United States        Office of Air Quality        EPA-340/1-86-01 6
             Environmental Protection   Planning and Standards       July 1986
             Agency          Washington, DC 20460

             Air
v>EPA      A Guideline for
             Surface Coating
             Calculations

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                                              EPA-340/1-86-016
A  Guide For Surface  Coating Calculations
                              Prepared by

                           PEI Associates, Inc.
                           11499 Chester Road
                          Post Off ice Box 46100
                        Cincinnati, Ohio 45246-0100
                         Contract No. 68-02-3963
                          Work Assignment No. 6
                             Prepared for

                         Project Officer: John Busik
                   Work Assignment Manager: Dwight Hlustick
                   U.S. ENVIRONMENTAL PROTECTION AGENCY
                   Office of Air Quality Planning and Standards
                     Stationary Source Compliance Division
                          Washington, DC 20460

                              July 1986

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                                  DISCLAIMER


     This report was prepared for the U.S. Environmental Protection Agency by
PEI Associates, Inc., Cincinnati, Ohio, under Contract No. 68-02-3767, Work
Assignment No. 67.  The contents of this report are reproduced herein as re-
ceived from the Contractor.  The opinions, findings, and conclusions expressed
are those of the author and not necessarily those of the U.S. Environmental
Protection Agency.
                                         n

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                                   CONTENTS
Figures                                                                  iv
Tables                                                                   iv
Acknowledgment                                                            v
Abstract                                                                 vi

1.   Introduction                                                         1

     1.1  Background                                                      1
     1.2  Description of VOC calculations                                 2
     1.3  Negligibly photochemically reactive materials                   3

2.   Basic Calculations                                                   5

     2.1  Determining the mass of VOC emitted per volume of solids        5
     2.2  Determining the mass of VOC emitted per volume of coating       6
          less water

3.   Transfer Efficiency                                                  9

     3.1  Determining the mass of VOC emitted per volume of solids        9
          applied
     3.2  Calculating average transfer efficiency                        10

4.   Compliance Determinations                                           12

     4.1  Calculating coating compliance with a standard                 12
     4.2  Calculating compliance when add-on controls are used           13

5.   Equivalency Determinations                                          16

     5.1  Calculating allowable hourly emissions for a solvent-borne     16
          coating
     5.2  Equivalency calculations for a can coating operation           17
(continued)
                                     ill

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CONTENTS (continued)


                                                                        Page

6.   Complex Calculations                                                23

     6.1  Compliance determination for auto plant primer-surfacer        23
          (guide coat) operation
     6.2  Determining compliance for a large appliance coating line      26
          using several types of spray equipment

7.   Graphs and Tables Useful in Approximating and Double-Checking       30
     Surface Coating Calculations

References                                                               41

Appendices

     A    Glossary of Air Pollution Control of Industrial  Coating       A-l
          Operations.  EPA-450/3-83-013R.  December 1983.   pp. 26-29.

     B    Procedures for Certifying Quantity of Volatile Organic        B-l
          Compounds Emitted by Paint, Ink, and Other Coatings.
%
          EPA-450/3-84-019.  December 1984.

          Reference Method 24.                                          C-l
                                     iv

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                                    FIGURES

Number                                                                  Page
  1       Graph For Determining Equivalent Solids/VOC (Solvent)          31
           Contents of Waterborne and Organic-Borne Coatings
  2       Graph For Determining Pounds of VOC (Solvent) Per Gallon       32
           Of Coating Solids
  3       Smaller-Scale Graph For Determining Pounds of VOC (Solvent)    33
           Per Gallon of Coating Solids
                                    TABLES
Number                                                                  Page
  1       Example Calculation of Average TE When Several Different       11
           Coating Application Methods Are Used
  2       Suggested Format For Determining Compliance for Can Coating    21
           Operations
  3       Large Appliance Multitransfer Efficiency Calculation           27
  4       CTG Volume Percent Solids Equivalency Data                     34
  5       CTG Equivalency Data                                           36
  6       Equivalent Solids Deposited Limits                             39
  7       Metric Conversion Factors                                      40

