the control of hydrocarbon emissions is only one of many factors
that influence assembly line speed and construction, and, of itself, should
not strongly affect decisions in that area since the costs involved are
relatively insignificant.
8.4.3 • Potential Price Effect
Several factors must be considered in analyzing potential price
increases attributable to New Source Performance Standards. For one
-------
thing, not every manufacturer will incur NSPS-related cost increases in the
same year by reason of new assembly line construction. Both.Chrysler and
Ford will probably incur such costs earlier than General Motors, and all
firms in the industry, including those not impacted by 1983, will eventually
face NSPS-related cost increases.
Another point to be considered is that it will probably not be pos-
sible to determine which portion of the firm's price increase in any given
year is reflecting NSPS-related costs since, as a rule, current prices do
not reflect current cost in the automotive industry.
The ability of Ford and Chrysler to adjust their revenue functions
so as to effect an NSPS-related price change will depend upon the pricing
behavior of General Motors, the industry price leader. Ford and Chrysler
can adjust their revenue functions only within the constraints imposed
by the degree, timing and nature of price changes announced by General
Motors.
A consideration of Ford's desired price increase relative to that of
General Motors suggests that there should be no adverse effects on Ford's
profitability function regardless of the size, timing, or nature of the
change. The effect on Chrysler's revenue function is less predictable.
Critical to Chrysler's ability to adjust its revenue function is the nature
and magnitude of General Motor's desired price change. If future price
changes by General Motors are not of the nature and magnitude to allow
Chrysler to pass along the entire NSPS increase, then Chrysler's profit-
ability function will in all probability be somewhat adversely affected.
Recently, General Motors announced a new price increase strategy
that would permit small price increases to take place over a model year,
8-89
-------
as frequently as the firm deems necessary. By eliminating the traditional
annual increase in favor of the new system, manufacturers would appear to
be recovering cost increases more quickly. While General Motors' pricing
strategy imposes constraints on the ability of other members of the industry
to recover costs, the new pricing strategy may provide some relief in cost
recovery. It is also possible that the system will "flatten out" a degree of
the cyclical nature of sales. In effect, consumer purchasing patterns may
become more consistent throughout the year and less negatively influenced by
one large annual increase. To the extent that sales volume increase consis-
tently over the year, cost recovery may take place rapidly enough to permit
lower total annual increases while maintaining target rates of return.
Annual price increases for new cars have averaged approximately 5%
over the past five years and 4.38% over the past 10 years. The magnitude
of hydrocarbon emission control cost increases, is, at most, a .1% per car
and .2% per light-duty truck for General Motors. For Ford, the cost increase
is .1% per light-duty truck and for Chrysler, .2% per car. Since these price
changes are based on the lowest-priced vehicle for each manufacturer, the
percentage change should become almost infintesimal when compared with the
range of vehicle prices for each manufacturer. It is apparent that the rela-
tive magnitude of these projected NSPS-r.elated cost increases to historical
average price increases is small. In itself, they should not cause signifi-
cant cost-price increases for cars or light-duty trucks through 1983.
8.4.4 Sensitivity Analysis
The economic impact that has been projected in this chapter assumes
that market shares of each company will remain constant through 1983. To
8-90
-------
give recognition to the possibility that these shares could shift, a sensi-
tivity analysis, based on the assumption that each company had regained the
highest market share it had held in the past five years, was conducted.The
test indicated that were these market shares possible, General Motors would
need one additional truck line, Ford would need one car line and one addi-
tional truck line, Chrysler would need two additional car line and a truck
line, and American Motors would need a car line.
It should be noted in this context that it is obviously impossible
for all companies to achieve their top market shares simultaneously since
the total share would add up to more than 100%. In any case, the annualized
costs involved would still be minimal with .7% increase for cars and .2%
increase for trucks being the largest single unit price increase.
The sensitivity test did not indicate any restructuring of relative
positions within the industry. There were indications, however, that if
market shares for Chrysler and/or American Motors increased appreciably in
the passenger car market, there could be a resultant adverse effect on pro-
fit margins, since these firms would be producing more units with associated
NSPS cost increases and would still be in the position of being constrained
in passing along those costs by whatever pricing action was being taken by
General Motors. However, the probability that either firm will be able to
recapture a substantially higher market share is remote.
8.5 Potential Socioeconomic and Inflationary Impacts
The projected economic impact of each considered alternative control
system is small and the costs of NSPS should not, by themselves, preclude
construction of grass roots new lines. Output and employment effects, if
3-91
-------
they do occur, should be insignificant.
Total investment costs to achieve compliance by 1983, as shown in
Table 8-47, are projected to be approximately $47 million. The fifth-year
annualized costs, including depreciation and interest, are estimated at
approximately S57 million. The maximum anticipated unit price increase
is 1%.
8-92
-------
Table 8- 47
INFLATIONARY IMPACT ASSESSMENT
No. of Fifth-Year Investment Number of Vehicles
Lines Annualized Costs Costs Impacted
Manufacturer
(ooo's)
(ooo's)
(ooo's)
General Motors Corp.
$40,300
$32,900
8,366
Ford Motor Co.
$ 6,070
$ 5,380
1,521
00
10
CO
Chrysler Corp.
$10,100
$ 8,460
1,657
Totals
$56,470
$46,.740
11.544
-------
9. RATIONALE
9.1 SELECTION OF SOURCE AND POLLUTANTS
Volatile organic compounds (VOC) are organic compounds, measured by
Reference Methods 24 and 25, which are precursors to photochemical oxidants.
There has been some confusion in the past with the use of the term "hydro-
carbons." In addition to being used in the most literal sense, the term
"hydrocarbons" has been used to refer collectively to all organic chemicals.
Some organics which are photochemical oxidant precursors are not hydro-
carbons (in the strictest definition) and are not always used as solvents.
For purposes of this discussion, organic compounds include all compounds of
carbon except carbonates, metallic carbides, carbon monoxide, carbon dioxide
and carbonic acid.
Ozone and other photochemical oxidants result in a variety of adverse
impacts on health and welfare, including impaired respiratory function, eye
irritation, deterioration of materials such as rubber, and necrosis of
plant tissue. Further information on these effects can be found in the
April, 1978 EPA document "Air Quality Criteria for Ozone and Other Photo-
chemical Oxidants," EPA-600/8-78-004. This document can be obtained from
the EPA library at the address cited above.
Industrial coating operations are a major source of air pollution
emissions of VOC. . Most coatings contain organic solvents which evaporate
upon drying of the coating, resulting in the emission of VOC. Among the
largest individual operations producing VOC emissions in the industrial
coating category are automobile and light-duty truck surface coating opera-
tions. Automobile and light-duty truck manufacturers employ a variety of
surface coatings, most often enamels and lacquers, to produce the protec-
9-1
-------
tive and decorative finishes of their product. These coatings normally use
an organic solvent base, which is released upon drying.
As required by the Clean Air Act Amendments of 1977, a priority list
has been developed for use in developing standards of performance through
1982. Automobile and light-duty truck surface coating operations rank 27
out of 59 on this list of sources to be controlled for VOC emissions.
The surface coating operation is an integral part of an automobile or
light-duty truck assembly plant, accounting for about one-quarter to one-third
of the total space occupied by a typical assembly plant. Surface coatings
are applied in two main steps, prime coat and topcoat. Prime coats may be
water-based or organic solvent-based. Water-based coatings use water as
the main carrier for the coating solids, although these coatings normally
contain a small amount of organic solvent. Solvent-based coatings use
organic solvents as the coating solid carrier. Currently about half of the
domestic automobile and light-duty truck assembly plants use water-based
prime coats.
Where water-based prime coating is used, it is usually applied by
electrodeposition (EDP). The EDP coat is normally followed by a "guide
coat," which provides a suitable surface for application of the topcoat.
The guide coat may be water-based or solvent-based.
Automobile and light-duty truck topcoats presently being used are
almost entirely solvent-based. One or more.applications of topcoats are
applied to ensure sufficient coating thickness. An oven bake may follow
each topcoat application, or the coating may be applied wet on wet.
In 1976, nationwide emissions of volatile organic compounds from
automobile and light-duty truck surface coating operations totaled about
9-2
-------
135,000 metric tons. Prime and guide coat operations accounted for about
50,000 metric tons with the remaining 85,000 metric tons being emitted from
topcoat operations. This represents almost 15 percent of the volatile
organic emissions from all industrial coating operations.
Volatile organic compounds comprise the major air pollutant emitted by
automobile and light-duty truck assembly plants. Technology is available
to reduce VOC emissions and thereby reduce the formation of ozone and other
photochemical oxidants. Consequently, automobile and light-duty truck
surface coating operations have been selected for the development of stan-
dards of performance.
9.2 SELECTION OF AFFECTED FACILITIES
The prime coat, guide coat, and topcoat operations usually account for
more than 80 percent of the VOC emissions from automobile and light-duty
truck assembly plants. The remaining VOC emissions result from final top-
coat repair, cleanup, and coating of various small component parts. These
VOC emission sources are much more difficult to control than the main
surface coating line for several reasons. First, water-based coatings
cannot be used for final topcoat repair, since the high temperatures
required to cure water-based coatings may damage heat sensitive components
which have been attached to the vehicle by this stage of production.