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                                ACKNOWLEDGMENT


     This guideline was prepared for the U.S. Environmental Protection Agency
by PEI Associates, Inc. under Contract No. 68-02-3963.  It is primarily a re-
vision of a preliminary draft manual with the same title, dated January 1982,
and prepared by Messrs. William Polglase, Brock Nicholson, and Tom Williams of
the Control Programs Development Division (CPDD), U. S. Environmental Protec-
tion Agency, Research Triangle Park, North Carolina.  PEI especially appreci-
ates the support and input given by Mr. Dwight Hlustick, the Work Assignment
Manager, during the preparation of this guideline.  The review and comments
provided by Messrs.  Robert Blaszczak, Douglas Cook, Richard Dalton, Paul
Kahn, Laxmi Kesari, William Polglase, Michael Pucci, David Salman, Dennis San-
tella, and James Topsale are also gratefully acknowledged.

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                                   ABSTRACT
     The calculation of volatile organic compound emissions from surface coat-
ing operations to determine compliance is often a complicated task, sometimes
creating confusion with compliance authorities and sources alike.  In an at-
tempt to minimize this confusion, EPA (OAQPS) has periodically issued guidance
in this area, generally in the form of memoranda to the EPA Regional  Offices.
EPA guidance for submitting data on surface coatings and performing basic cal-
culations is contained in the document entitled "Procedures for Certifying
Quantity of Volatile Organic Compounds Emitted by Paint, Ink and Other Coat-
ings," EPA 450/3-84-019, published in December 1984.

     "A Guideline for Surface Coating Calculations" takes the above guidance
process one step further.  Example calculations are included for basic emis-
sion problems, compliance determinations, equivalency determinations, appli-
cation of transfer efficiency, and calculations involving complex multiproduct
plants.  Graphs anci tables useful in approximating and double-checking these
calculations are also included.
                                     •V3-X

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                                   SECTION 1
                                 INTRODUCTION
1.1  BACKGROUND
     Surface coating entails the deposition of a solid film on a surface
through the application of a coating material such as paint, lacquer, or var-
nish.  Surface coating operations are significant volatile organic compound
(VOC) emission sources.  Most coatings contain VOCs which evaporate during the
coating application and curing processes, rather than becoming part of the dry
film.
     The U.S. Environmental Protection Agency (EPA) has issued Control Tech-
niques Guidelines (CTGs) for many surface coating operations, including cans,
metal coils, paper, fabric, automobiles, light-duty trucks, metal furniture,
large appliances, magnet wire, miscellaneous metal parts and products, graphic
arts, and flatwood paneling.  The emission limits recommended in these guide-
lines have been adopted by many state and local agencies.  The EPA has also
issued new source performance standards (NSPS) for many surface coating opera-
tions, including automobile, light-duty trucks, beverage cans, metal  coils,
large appliances, metal furniture, pressure sensitive tapes and labels, vinyl
printing and topcoating, and publication rotogravure printing.
     To comply with these regulations, a surface coating operator might elect
to change to low VOC content coatings, to use add-on controls such as inciner-
ation or carbon adsorption, or to improve transfer efficiency.  In cases where
compliance is achieved by a change in coating alone, VOC emissions can be cal-
culated from the VOC content of the coating as applied to the substrate.  When
add-on controls or transfer efficiency improvements are used, more complex
calculations can be performed to determine the effectiveness of the control
strategy.  It is more convenient (and frequently more reliable) to establish
VOC compliance or non-compliarice through these calculations than it is to
measure total VOC emissions directly.

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     The emission limits for existing sources recommended in the CTGs and
adopted by many state and local agencies are expressed in terms of pounds of
VOC per gallon of coating less water.  These units are directly useful only
for cases where compliance is achieved with low VOC content coatings alone.
When add-on controls or transfer efficiency improvements are used, compliance
calculations must be done on an equivalent solids basis.  The reasons for this
are explained graphically in Glossary of Air Pollution Control of Industrial
Coating Operations, EPA-450/3-83-013R, December 1983.  Pages 26-29 of this
document are located in Appendix A.  The emission limits in most surface coat-
ing NSPSs are expressed in terms of pounds of VOC per gallon of coating solids
applied.  The reader should review this concept in Appendix A before contin-
uing in this guideline manual.  This calculation guide assumes that the solids
used or applied in a specific process remain constant for a given example
(solids equivalency).

1.2  DESCRIPTION OF VOC CALCULATIONS
     This document presents sample calculations typical of those used to
determine compliance or to evaluate control strategies.  These step-by-step
calculations are accompanied by explanations that are useful to persons
unfamiliar with surface coating operations.  Basic calculations are included
along with calculations to determine compliance and equivalency (necessary for
evaluating bubbles, offsets, netting, etc.).  Transfer efficiency problems
requiring a series of calculations are included.
     The basis for most of the sample calculations is the information and
procedures discussed in Procedure for Certifying Quantity of Volatile Organic
Compounds Emitted by Paint, Ink, and Other Coatings. EPA-450/3-84-019, Decem-
ber 1984, which is reprinted as Appendix B of this report and referred to as
the "VOC Data Sheets".   The first VOC Data Sheet provides information on the
VOCs present in a coating when it is sold by the manufacturer to the coater.
This is referred to as  the VOC content of the coating "as supplied by the
coating manufacturer to the user."  The second VOC Data Sheet provides infor-
mation on the VOCs present in the coating as it is used by the coater and in-
cludes the effect of dilution solvent added before application.  This is re-
ferred to as the VOC content "as applied to the substrate by the user."  For

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dip or flow coating operations, this should include any make-up solvent which
is added to a coating to replace evaporated solvent and therefore maintain a
specific viscosity of the coating being applied.  The calculations in this
document assume that the inspector has obtained the coating data from the VOC
Data Sheets.  However, it is up to the inspector to verify this data.  EPA
Reference Method 24 or individual ASTM methods are the final judge in deter-
mining compliance.  Appendix C contains a copy of Reference Method 24.
     Some confusion may exist regarding the meanings and proper uses of terms.
As defined in Appendix B, the term "as applied" means the condition of a coat-
ing after dilution by the user just prior to application to the substrate.
However, the term "solids applied" means the amount coating solids that
actually adheres to the object being coated, not the amount of solids leaving
the applicator.  In contrast, the term "solids used" refers to the total
amount of solids used in an application, not the amount of solids that act-
ually adheres to substrate.  Care should be taken when using these terms to
avoid confusion.

1.3  NEGLIGIBLY PHOTOCHEMICALLY REACTIVE MATERIALS
     A volatile organic compound is defined in 40 CFR Subpart A, General Pro-
visions, §60.2, as any organic compound which participates in atmospheric pho-
tochemical reactions; or which is measured by a reference method, an equiva-
lent method, or an alternative method; or which is determined by procedures
specified under any subpart.  The EPA considers the following organic solvents
to have negligible photochemical reactivity, and therefore does not consider
them to be VOCs:
                              Methane1
                              Ethane1
                              1,1,1-trichloroethane (methyl chloroform)1
                              Methylene chloride2
                              Trichlorofluoromethane  (CFC-11)3
                              Dichlorodifluoromethane (CFC-12)3
                              Chlorodifluoromethane (CFC-22)3
                              Trifluoromethane  (CFC-23)3
                              Trichlorotrifluoroethane  (CFC-113)1