Second, the use of solvents is required for equipment clean-up procedures.
Third, add-on controls, such as incineration, cannot be used effectively on
these cleanup operations because they are composed of numerous small opera-
tions located throughout the plant. Since prime coat, guide coat, and
topcoat operations account for the bulk of VOC emissions from automobile
and light-duty truck assembly plants, and control techniques for reducing
9-3
-------
VOC emissions from these operations are demonstrated, they have been selected
for control by standards of performance.
The "affected facility" to which the proposed standards would apply
could be designated as the entire surface coating line or each individual
surface coating operation. A major consideration in selecting the affected
facility was the potential effect that the modification and reconstruction
provisions under 40 CFR 60.14 and 60.15, could have on existing assembly
plants. These regulations apply to all source categories for which a
standard of performance has been promulgated. A modification is any physical
&
or operational change in an existing facility which increases air pollution
from that facility. A reconstruction is any replacement of components of
an existing facility which is so extensive that-the capital cost of the new
components exceeds 50 percent of the capital cost of a new facility. For
the standard of performance to apply, EPA must conclude that it is technically
and economically feasible for the reconstructed facility to meet the standards.
Many automobile and light-duty truck assembly plants that have a spray
prime coat system will be switching to EDP prime coat systems in the future
to reduce VOC emissions to comply with revised SIP's. The capital cost of
this change could be greater than 50 percent of the capital cost of a new
surface coating line. If the surface coating line were chosen as the
affected facility, and if this switch to an EDP prime coat system were
considered a reconstruction of the surface coating line, all surface coating
operations on the line would be required to comply with the proposed stan-
dards. Most plants would be reluctant to install an EDP prime coat system
to reduce VOC emissions if, by doing so, the entire surface coating line
might then be required to comply with standards of performance. By desig-
nating the prime coat, guide coat, and topcoat operations as separate
9-4
-------
affected facilities, this potential problem is avoided. Thus, each surface
coating operation (i.e., prime coat, guide coat, and topcoat) has been
selected as an affected facility in the proposed standards.
9.3 SELECTION OF BEST SYSTEM OF EMISSION REDUCTION
As discussed in Chapter 4, several techniques, or combinations of
techniques, have the potential for reducing VOC emissions from automobile
and light-duty truck surface coating operations. This section will present
a summary of each of these control techniques, identify the control tech-
niques which are chosen as candidate "best systems," and, based on a com-
T
parison of the impacts of each candidate system, will recommend the best
system of emission reduction.
Potential control techniques can be categorized as either new coating
systems or add-on controls. The term new coatings refers to application of
coating materials containing relatively low levels of organic solvents.
Such materials include water-based coatings, high solids coatings, and
powder coatings. Table 4.2 on page 4-38 presents a summary of the theore-
tical emission reduction potential associated with various new coatings.
Add-on controls are used to reduce emissions by either recovering or de-
stroying the solvents before they are emitted into the atmosphere. Such
techniques include thermal and catalytic incinerators and carbon adsorbers.
9.3.1 NEW COATINGS
The term "water-based" refers to any coating material which uses water
instead of an organic solvent as the carrier. Most of the water-based
coating material used in the automobile industry is used as primer and is
applied by electrodeposition (EDP). Application of coatings by EDP involves
dipping the automobile or truck to be coated into a bath containing a
dilute water solution of the coating material. When electrical charges of
9-5
-------
opposite polarity are applied to the dip tank and part, the coating material
deposits on the vehicle. Many EDP systems presently in use are anodic
systems in which the vehicle to be coated is given a positive charge.
Cathodic EDP, in which the vehicle is negatively charged, is a new technology
which is expanding rapidly in the automobile industry. Cathodic EDP pro-
vides better corrosion resistance and lower cure temperatures than anodic
systems. Cathodic systems are also capable of applying better coverage in
deep recesses of parts. It is expected that the automobile industry will
convert to cathodic systems as rapidly as schedules and equipment will
permit.
The film thickness which can be applied by EDP is limited by the
insulating effect which the deposited layer of coating creates. Due to the
limitation on film thickness, the EDP coat is usually followed by a spray
application of an intermediate coat (the "primer surfacer" or guide coat)
before topcoat application. The guide coat is used to build film thickness,
permit sanding, and provide a more suitable surface for the application of
the topcoat. Even in the case of spray prime, a guide coat is normally
applied over the primer to improve the surface prior to topcoating.
Use of water-based coatings for guide coat and topcoat is limited to
application by conventional spraying devices. Electrostatic spray, in
which the coating material is given an electrical charge, is considered
unsafe for large operations using water-based paints. Presently there are
only two domestic plants which use water-based coatings for the guide coat
and topcoat.
High solids coatings are a relatively new family of coating materials,
consisting of from 45 to 60 percent solids, that are being investigated in
9-6
-------
the automotive industry. The advantages of such coatings are their low
solvent content and, through the use of more reactive solvents, reduced
energy requirements for drying. One problem preventing the use of higher
solids coatings in the automobile and light-duty truck industry is their
high working viscosity, which makes these materials unsuitable for use in
many existing application devices. To overcome this problem, techniques
such as heated application and molecular weight reduction are being inves-
tigated, but so far these approaches have not proved technically feasible
for use in automobile and light-duty truck surface coating operations.
There are also some problems with the finish produced by high solids coatings.
Since the viscosity of the material is very high, it often produces an
uneven, or "orange peel," effect on the surface. High solids coatings are
also limited because they cannot be used in metallic finishes. This type
of finish accounts for about 50 percent of the domestic demand. It is
produced by adding small metal flakes to the paint. As the paint dries,
these flakes become oriented parallel to the surface where they reflect
light and add a sparkling effect to the finish. With high solids coatings,
the viscosity of the paint prevents free movement of the flakes, and they
remain randomly oriented, producing a rough surface. Although high solids
coatings hold a great deal of promise, they are still an emerging technology
and have not been demonstrated in the automotive industry.
Powder coatings, are a special class of high solid coatings that
contain no organic solvents. They are applied by electrostatic spray as
100 percent solid materials in dry powder form. Currently, powder coatings
are being used on a limited basis for topcoating automobiles, both foreign
and domestic. Their application is severely limited, however, because they
9-7
-------
cannot be used in "metal!ic" automobile finishes. At present, therefore,
the most acceptable use of powder coatings is for small component parts
which are not highly visible in the finished vehicle.
9.3.2 ADD-ON CONTROLS
Incineration is the most universally applied technique for reducing
the emission of volatile organics from industrial processes. Two types of
incinerators are used, thermal (or direct fired) and catalytic. Thermal
incineration has been used to control emissions from bake ovens in automo-
bile and light-duty truck assembly plants. In practice these units normally
achieve VOC emission reductions of over 90 percent. Thermal incinerators
have not, however, been used for control of spray booth emissions. Typically,
spray booths exhaust a high volume stream (95,000 to 200,000 cubic liters
per second) with very low VOC concentration (about 50 ppm). Thermal incineration
of this exhaust stream would require a large amount of supplemental fuel.
Although oil can be used to fire thermal incinerators, natural gas is
normally used when it is available. This large impact on scarce fuels
precludes thermal incineration as a viable technology for control of spray
booth VOC emissions. There are, however, no technological problems with
the use of thermal incineration.
Catalytic incineration makes use of a metal catalyst (such as platinum
or palladium) to promote the oxidation of volatile organies into carbon
dioxide and water without use of a flame. Catalytic incineration permits
lower incinerator operating temperatures and, therefore, uses less energy
than thermal incineration. While catalytic incineration is not currently
being employed in the automobile and light-duty truck industry for control
of VOC emissions, there are no major technical problems which would pre-
9-8
-------
elude its use on bake oven exhaust gases. For spray booth emission control,
however, the same considerations apply as in the case of thermal incineration
(i.e., high air flow, low vapor concentration, and the need to incorporate
an efficient heat recovery system to minimize the need for auxiliary heating
of inlet air). In addition, natural gas must be used for air pre-heating
since oil firing tends to cause fouling of the catalyst.
Carbon adsorption has been used successfully to control solvent emis-
sions in a number of industrial applications. However, the ability of
carbon adsorption to control emissions from spray booths and bake ovens in
automobile and light-duty truck surface coating operations is uncertain.
The high volume/low VOC exhaust streams from spray booths would require
carbon adsorption units much larger than any that have ever been built.
Furthermore, spray booth exhaust contains water vapor, which would severely
impair the efficiency of the carbon bed by competing with the VOC for
available binding sites. Also, a highly efficient filtering system would
be needed to remove particulate matter from the spray booth exhaust stream
in order to prevent plugging of the carbon bed.
An additional major impediment to the use of carbon adsorption for
paint bake ovens in automobile and light-duty truck coating operations is
the high temperature (100°C to 200°C) of the oven exhaust stream. At this
high temperature many volatile organics would not be adsorbed in the carbon
bed. In order to solve the problem, huge refrigeration units would be
required for cooling this gas stream before it is passed through the carbon
bed. In addition, the volatile organics in the oven exhaust are a much
higher boiling component than those in the spray booth exhaust, making
regeneration of the carbon bed more difficult. Futhermore, the high oven
9-9
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temperatures result in the polymerization of some VOC into resinous materials
which could foul the carbon bed. As a result, filtering of the oven exhaust
stream would be required. Equipment for the cooling and filtering of
automobile and light-duty truck paint bake oven exhaust streams, however,
has not been demonstrated.
To summarize,use of water-based coatings and thermal or catalytic
incineration are two well demonstrated and feasible techniques for control-
ling emissions of VOC from automobile and light-duty truck coating opera-
tions. Based upon the use of these two VOC emission control techniques,
two regulatory options can be identified as candidates for the "best tech-
nological system of continuous emission reduction." Either one of these
could serve as the basis for standards. These two regulatory options are
summarized in Table 9-1 and are compared against a base case consisting of
water-based prime coat (EDP) and solvent-based guide coat and topcoat.
This base case is representative of VOC emissions from new automobile and
light-duty truck surface coating operations capable of meeting existing
State Implementation Plan (SIP) emission limits.
9.3.3 IMPACTS
Chapters 7 and 8 of the BID discuss in detail the impacts associated
with the proposed standards. The economic, environmental, and energy
impacts of proposed standards are normally expressed as incremental dif-
ferences between a facility complying with a proposed new source performance
standard and one meeting a typical State Implementation Plan (SIP) emission
standard. In the case of automobile and light-duty truck surface coating
operations, most of the existing facilities are located in areas which are
considered nonattainment areas for purposes of achieving the National
9-10
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Table 9-1. AUTOMOBILE AND LIGHT-DUTY TRUCK COATING LINES -
EMISSION CONTROL OPTIONS EVALUATED
Emission Control System
Base Case
1. Primer - water-based coatings applied by EDP
2. Guide coat - solvent-based coatings applied by air spray
3. Topcoat - solvent-based coatings applied by air spray
Option I(A)
1. Primer - water-based coatings applied by EDP
2. Guide coat - water-based coatings applied by air spray
3. Topcoat - water-based coatings applied by air spray
Option I(B)
1. Primer - water-based coatings applied by EDP
2. Guide coat - solvent-based coatings applied by air spray
3. Topcoat - solvent-based coatings applied by air spray with incineration of spray booth and
oven exhaust1
Option II
1. Primer - water-based coating applied by EDP
2. Guide coat - solvent-based coatings applied by air spray with incineration of spray booth and
oven exhaust1
3. Topcoat - solvent-based coatings applied by air spray with incineration of spray booth and oven
exhaust1
Emissions from Model
Plant
(Metric Tons/Year)
Light-Duty
Automobile Truck
1775
373
435
212
1273
278
301
147
% Reduction
From Base Case
Light-Duty
Automobile Truck
—
79
76
88
~ •
78
76
88
ID
I
'Emissions based on incineration with 90% efficiency.
-------
Ambient Air Quality Standard (NAAQS) for ozone. Most new facilities are
also expected to locate in similar areas. The states are in the process of
revising their SIP's for these areas and are expected to include revisions
to their emission limitations applicable to automobile and light-duty truck
surface coating operations. The actual incremental impacts of the proposed
standards will be determined by the final emission limitations adopted by
the States. For the purposes of this comparison, however, the environmental,
energy, and economic impacts of the proposed standards are based on existing
SIP's which do not require VOC control for this source category. As shown
in Table 9-1, standards based on Option I would lead to a reduction in VOC
emissions of about 80 percent, and standards based on Option II would lead
to a reduction in emissions of about 90 percent compared to VOC emissions
from an uncontrolled automobile or light-duty truck assembly plant. In
1983 national emissions of VOC would be reduced by about 4,800 metric tons
with standards based on Option I, and about 5,400 metric tons with standards
based on Option II. Thus, both regulatory options would result in a signifi-
cant reduction in VOC emissions from automobile and light-duty truck surface
coating operations.
With regard to water pollution, standards based on Regulatory Option
II would have essentially no impact. Similarly, standards based on Regu-
latory Option I(B) would have no water pollution impact. Standards based
on Option I(A), however, would result in a slight increase in the chemical
oxygen demand (COD) of the wastewater discharged from automobile and light-
duty truck surface coating operations within assembly plants. This increase
is due to water-miscible solvents in the water-based guide coats and topcoats
which become dissolved in the wastewater. The increase in COD of the
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wastewater, however, would be small relative to current COD levels at
plants using solvent-based surface coatings and meeting existing SIP's. In
addition, this increase would not require the installation of a larger
wastewater treatment facility than would be built for an assembly plant
which used solvent-based surface coatings.
The solid waste impact of the proposed standards would be negligible.
The volume of sludge generated from water-based surface coating operations
is approximately the same as that generated from solvent-based surface
coating operations. The solid waste generated by water-based coatings,
however, is very sticky, and equipment clean-up is more time consuming than
for solvent-based coatings. Sludge from either type of system can be
disposed of by conventional landfill procedures without leachate problems.
With regard to energy impact, standards based on Regulatory Option
I(A) would increase the energy consumption of surface coating operations at
a new automobile or light-duty truck assembly plant by about 25 percent.
Option I(B) would cause an increase of about 150 to 425 percent in energy
consumption. Standards based on Regulatory Option II would result in an
increase of 300 to 700 percent in the energy consumption of surface coating
operations at a new automobile or light-duty truck assembly plant. The
range in energy consumption for those options which are based on use of
incineration reflects the difference between catalytic and thermal incinera-
tion.
The relatively high energy impact of standards based on Regulatory
Option I(B) and Regulatory Option II is due to the large amount of incinera-
tion fuel needed. Standards based on Option II would increase energy
consumption at a new automobile and light-duty truck assembly plant by the
9-13
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equivalent of about 200,000 to 500,000 barrels of fuel oil per year, depending
upon whether catalytic or thermal incineration was used. Standards based
on Regulatory Option I(B) would increase energy consumption by the equivalent
of about 100,000 to 300,000 barrels of fuel oil per year.
Standards based on Regulatory Option I(A) would increase the energy
consumption of a new automobile and light-duty truck assembly plant by the
equivalent of about 18,000 barrels of fuel oil per year. This increase in
energy consumption is due to the use of air conditioning, which is necessary
with the use of water-based coatings, and the increased fuel required in
the bake ovens for curing water-based coatings.
Growth projections indicate that four new automobile and light-duty
truck assembly lines (two automobile and two truck lines) will be built by
1983. Based on these projections, standards based on Regulatory Option
I(A) would increase national energy consumption in 1983 by the equivalent
of about 72,000 barrels of fuel oil. Standards based on Regulatory Option
I(B) would increase national energy consumption in 1983 by the equivalent
of 400,000 to 1,200,000 barrels of fuel oil, depending on whether catalytic
or thermal incineration were used. Standards based on Regulatory Option II
would increase national energy consumption in 1983 by the equivalent of
800,000 to 2,000,000 barrels of fuel oil, again depending on whether cata-
lytic or thermal incineration were used.
The economic impacts of standards based on each regulatory option were
estimated using the above mentioned growth projection of four new assembly
lines by 1983. Incremental control costs were determined by calculating
the difference between the capital and annualized costs of new assembly
plants controlled to meet Regulatory Options I(A), I(B), and II, respec-
9-14
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tively, with the corresponding costs for new plants designed to comply with
existing SIP's. Of the four assembly plants projected by 1983, two were
assumed to be General Motors lines, one a Ford line, and the other a Chrysler
line. In the absence of standards of performance, it was assumed the
General Motors assembly plants would be designed to use solvent-based
lacquer surface coatings, and the Ford and Chrysler assembly plants would
be designed to use solvent-based enamel surface coatings. There are basic
design differences between these two types of surface coatings which have a
substantial impact on the magnitude of the costs estimated to comply with
standards of performance. Lacquer surface coating operations, for example,
require much larger spray booths and bake ovens than enamel surface coating
operations. Water-based systems also require large spray booths and bake
ovens; thus, the incremental capital cost of installing a water-based
system in a plant which would otherwise have used a lacquer system, is
relatively low. The incremental capital costs differential, however, would
be much larger if the plant would have been designed for an enamel system.
Tables 9-2 and 9-3 summarize the economic impacts of the proposed
standards on typical size plants. Table 9-2 presents the incremental costs
of the various control options for a plant which would have used solvent-
based lacquers. Table 9-3 presents similar costs for plants which would
have been des.igned to use solvent-based enamels. While these tables present
incremental costs for passenger car plants, light-duty truck plants would
have similar cost differentials. In all cases, it is assumed the plants
would install a water-based EDP prime system in the absence of standards of
performance. Therefore, no incremental costs associated with EDP prime
coat operations are included in the costs presented in Tables 9-2 and 9-3.