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                              Dichlorotetrafluoroethane (CFC-114)3
                              Chloropentafluoroethane (CFC-115)3
Many states also do not consider some or all of these materials to be VOCs.
     Two of these compounds, 1,1,1-trichloroethane and methylene chloride, are
used as solvents in some coatings.  These materials should not be counted as
VOCs if they are "exempt" from the applicable regulation.  The method for
discounting these materials is described in some of the examples and in
Appendix B.  Generally, these materials, when "exempt" from the applicable
regulation, are treated in the same manner as water in emission calculations.
     Only the compounds listed above and any compounds given the status of
"negligibly photochemically reactive" by the U.S. EPA in a future Federal Re-
gister may be considered as exempt from Federal enforcement of applicable
State SIP VOC regulations.  Also, Rule 66 should not be referenced for exempt-
ing  compounds as per 42 FR 35314, July 8, 1977.
   2  FR  3D314,  July 8,  1977
 245  FR  32042,  June 4,  1979
 345  FR  48941,  July 22,  1980

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                                   SECTION 2

                              BASIC CALCULATIONS


     This section presents examples of basic types of calculations.  The
examples closely follow the VOC Data Sheets (Appendix B).


2.1  DETERMINING THE MASS OF VOC EMITTED PER VOLUME OF SOLIDS

Example 1 -

Determine the mass of VOC emitted per volume of solids for a solvent-borne
coating.  The following data are given:

               A.  Coating Density        =10.0 Ib/gal
               B.  Total Volatiles        = 60 percent by weight
               C.  Water Content          = 0
               D.  Organic* Volatiles
                    Content               = 60 percent by weight
               E.  Nonvolatiles Content
                    (Solids)              = 35 percent by volume

Mass of VOC emitted per volume of solids is:

     10.0 Ib coating   0.60 Ib VOC    1 gal coating  = 17.1 Ib VOC
       gal coating      Ib coating   0.35 gal solids    gal solids
Example 2 -

Determine the mass of VOC emitted per volume of solids for a waterborne
coating.  The following data are given:

               A.  Coating Density        = 9.0 Ib/gal
               B.  Total Volatiles        = 70 percent by weight
               C.  Water Content          = 30 percent by weight
               D.  Organic* Volatiles
                    Content               = 70-30=40 percent by weight
               E.  Nonvolatiles Content   = 19.6 percent by volume
                    (Solids)
*Photochemically reactive materials only.

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Mass of VOC emitted per volume of solids is:

     9.0 1b coating   0.40 1b VOC     1 gal coating  _ 18.4 Ib VOC
       gal coating     Ib coating   0.196 gal solids    gal solids
Example 3 -

Determine the mass of VOC emitted per volume of solids for a coating  that
contains some negligibly photochemically reactive  (NPR) solvents.
The  following data are given:

               A.  Coating Density        = 11.0 Ib/gal
               B.  Total Volatiles        = 80 percent by weight
               C.  NPR Solvent Content    = 40 percent by weight
               D.  Organic*  Volatiles
                     Content               = 40 percent by weight
               E.  Nonvolatiles  Content   = 15 percent by volume
                     (Solids)

Mass of  VOC  emitted  per volume of solids is:

      11.0  Ib coating  0.40  Ib VOC    1 gal coating   = 29.3  Ib  VQC
       gal  coating    x  Ib coating   0.15 gal solids    gal  solids
 2.2  DETERMINING THE MASS  OF VOC  EMITTED  PER  VOLUME  OF  COATING  LESS  WATER

 Example 4 -

 Determine the mass of VOC  emitted per volume  of coating less  water  for a
 solvent-borne coating.   The following data  are  given:

                A.  Coating Density        = 10  Ib/gal
                B.  Total  Volatiles        = 60  percent  weight
                C.  Water Content           = 0
                D.  Organic* Volatiles
                     Content               = 60  percent  weight

 Mass of VOC per volume of  coating less water  is:

           10 Ib coating   0.60 Ib VOC            1  gal  coating	
           gal coating     Ib coating    (1-0) gal  coating less  water

                    6 Ib VOC
             gal  coating less water


 *Photochemically reactive materials only.