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Table 9-2. INCREMENTAL CONTROL COSTS1
(Compared to the Costs of a Lacquer Plant)
UD
Capital Cost of Control
Alternative
Annualized Cost of Control
Alternative
Incremental Cost/Vehicle
Produced at this Facility
KA)
Regulatory Options
KB)
II
Water-Based Coatings Thermal
Catalytic
Thermal
$ 720,000
$1,550,000
$7.34
$68.66
$50.66
$73.39
Catalytic
$11,800,000 $15,000,000 $12,800,000 $16,200,000
$14,500,000 $10,700,000 $15,500,000 $11,500,000
$54.45
Assumes a line speed of 55 vehicles per hour and an annual production of 211,200 vehicles.
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Table 9-3. INCREMENTAL CONTROL COSTS1
(Compared to the Costs of an Enamel Plant)
Capital Cost of Control
Alternative
Annualized Cost of Control
Alternative
Incremental Cost/Vehicle
Produced at this Facility
KA)
Regulatory Options
KB)
II
Water-Based Coatings Thermal
Catalytic
Thermal
Catalytic
$10,300,000
$ 3,640,000
$17.23
$ 4,630,000 $ 5,850,000 $ 5,640,000 $ 7,000,000
$ 5,620,000 $ 4,150,000 $ 6,610,000 $ 4,890,000
$26.61
$19.65
$31.30
$23.15
Assumes a line speed of 55 vehicles per hour and an annual production of 211,200 vehicles.
-------
A nominal production rate of 55 passenger cars per hour was assumed for
both plants. Tables 9-2 and 9-3 show incremental costs per vehicle produced
at each new facility. The manufacturers would probably distribute these
incremental costs over their entire annual production to arrive at purchase
prices for the automobiles and light-duty trucks.
Incremental capital costs for using incineration to reduce VOC emissions
from solvent-based lacquer plants to levels comparable to water-based
plants are much larger than they are for using incineration on a solvent-
based enamel plant. This large difference in costs occurs because lacquer
plants have larger spray booth and bake oven areas than enamel plants and,
therefore, a larger volume of exhaust gases. Since larger incineration
units are required, the incremental capital costs of using incineration to
control VOC emissions from a solvent-based lacquer plant are about 15 to 25
times greater than they are for using water-based coatings. Similarly,
energy consumption is much greater; hence, the annualized costs of using
incineration are about ten times greater than they are for using water-based
coatings.
On the other hand, the incremental capital costs of controlling VOC
emissions from new solvent-based enamel plants by the use of incineration
are only about one-half the incremental capital costs between a new solvent-
based enamel plant and a new water-based plant. Due to the energy consumption
associated with incinerators, however, the incremental annualized costs of
using incineration with solvent-based enamel coatings could vary from as
little as 15 percent more to as much as 90 percent more than the annualized
costs of using water-based coatings.
9-18
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While the incremental capital costs of building a plant to use water-
based coatings can be larger or smaller than the costs of using incineration,
depending upon whether a solvent-based lacquer plant or a solvent-based
enamel plant is used as the starting point, the annualized costs of using
water-based coatings are always less than they are for using incineration.
This is due to the large energy consumption of incineration units compared
to the energy consumption of water-based coatings.
Since the incremental annualized costs are less with Option I(A) than
with Option I(B), it is assumed in this analysis that Option I(A) would be
incorporated at any new, modified, or reconstructed facility to comply with
standards based on Regulatory Option I. As noted, four new assembly plants
are expected to be built by 1983. The incremental capital cost to the
industry for these plants to comply with standards based on Regulatory
Option I would be approximately $19 million. The corresponding incremental
annualized costs would be about $9 million in 1983. If standards are based
on Regulatory Option II, it is expected that industry would choose catalytic
incineration because its annualized costs are lower than thermal incineration.
Based on this assumption, the incremental capital costs for the industry
under Regulatory Option II would be approximately $42 million, and the
incremental annualized costs by 1983 would be about $30 million. For
standards based on either Regulatory Option I or Regulatory Option II, the
increase in the price of an automobile or light-duty truck that is manu-
factured at one of the new plants would be less than one percent of the
base price of the vehicle.
9.3.4 BEST SYSTEM OF EMISSION REDUCTION
Both Regulatory Options I and II achieve a significant reduction in
VOC emissions compared to automobile and light-duty truck assembly plants
9-19
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controlled to comply with existing SIP's, and neither option creates a
significant adverse impact on other environmental media. Standards based
on Regulatory Option II, however, would have as much as 10 to 25 times the
adverse impact on energy consumption as standards based on Regulatory
Option I, while only achieving 10 to 15 percent more reductions in VOC
emissions. Thus, Regulatory Option I was selected as the best system of
continuous emission reduction, considering costs and nonair quality health,
environmental, and energy impacts.
9.4 SELECTION OF FORMAT FOR THE PROPOSED STANDARDS
A number of different formats could be selected to limit VOC emissions
from automobile and light-duty truck surface coating operations. The
format ultimately selected must be compatible with any of the three different
control systems that could be used to comply with the proposed standards.
One control system is the use of water-based coating materials in the prime
coat, guide coat, and topcoat operations. Another control system is the
use of solvent-based coating materials and add-on VOC emission control
devices such as incineration. The third control system consists of the use
of high solids coatings applied at high transfer efficiencies. Although
these coatings are not demonstrated at this time, research is continuing
toward their development; hence, they may be used in the future.
The formats considered were emission limits expressed in terms of:
(1) concentration of emissions in the exhaust gases discharged to the
atmosphere; (2) mass emissions per unit of production; or (3) mass emis-
sions per volume of coating solids applied.
The major advantage of the concentration format is its simplicity of
enforcement. Direct emission measurements could be made using Reference
9-20
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Method 25. There are, however, two significant drawbacks to the use of
this format. Regardless of the control approach chosen, emission testing
would be required for each stack exhausting gases from the surface coating
operations (unless the owner or operator could demonstrate to the Admini-
strator's satisfaction that testing of representative stacks would give the
same results as testing all the stacks). This testing would be time consuming
and costly because of the large number of stacks associated with automobile
and light-duty truck surface coating operations. Another potential problem
with this format is the ease of circumventing the standards by the addition
of dilution air. It would be extremely difficult to determine whether
dilution air were being added intentionally to reduce the concentration of
VOC emissions in the gases discharged to the atmosphere, or whether the air
was being added to the application or drying operation to optimize perfor-
mance and maintain a safe working space.
A format of mass of VOC emissions per unit of production relates emis-
sions to individual plant production on a direct basis. Where water-based
coatings are used, the average VOC content of the coating materials could
be determined by using Reference Method 24. The volume of coating materials
used could be determined from purchase records. VOC emissions could then
be calculated by multiplying the VOC content of the coating materials by
the volume of coating materials used in a given time period, and dividing
the result by the number of vehicles produced in that time period. This
would provide a VOC emission rate per unit of production. Consequently,
procedures to determine compliance would be straightforward, although very
time consuming. This procedure would also require data collection over an
excessively long period of time.
9-21
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Where solvent-based coatings were used with add-on emission control
devices, stack emission tests could be performed to determine VOC emissions.
Dividing VOC emissions by the number of vehicles produced would again yield
VOC emissions per unit of production. This format, however, would not
account for differences in surface coating requirements for different
vehicles due to size and configuration. In addition, manufacturers of
larger vehicles would be required to reduce VOC emissions further than
manufacturers of smaller vehicles.
A format of mass of VOC emissions per volume of coating solids applied
also has the advantage of not requiring stack emission testing unless
add-on emission control devices are used to comply with the standards
rather than water-based coatings. The introduction of dilution air into
the exhaust stream would not present a problem with this format. The
problem of varying vehicle sizes and configurations would be eliminated
since the format is in terms of volume of applied solids regardless of the
surface area or number of vehicles coated. This format would also allow
flexibility in selection of control systems, for it is usable with any of
the control methods. Since this format overcomes the varying dilution air
and vehicle size problems inherent with the other formats, it has been
selected as the format for the proposed standards. Equations have been
developed to use this format with water-based coating materials as well as
with solvent-based coating materials in combination with high transfer
efficiencies and/or add-on emission controls devices. These equations are
included in the proposed standards.
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9.5 SELECTION OF NUMERICAL EMISSION LIMITS,
The numerical emission limits selected for the proposed standard are
as follows:
0 0.3 kilograms of volatile organic compounds per liter of applied
coating solids from prime coat operations
• 0.9 kilograms of volatile organic compounds per liter of applied
coating solids from guide coat operations
• 0.9 kilograms of volatile organic compounds per liter of applied
coating solids from topcoat operations
In all three limits the mass of VOC is expressed as carbon equivalent in
accordance with Reference Methods 24 and 25. These emission limits are
based on the use of water-based coating materials in the prime coat, guide
coat, and topcoat operations. The Control Techniques Guideline (CTG)
document developed by EPA on automobile and light-duty truck surface coating
operations recommends the use of this same technology. The limits in the
CTG are expressed in pounds of VOC per gallon of coating (minus water) used
in the EDP system or the spray device. The limits in this proposed standard,
however, are referenced to the amount of coating solids which adhere to the
vehicle body. Therefore to compare the limits in the CTG to those proposed
here, it is necessary to account for the efficiency of applying the guide
coat and t.opcoat to the vehicle body. The emission limit for guide coat
operations is based on a transfer of technology from topcoat operations.
The guide coat is essentially a topcoat material, without pigmentation, and
water-based topcoats are available which can comply with the proposed
limits. Hence, the same emission limit is proposed for the guide coat
operation as for the topcoat operation.
9-23
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Because of the elevated temperatures present in the prime, guide, and
topcoat bake ovens, there may be additional amounts of "cure volatile" VOC
emitted. These "cure volatile" VOC emissions are present only at high
temperatures and are not measured in the analysis which is used to deter-
mine the VOC content of coating materials. Cure volatile VOC, however, are
believed to constitute only a small percentage of total VOC emissions.
Consequently, due to the complexity of measuring and controlling cure
volatile VOC emissions, they would not be considered in determining com-
pliance with the proposed standards.
A large number of coating materials are used in topcoat operations,
and each may have a different VOC content. Hence, an average VOC content
of all the coatings used in this operation would be computed to determine
compliance with the proposed standards. Either of two averaging techniques
could be used for computing this average. Weighted averages provide very
accurate results but would require keeping records of the total volume of
each different coating used. Arithmetic averages are not always as accurate;
however, they are much simpler to calculate. In the case of topcoat opera-
tions, normally 16 to 18 different coatings are used, and the VOC content
for most of these coatings is in the same general range. Therefore, an
arithmetic average would closely approximate the values obtained from a
weighted average. An arithmetic average would be calculated by summing the
VOC content of each surface coating material used in a surface coating
operation (i.e., guide coat or topcoat), and dividing the sum by the number
of different coating materials used. Arithmetic averages are also consistent
with the approach being incorporated into most revised State Implementation
Plans.
9-24
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For the EDP process, however, an arithmetic average VOC content is not
appropriate to determine compliance with the proposed standards. In an EDP
system, the coating material applied to an automobile or light-duty truck
body is replaced by adding fresh coating materials to maintain a constant
fluid level in the EDP coating tank. Three different types of materials
are usually added in separate streams—clear resin, pigment paste, and
solvent.
The clear resin and pigment paste are very low in VOC content (i.e.,
10 percent or less), while the solvent is very high in VOC content (i.e.,
90 percent or more). The solvent additive stream is only about 2 percent
of the total volume added. Consequently, an arithmetic average of the
three streams seriously misrepresents the actual amount of VOC added to the
EDP coating tank. Weighted averages, therefore, were selected for deter-
mining the average VOC content of coating materials applied by EDP.
If an automobile or light-duty truck manufacturer chooses to use a
control technique other than water-based coatings, the transfer efficiency
of the application devices used becomes very important. As transfer effi-
ciency decreases, more coating material is used, and VOC emissions increase.
Therefore, when add-on controls or high solids coatings are used to comply,
tranfer efficiency must be taken into account to determine equivalency to
water-based coatings.
Electrostatic spraying, which applies surface coatings at high transfer
efficiencies, is not considered safe for use with water-based surface
coatings in large operations because of the potential employee shock hazard.
Consequently, water-based surface coatings are applied by air-atomized
spray systems at a transfer efficiency of about 40 percent. The numerical
9-25
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emission limits included in the proposed standards were developed based on
the use of water-based surface coatings applied at a 40 percent transfer
efficiency. Therefore, if surface coatings are applied at greater than 40
percent transfer efficiency, surface coatings with higher VOC contents may
be used with no increase in VOC emissions to the atmosphere. Transfer
efficiencies for various means of applying surface coatings have been
estimated, based on information obtained from industries and vendors, as
follows:
Application Method . Transfer Efficiency
Air Atomized Spray 40 percent
Manual Electrostatic Spray 75 percent
Automatic Electrostatic Spray 95 percent
Electrodeposition (EDP) 100 percent
Frequently, more than one application method is used within a single
surface coating operation. In these cases a weighted average transfer
efficiency, based on the relative volume of coating sprayed by each method,
will be estimated. These situations are likely to vary among the different
manufacturers and the estimates, therefore, will be subject to approval by
the Administrator on a case-by-case basis.
9.6 SELECTION OF MONITORING REQUIREMENTS
To provide a means for enforcement personnel to ensure that emission
control measures adopted by a facility to comply with standards of perfor-
mance are properly operated and maintained, monitoring requirements are
generally included in standards of performance. Surface coating operations
which have achieved compliance with the proposed standards without the use
9-26
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of add-on VOC emission control devices would be required to monitor the
average VOC content (weighted averages for EDP and arithmetic averages for
guide coat and topcoat) of the coating materials used in each surface
coating operation. Generally, increases in the VOC content of the coating
materials would cause VOC emissions to increase. These increases could be
caused by the use of new coatings or by changes in the composition of
existing coatings. Therefore, following the initial performance test,
increases in the average VOC content of the coating materials used in each
surface coating operation would have to be reported as excess emissions on
a quarterly basis.
Where add-on control devices, such as incinerators, were used to
comply with the proposed standards, combustion temperatures would be monitored.
Following the initial performance test, decreases in the incinerator combus-
tion temperature would be reported as excess emissions on a quarterly
basis.
9.7 PERFORMANCE TEST METHODS
Reference Method 24, "Determination of Volatile Organic Compound
Content of Paint, Varnish, Lacquer, or Related Products," is proposed as
the test method to determine VOC emissions from the coating materials used
in each surface coating operation. Reference Method 25, "Determination of
Total Gaseous Nonmethane Volatile Organic Compound Emissions," is proposed
as the test method to determine the percentage reduction of VOC emissions
in add-on emission control devices.
9.8 MODIFICATIONS AND RECONSTRUCTIONS
During the development of the standards, the automobile industry
expressed concern that changes to assembly plants made only for the purpose
9-27
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of annual model changeovers would be considered a modification or reconstruc-
tion as defined in 40 CFR 60.14 and 60.15. A modification is any physical
or operational change in an existing facility which increases air pollution
from that facility. A reconstruction is any replacement of components of
an existing facility which is so extensive that the capital cost of the new
components exceeds 50 percent of the capital cost of a new facility. In
general, modified and reconstructed facilities must comply with standards
of performance. According the available information, changes to coating
lines for annual model changeovers do not cause emissions to increase
?
significantly. Further, these changes would normally not require a capital
expenditure that exceeds the 50 percent criterion for reconstruction.
Hence, it is very unlikely that these annual facility changes would be
considered either a modification or a reconstruction. Industry, however,
continued to express concern, stating that the intent of this standard
could be misinterpreted unless an exemption for annual model changeovers
was explicitly included in the standard. To avoid any possibility for such
a misinterpretation, the proposed standard states that changes to surface
coating operations made only to accomodate annual model changeovers are not
a modification or reconstruction.
9-28
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APPENDIX A
EVOLUTION OF PROPOSED STANDARDS
This study to develop proposed standards of performance for new surface
coating operations within the automotive industry began in 1973 under the
direction of Richard B. Atherton (OAQPS/ESED/ISB), Lead Engineer. In June
1975, EPA authorized DeBell and Richardson to continue the study, contract
number 68-02-2062, under the direction of Dave Patrick (OAQPS/ESED/CPB).
On March 30, 1976, James Berry (OAQPS/ESED/CPB) replaced Dave Patrick as
lead engineer. Table A-l lists the major events that occurred between
project initiation and October 1978 when Acurex Corporation was retained by
EPA to complete the study under contract number 68-02-3064 with Sims L. Roy
(OAQPS/ESED/SDB), as the lead engineer.
The overall objective of this study was to compile and analyze data in
sufficient detail to substantiate standards of performance. To accomplish
this objective, the investigators first acquired the necessary technical
information on: (1) coating operations and processes; (2) the release of
organic emissions into the atmosphere by this source and their controlla-
bility; and (3) the costs of demonstrated control techniques. A literature
search was conducted and data obtained from the following:
• U.S. Department of Commerce
t Federal Trade Commission Quarterly Reports
• Society of Manufacturing Engineers
• U.S. Government Printing Office
• National Technical Information Service
• Various Trade Journals
A-l
-------
Table A-l. MAJOR EVENTS, YEAR 1974 - MID 1978
Equipment Manufacturers Telephone Survey
Equipment Suppliers Telephone Survey
Surface Coating Equipment Manufacturers
OMB Approval of Questionnaire
Industry Completion of Questionnaires
Meeting to Discuss Economic Impacts
Draft Document, "Study to Support NSPS
for Automobile and Light-Duty Trucks," Published by EPA
EPA Memo Suggesting Standards of Performance Sent to Industry
NAPCTAC Meeting
Working Group Meeting
JACA Corporation Retained by EPA to Study Economic Impacts
PEDCo Retained by EPA to Prepare an Economic Impact Analysis
Centec Consultants, Inc. Retained by EPA to Revise Draft
Document
Meetings with Various Equipment Manufacturers, Suppliers
and Auto Makers and State Agencies (See Tables A-2, A-3, A-4,
8/11/75
8/15/75
8/20/75
9/26/75
12/75 - 5/76
2/1/76
6/1/77
8/77
9/27/77
10/6/77
11/77
4/26/78
7/1/78
A-5)
A-2
-------
Through an extensive telephone survey, data were obtained from the suppliers
and manufacturers listed in Table A-2 on control equipment and coating
materials used within the surface coating industry. Contacts with trade
associations, regional EPA offices, and state air pollution authorities
(Table A-3) provided additional technical information. An EPA question-
naire (industry survey) was approved by OMB and distributed throughout the
automotive industry to obtain information on plant size, control techniques,
production capacities and emissions data. Direct contacts were supplemented
by plant tours (Table A-4) of various surface coating operations to gain
first-hand information on control techniques and emissions data.
The second major step in this study was to determine the environmental
and economic impacts of various alternative regulatory options. The
environmental impacts of the various alternative regulatory options were
determined by comparing the projected emissions under each option with
those for the base case. The economic analysis was supported by examining
various automotive plants, contacting the Department of Commerce, and
reviewing Wards Automotive yearbooks and various trade journals.
On June 1, 1977, EPA published a draft document, "Study to Support an
NSPS for Automobile and Light-Duty Trucks." A memo suggesting standards of
performance was distributed throughout the automotive industry in August
1977. DeBell and Richardson presented the draft study to the NAPCTAC
meeting held in Alexandria, Virginia, on September 27 and 28, 1977. On
October 6, 1977, a working group meeting was held to discuss industry
comments raised at the NAPCTAC meeting.
Upon receipt of this project in October 1978, Acurex began to review
and revise the previous documents in light of the comments made by the
A-3
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Table A-2. SUPPLIERS AND MANUFACTURERS CONTACTED
ADSOX
AER Corporation
Binks
Calgon Activated Carbon Division
Combustion Equipment Associates
DeVilbiss Company
Dow Corning Corporation
DuPont
George Koch & Sons, Inc.
High Voltage Engineering Corporation
Hoyt Solvent Recovery Systems
Interrad
Jensen, Inc.
Lilly Industrial Coatings, Inc.
Matthey Bishop, Inc.
Moller Engineering
Polychrome
PPG Industries
Programmed Coating
Ransburg Corporation
RaySolv Incorporated
Reeco Regenerative Environmental Equipment Co., Inc.
Sealectro Corporation
Sherwin Williams
Troy Chemical Corporation
Vulcan
W. R. Grace and Company
W.S. Rockwell
A-4
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Table A-3. STATE AGENCIES CONTACTED
Southern California Air Resources Board
Sacramento, CA
Bay Area Air Pollution Control District
San Francisco, CA
Air Pollution Control District
Louisville, KY
State of Maryland
Department of Health and Mental Hygiene
Baltimore, MD
Department of Environmental Protection
Hartford, CT
Massachusetts Division of Environmental
Quality Enginnering
Boston, MA
State of New Jersey
Department of Environmental Protection
Trenton, NJ
Commonwealth of Virginia
State Air Pollution Control Board
Virginia Beach, VA
A-5
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Table A-4. SURFACE COATING OPERATIONS VISITED DURING
PREPARATION OF THE SUPPORT DOCUMENT
COMPANY/LOCATION
Ford Motor
Wayne, MI
General Motors
Detroit, MI
Chrysler Corp.
Detroit, MI
Ford Motor
Pico Rivera, CA
General Motors
Southgate/Van Nuys, CA
General Motors
DATE(S)
3/27/73
3/28/73
3/29/73
7/11/73
7/12/73
9/29/74
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Gather general information on
Ford's truck plant and the Wayne
auto assembly plant.
Fleetwood plant; gather general
information.
Observe the sources of emissions
and gather general information.
Observe bake ovens.
Observe bake ovens.
Familiarize EPA personnel with
Norwood, OH
Ford Motor
Atlanta, GA
Ford Motor
Metuchen, NJ
General Motors
Framingham, MA
Ford Motor
Norfolk, VA
General Motors
Southgate/Van Nuys, CA
Mack Trucks
Allentown/Macunigie, PA
the surface coating operations
within the automotive industry.
2/18/75 Familiarize EPA personnel with the
surface coating operations within
automotive industry.
5/14/75 Powder and conventional coating
operations.
9/9/75 Observe water-based primer process
(EDP) and to discuss powder coatings.
9/12/75 Pick-up trucks are assembled at
this location. Gather general
information.
10/7-8/75 Southgate and Van Nuys plants are
the only full scale automotive
assembly plants in the U.S.
employing water-based paints.
10/10/75 Gather general information.
A-6
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Chrysler Corp.
Newark, DE
White Motor Corp.
Exton, PA
General Motors
Baltimore, MD
General Motors
Wilmington, DE
Checker Motors Corp.
Kalamazoo, MI
Ford Motor
Wayne, MI
American Can Co.
Hillside, NJ
American Can Co.
Edison, NJ
General Dynamics Co.
Corvair Division
San Diego, CA
Chrysler Co.
Detroit, MI
Chrysler Co.
Detroit, MI
General Motors
Detroit, MI
10/14/75 Epoxy prime coat and acrylic enamel
topcoat operations.
10/15/75 Gather general information.
10/16/75 Enamel is used for prime coat and
lacquer for topcoat.
10/17/75 Chevettes are assembled at this
location. The Chevette requires
considerable inside painting.
11/11/75 Checker Motors manufactures taxi-
cabs. Checker Motors has had con-
tracts with one or more of the
other auto makers to paint cars
and produce body parts.
11/13/75 Observe conventional coating
operations.
12/2/75 Gather general information.
12/2/75 This location produces two piece
cans which are coated with solvent-
based materials. The plant is
equipped with incinerators.
12/7/75 One of three U.S. aircraft indus-
tries employing new technology,
water-based technology.
12/8/75 Longest automobile assembly line in
the world. Considered a good can-
didate for general information pur-
poses.
12/8/75 Autophoretic coating is employed at
this plant.
12/9/75 Fleetwood plant; this coating
operation produces GM's highest
quality paint job.
A-7
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
General Motors 12/10/75
Pontiac, MI
Douglas Aircraft Co. 12/10/75
Long Beach, CA
Virco Manufacturing
Gardena, CA
Rockwell International 12/11/75
Saberline Division
El Segundo, CA
General Motors 12/12/75
Pontiac, MI
California Finished Metals, Inc. 12/12/75
Cucamonga, CA
Supracote Inc. 12/12/75
Cucamonga, CA
International Harvester Co. 12/15/75
Rock Island, IL
International Harvester Co. 12/15/75
East Moline, IL
Deere Co. 12/17/75
Waterloo, IA
Republic Steel Co. 12/17/75
Youngstown, OH
Two identical production lines are
housed at this location. LDL
(solvent-based low dispersion lac-
quer) was employed at this site
with the 1976 models.
To view application of conventional
solvent solution coatings.
Observe Virco's powder coating line
which is fitted with an incinerator.
Conventional coating of aircrafts
with solvent-based materials.
Modern truck assembly plant, to
gather general information.
Obtain data on afterburners.
Obtain data on afterburners.
Observation of the manual
electrostatic spray operations.
Application of one coat modified
AKYD sol vent-based paints with
electrostatic spray was observed.
Undercoating of all tractor parts,
except chasis, is applied with
water-based paint by using the
EDP process.
Observe conventional coil coating
operations.
Armco Steel Corp.
Middletown, Ohio
12/18/75 Observe conventional coil coating
operations.
A-8
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Winnebago Industries
Forest City, IA
All is Chalmers Corp.
La Porte, IN
The Boeing Co.
Everett, WA
Hackney & Sons (East
Washington, NC
Modern Materials Corp.
Detroit, MI
Litho-Strip Co.
Glenview, IL
Signode Corp.
Bridgeview, IL
Chrysler Corp.
Detroit, MI
Ford Motor
Wayne, MI
Simmons Co.
Munster, IN
Food Machinery Co.
Tupello, MS
Ford Motor
Metuchen, NJ
Lau Industries
Dayton, OH
12/18/75 Molding and trim on all Winnebago
mobile homes are electrostatically
sprayed with powder. Cabs are
electrostatically coated with
liquid paints.
12/19/75 Farm machinery is coated with
water-based paints.
12/21/75 Observe application of water-based
coatings.
12/22/75 Beverage trucks are topcoated with
acrylic enamels which are metallic
and nonmetallic.
1/7/76 Coil coating using water-based
materials.
1/8/76 Solvent-based coating materials
are employed on their coil coating
lines.
1/8/76 Company manufactures steel strap-
pings which are coated with epoxy-
based materials.
1/9/76 Trucks are topcoated with solvent-
based coatings at this site.
1/9/76 Truck plant, solvent-based primer
coating operation. Small parts
are powder coated with an acrylic.
1/14/76 Metal drawers are coated with
high solids.
1/14/76 Conveyor parts are powder coated.
1/15/76 Observe powder coating operations.
1/15/76 Blower and fan components are
coated with water reducible
alkyd paint.
A-9
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
American Can Co. 1/16/76
Baltimore, MD
Solvent-based inner lacquer is
employed. The base coat is a
high solids solvent-base material
Continental Can Co.
Sparrows Point, MD
1/16/76 Obtain information in UV curing.
H.K. Porter Co., Inc. 1/16/76
Lynchburg, VA
Teledyne Rodney Metals 1/23/76
New Bedford, MA
Bilco, Inc. 1/28/76
West Haven, CT
Levolor Lorenthen, Inc. 1/29/76
Hoboken, NJ
Sun Shipbuilding & Dry Dock 1/30/76
Chester, PA
Lyon Metal Products, Inc. 2/3/76
Aurora, IL
Steel case Co. 2/4/76
Grand Rapids, MI
Ford Motor 2/5/76
Oakville
Ontario, Canada
Roll Coater, Inc. - 2/9/76
Kingsbury, IN
International Harvester 2/10/76
Fort Wayne, IN
Norfolk Shipbuilding & Dry Dock 2/11/76
Norfolk, VA
Newport News Shipbuilding 2/12/76
Newport News, VA
Observe coating operations of
transformer parts.
Observe and discuss the coil coating
operation of the company. No primer
is applied, only a single solvent-
based topcoat.
Observe the coating operation of
metal doors.
Observation of the coil coating
operation.
Coating materials are solvent-based.
Metal furniture is coated with
solvent-based materials.
Metal furniture is powder coated
at this plant.
Plant has two assembly lines, one
truck and one automobile line.
Water-based coatings are employed.
Gather information on incinerators
and observe coil coating operations.
Truck plant, observe surface
coating operations of Scouts
(light-duty trucks).
The most commonly used coating
materials are solvent-based.
Practically all coating materials
are solvent-based.
A-10
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
General Products
Mayfield, VA
Keller Industries
Mil ford, VA
General Products
Fredericksburg, VA
Keller Industries
Mil ford, VA
Crown Cork and Seal Co., Inc.
Philadelphia, PA
Central Chevrolet Co.
West Springfield, MA
Endure a Lifetime
Miami, FL
Connecticut Auto Body
Bloomfield, CT
Houser Auto Body
Springfield, MA
Raybestos Manhattan, Inc.
Mayheim, PA
Viking Wire
Danbury, CT
Steiber Cycle Corp.
Medford, NY
2/12/76 Steel exterior entrance doors are
topcoated with acrylic which is
electrostatically sprayed.
2/12/76 Aluminum patio doors and windows
are coated with a modified polyes-
ter water-based material.
2/12/76 Observe electrostatic spray and
miscellaneous spray booths.
2/12/76 Aluminum patio doors and windows
are coated with a modified polyes-
ter water-based material.
2/13/76 Steel sheets for cans, the bulk
of the coating and decorating
materials are solvent-based.
Water-based inner coating materials
are also used.
2/16/76 Auto body repair ship which uses
solvent-based materials. Lacquer
is employed for touch-ups and
enamel for whole paint jobs.
2/16/76 Laminated doors are touched up with
an air dry enamel which is applied
with a manual spray.
2/17/76 Acrylic lacquer is used for re-
finishing doors and fenders.
2/17/76 Observe a typical plant spraying
operation.
2/17/76 To view add-on equipment which is
used to reduce hydrocarbon emis-
sions.
2/19/76 Plant uses a catalytic adsorber
and incineration.
2/24/76 Observe powder coating of bicycle
frames.
A-11
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Table A-4 (continued)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Continental Can Co.
Portage, IN
Continental Can Co.
Weirton, WV
Earl Scheib Auto Body Shops
Providence, RI
Goodman Bros. Mfg. Co.
Philadelphia, PA
Burting Co.
Philadelphia, PA
Joy Manufacturing Co.
Michigan City, IN
Earl Scheib Auto Body Shops
West Haven, CT
Nordson Corp.
Amherst, OH
American Can Co.
Lemoyne, PA
Essex International
Fort Wayne, IN
H.D. Hudson Co.
Hastings, MN
Peachtree Door
St. Joseph, MO
REA Magnet Wire
Fort Wayne, IN
General Motors
Southgate, CA
General Motors
Van Nuys, CA
2/24/76 Discuss and observe the use of
incinerators.
2/25/76 UV curing technology employed at
this plant.
2/25/76 Observe a typical auto refinishing
operation.
2/25/76 Metal hospital beds are powder
coating at this plant.
2/25/76 Observation of powder coating
outdoor metal furniture.
2/25/76 Observe spray painting of
compressor parts.
2/26/76 Observation of an auto refinishing
operation.
2/26/76 Pump components for spray equipment
is powder coated at this plant.
2/27/76 Observe and discuss the use of a
carbon adsorber for solvent
recovery.
3/4/76 Observe wire coating operations.
3/3/76 Insecticide spray equipment is
powder coated at this plant.
3/3/76 . Observation of two finishing lines,
EDP and electrostatic spray
3/4/76 Magnet wire coating operation was
observed.
3/10/76 Water-based coating operations are
employed at GM plant.
3/11/76 Water-based topcoating operations
are employed at this site.
A-12
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Table A-4 (concluded)
COMPANY/LOCATION
DATE(S)
TECHNOLOGY OBSERVED AND/OR
PURPOSE OF TRIP
Ford Motor
Milpitas, CA
American Motors Corp.
Mishawaka, IN
General Electrical Corp.
Louisville, KY
Hazen Paper Co.
Hoiyoke, MA
Brown-Bridge Mills
Troy, Ohio
Scott Graphics
South Hadley, MA
Fasson Co.
Painesville, OH
Chrysler Corp.
Belvidere, IL
General Motors
Ypsilanti, MI
Ford Motor
Dearborn, MI
Sebring-Vanguard Corp.
Sebring, FL
3/12/76 Observation of typical coating
operations, incinerators are
housed at this site, (auto
and truck plant).
3/15/76 Bus manufacturing, observe coating
operations and gather general
information.
5/4/76 Large appliances are powder coated
at this site. Observe EDP coating
facilities.
5/19/76 Sol vent-based coating line equipped
with an incinerator.
To view the paper coating operation
and carbon adsorption system.
7/1/76 Discuss solvent recovery process
and observe the carbon adsorption
system and paper coating operation.
7/14/76 To view the paper coating operation
and carbon adsorption system.
10/12/76 Plant represents the typical adhe-
sives (solvent-based) operation.
10/10/76 Compact sized cars manufactured
at this site. Plant employs the
operation of typical adhesives.
11/11/76 Sporty compact cars manufactured
at this site. Typical adhesives
are used at this location.
3/1/77 Largest producer of electric cars
in the world. Determine the
ability of small automobile or
light-duty truck producers to
meet an NSPS that might be promul-
gated for the auto industry.
A-13
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Working Group and NAPCTAC, and the information received from industry since
the preparation and public presentation of the first draft.
Additional data were obtained from Ransburg Corporation on transfer
efficiencies and from General Motors on paint content. The existing document
was extensively revised from December 1978 to March 1979. The complete
Background Information Document (BID) and the Federal Register notice of
the proposed regulation were prepared and submitted to the EPA Steering
Committee on May 18, 1979. Table A-5 lists the major reviews and decision-
related communications which occurred from October 1978 to the date of
proposal.
A-14
-------
Table A-5. MAJOR REVIEWS AND DECISION-RELATED COMMUNICATIONS
DATE
COMMUNICATION
PURPOSE
CONCLUSIONS/REDIRECTIONS
12/7/78 EPA, Acurex, Ransburg Corp.
Meeting; report prepared by
Acurex ( ).
To discuss whether regulation
should be set in terms of mass
VOC, and whether to measure
transfer efficiency (TE) or
develop a list of TE for dif-
ferent types of coating sys-
tems.
The Emission Measurement Branch was to
develop a reference method for determining
TC, Reference Method 24. TE list would be
developed.
en
Draft Example of Format
(to be completed later)
-------
APPENDIX B
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Background
Information Document
03
I
1. Background and Description of the Proposed
Action.
- Describe the recommended or proposed
action and its purpose.
2. Alternatives to the Proposed Action.
- Describe and objectively weigh reasonable
alternatives to the proposed action, to
the extent such alternatives are permitted
by the law . . . For use as a reference
point to which other actions can be com-
pared, the analysis of alternatives should
include the alternative of taking no action,
or of postponing action. In addition, the
analysis should include alternatives having
different environmental impacts, including
proposing standards, criteria, procedures,
or actions of varying degrees of stringency.
When appropriate, actions with similar envi-
ronmental impacts but based on different
technical approaches should be discussed.
This analysis shall evaluate alternatives in
such a manner that reviewers can judge their
relative desirability.
The proposed regulations are summarized in
Chapter 1 and Chapter 9. The statutory ba-
sis for the proposed regulatons (Section 111
of the Clean Air Act, as amended) is dis-
cussed in Chapter 9.
The Clean Air Act amendments of 1977 require
EPA to revise existing regulations under
Section 111 of the Act. Alternative control
systems are discussed in Chapter 4. The
environmental impact of different levels of
control are discussed in Chapter 7. The
economic impact of alternative control levels
and systems are discussed in Chapter 8.
Alternative formats for the proposed regula-
tions are discussed in Chapter 9.
-------
APPENDIX B (CONTINUED)
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Background
Information Document
CD
I
INS
- The analysis should be sufficiently de-
tailed to reveal the Agency's comparative
evaluation of the beneficial and adverse
environmental, health, social, and eco-
nomic effects of the proposed action and
and each reasonable alternative.
Where the authorizing legislation limits
the Agency from taking certain factors
into account in its decision making, the
comparative evaluation should discuss all
relevant factors, but clearly identify
those factors which the authorizing
legislation requires to be the basis of
the decision making.
In addition, the reasons why the proposed
action is believed by the Agency to be the
best course of action shall be explained.
The environmental and energy impacts of the
proposed regulations are discussed in Chapter 1,
Chapter 7, Chapter 8, and Chapter 9. Eco-
nomic impacts are discussed in Chapter 1 and
Chapter 8. The inflationary impact is dis-
cussed in Chapter 1 and Chapter 8. The socio-
economic impact is discussed in Chapter 8.
Section 111 of the Clean Air Act does not re-
quire EPA to directly consider health effects
in establishing the level of new source per-
formance standards.
The legislative history of new source per-
formance standards is presented in Chapter 2.
The proposed regulations are required by the
Clean Air Act amendments of 1977, as discussed
in Chapter 9.
The rationale for the proposed regulations is
presented in Chapter 9.
-------
APPENDIX B (CONTINUED)
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Background
Information Document
00
I
oo
Describe the extent to which the proposed
action curtails the diversity and range of
beneficial uses of the environment. For
example, irreversible damage can result if
a standard is not sufficiently stringent.
D. A discussion of problems and objections
raised by other Federal, State, and local
agencies and by other persons in this re-
view process. Final statements (and
draft statements if appropriate) shall
summarize the significant comments and
suggestions made by reviewig organi-
zations and individuals and shall describe
the disposition of issues surfaced (i.e.,
revisions to the proposed action to mitigate
anticipated impacts of objections). In
particular, they shall address in detail the
major issues raised when the Agency position
is a variance with recommendations and objec-
tions (e.g., reasons why specific comments and
suggestions could not be adopted, and factors
of overriding importance prohibiting the in-
corporation of suggestions). Reviewer's state-
ments should be set forth in a "comment" and
discussed in a "response."
All comments received during the public
comment period which follows proposal of
the regulations will be responded to in
a separate document.
-------
APPENDIX B (CONTINUED)
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Background
Information Document
00
I
3. Environmental Impact of the Proposed Action.
A. Primary impact
- Primary impacts are those that can be
attributed directly to the action,
such as reduced levels of specific pol-
lutants brought about by a new standard
and the physical changes that occur in
the various media with this reduction.
B. Secondary impact
- Secondary impacts are indirect or induced
impacts. For example, mandatory reduction
of specific pollutants brought about by a
new standard could result in the adoption
of control technology that exacerbates
another pollution problem and would be a
secondary impact.
4. Other Considerations.
A. Adverse impacts which cannot be avoided
should the proposal be implemented.
Describe the kinds and magnitudes of
adverse impacts which cannot be reduced
The primary environmental impacts on mass
emissions and ambient air quality are dis-
cussed in Chapter 7, and Chapter 9.
Secondary impacts on air and water quality,
solid waste disposal, noise, and energy con-
servation are discussed in Chapter 1, Chapter 7
and Chapter 8.
No potential adverse side effects are expected.
A more detailed discussion is presented in
Chapter 9. Potential adverse economic impacts
are discussed in Chapter 8.
-------
APPENDIX B (CONTINUED)
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Background
Information Document
co
i
en
in severity to an acceptable level or
which can be reduced to an acceptable
level but not eliminated. These may in-
clude air or water pollution, damage to
ecological systems, reduction in economic
activities, threats to health, or undesir-
able land use patterns. Remedial, pro-
tective, and mitigative measures which will
be taken as part of the proposed action
shall be identified.
Relationship between local short-term uses
of man's environment and the maintenance
and enhancement of long-term productivity.
Describe the extent to which the proposed
action involves trade-offs between short-
term environmental gains at the expense of
long-term losses or vice versa and the ex-
tent to which the proposed action forecloses
future options. Special attention shall be
given to effects which pose long-term risks
to health or safety. In addition, the tim-
ing of the proposed action shall be ex-
plained and justified.
Irreversible and irretrievable commitments
of resources which would be involved in the
proposed action should it be implemented.
No trade-offs are expected. This subject is
discussed in more detail in Chapter 9.
There would be no irreversible and irretrievable
commitments of resources as a result of the pro-
proposed regulations. See Chapter 7.
-------
APPENDIX E
ENFORCEMENT ASPECTS
E.1 ENFORCEMENT
The rules and regulations for determining if a source will be subject
to new source performance standards by reason that the source is new,
modified, or reconstructed, are given in Subpart A, Part 60, Subchapter C,
Chapter 1, Title 40, Code of Federal Regulations. It is suggested that
interpretation of the foregoing rules and regulations be reviewed through
the U.S. Environmental Protection Agency Regional Office Enforcement Divi-
sion for the region where a source will be located.
The locations and addresses of these regional offices are as follows:
Region I - Connecticut, Maine, Massachusetts, New Hampshire
Rhode Island, Vermont
John F. Kennedy Federal Building
Boston, MA 02203
Telephone: 617-223-7210
Region II - New Jersey, New York, Puerto Rico, Virgin Islands
26 Federal Plaza
New York, NY 10007
Telephone: 212-264-2525
Region III - Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia
Curtis Building
6th and Walnut Streets
Philadelphia, PA 19106
Telephone: 215-597-9814
Region IV - Alabama, Florida, Georgia, Mississippi,
Kentucky, North Carolina, South Carolina,
West Virginia
345 Court!and, N.E.
Atlanta, GA 30308
Telephone: 404-881-4727
Region V - Illinois, Indiana, Michigan, Minnesota,
Ohio, Wisconsin
230 South Dearborn
Chicago, IL 60604
Telephone: 312-353-2000
E-l
-------
Region VI - Arkansas, Louisiana, New Mexico, Oklahoma, Texas
First International Building
1201 Elm Street
Dallas, Texas 75270
Telephone: 214-767-2000
Region VII - Iowa, Kansas, Missouri, Nebraska
1735 Baltimore Street
Kansas City, MO 64108
Telephone: 816-374-5493
Region VIII - Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming
1860 Lincoln Street
Denver, CO 80295
Telephone: 303-837-3895
Region IX - Arizona, California, Hawaii, Nevada, Guam,
American Samoa
215 Fremont Street
San Francisco, CA 94051
Telephone: 415-556-2320
Region X - Washington, Oregon, Idaho, Alaska
1200 Sixth Avenue
Seattle, WA 98101
Telephone: 206-442-1220
E. 2 COMPLIANCE
General procedures for compliance testing and emission monitoring are
specified in Subpart A, Part 60, Subchapter C, Chapter 1, Title 40, Code of
Federal Regulations. Compliance with the proposed emission limits would be
determined by the following steps:
1. Determine the average VOC content per liter of coating solids of
the prime coat, guide coat, and topcoat materials being used.
This would require analyzing all coating materials used in each
coating operation using the proposed Reference Method 24 and
E-2
-------
calculating an average VOC content for each surface coating
operation.
2. Select the appropriate transfer efficiency for each surface
coating operation from the table included in the standards.
3. Calculate the mass of VOC emissions per volume of applied solids
for each surface coating operation by dividing the appropriate
average VOC content of the coatings (Step 1) by the transfer
efficiency of the surface coating operation (Step 2). If the
value obtained is lower than the emission limit included in the
standards, the surface coating operation would be in compliance.
If the value obtained is higher than the emission limit, add-on
VOC emission control would be required to comply with the stan-
dards.
4. If add-on emission control is required, calculate the emission
reduction efficiency in VOC emissions which is required using the
equations included in the standards.
5. In cases where all exhaust gases are not vented to an emission
control device, the percentage of total VOC emissions which enter
the add-on emission control device would have to be determined by
sampling all the stacks and using the equations included in the
standards. Representative sampling, however, could be approved
by the Administrator, on a case-by-case basis, rather than requiring
sampling of all stacks for this determination.
6. The actual efficiency of the control device would be calculated
by determining VOC emissions before and after the device using
the proposed Reference Method 25.
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7. The VOC emission reduction efficiency achieved would be calculated
by multiplying the percentage of VOC emissions which enter the
add-on VOC emission control device (Step 5) by the add-on control
device efficiency (Step 6). If the resulting value of the emis-
sion reduction efficiency achieved were greater than that required
(Step 4), then the surface coating operation would be in compliance.
Facilities which have achieved compliance without the use of add-on
control devices would be monitored by analyzing the coating materials.
Increases in the solvent content of coating materials will cause the VOC
emissions to increase. Therefore, after the initial compliance determina-
tions have been made, increases in the arithmetic average of the solvent
content of all the paints used by a plant would have to be.reported to EPA
by the plant on a quarterly basis.
Combustion temperatures would be monitored in incineration units which
were used to comply with the standard. The initial temperature measurements
would be made during compliance testing. Decreases in the combustion
temperature in the incinerator would be reported to EPA on a quarterly
basis.
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