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Example 5 -

Determine the mass of VOC emitted per volume of coating less water for a
water-borne coating.  The following data are given:

               A. Coating Density         =9.0 Ib/gal
               B. Total Volatiles         = 70 percent by weight
               C. Water Content           = 30 percent by weight
               D. Organic* Volatiles
                   Content                = 70-30=40 percent by weight

The mass of water in the coating is:

       9.0 Ib coating     0.3 1b water _ 2.7 1b water
         gal coating       Ib coating  " gal coating

The volume of water in the coating is:

       2.7 Ib water    	1	 _ 0.32 gal water
       gal coating      8.33 Ib water ~  gal coating
                         gal water

The mass of VOC in the coating is:

       9.0 Ib coating    0.4 Ib VOC = 3.6 Ib VOC
        gal coating      Ib coating " gal coating

The mass of VOC emitted per volume of coating less water is:

                3.6 Ib VOC
      	  gal coating"	 _       5.3 Ib VOC
      1 gal coating - 0.32 gal water ~ gal coating less water
               gal coating
Example 6 -

Determine the mass of VOC emitted per gallon of coating less negligibly photo-
chemically reactive material for a coating that contains some negligibly
photochemically reactive material.

The following data are given:

               A. Coating Density         = 10.5 Ib/gallon
               B. Total Volatiles         = 80 percent by weight
               C. NPR Solvent Content     = 40 percent by weight
               D. Organic* Volatiles
                   Content                = 40 percent by weight
               E. NPR Solvent Density     = 11.0 Ib/gal


*Photochemically reactive materials only.

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The mass of VOC per volume of coating is:

       10.5 1b coating    0.4 1b VOC _ 4.2 1b VOC
         gal coating      Ib coating ~ gal coating

The mass of NPR solvent in the coating is:

       10.5 Ib coating   0.4 Ib NPR solvent = 4.2 Ib NPR solvent
         gal coating         Ib coating     ~     gal  coating

The volume of NPR solvent in the coating is:
      4.2 Ib NPR solvent   	1	 = 0.38  gal  NPR solvent
         gal coating     x 11.0 Ib NPR solvent        gal  coating
                             gal NPR solvent

The mass of VOC per gallon of coating less NPR solvent is:

                   4.2 Ib VOC
      	gal coating	 _  	6.8  Ib VOC	
      1 gal coating - 0.38 gal NPR solvent ~  gal coating less NPR solvent
                 1 gal coating

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                                   SECTION 3
                              TRANSFER EFFICIENCY

     When spray guns are used to apply coatings, much of the coating material
either bounces off the surface being coated or misses it altogether.  Transfer
efficiency (TE) is the ratio of the amount of coating solids deposited on the
coated part to the amount of coating solids used.  Regardless of the TE, all
of the VOCs in the dispensed coating are emitted whether or not the coating
actually reaches and adheres to the surface.  Consequently, improved TE can
reduce VOC emissions because less coating is used.  EPA has defined baseline
transfer efficiencies of 60 percent for RACT in metal furniture and appliance
coating and 30 percent for RACT waterborne equivalence in the automobile in-
dustry (for both primer-surfacer and topcoat applications).  If a base TE has
not been documented by EPA, then the company must satisfactorily document
their base TE prior to equivalency calculations/demonstrations.  To obtain TE
credits, a company must prove its baseline TE with documentation, and document
the new TE.

3.1  DETERMINING THE MASS OF VOC EMITTED PER VOLUME OF SOLIDS APPLIED
Example 1 -
Determine the mass of VOC emitted per volume of solids applied given the fol-
lowing data:
               A. VOC content of coating      = 4.0 Ib VOC
                                                gal solids
               B. Transfer efficiency         = 40 percent
Mass of VOC emitted per volume of solids applied is:
     4.0 Ib VQC      1 gal solids used   =   10.0 Ib VOC
     gal  solids   0.4 gal solids applied ~ gal solids applied

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Example 2 -


Determine the mass of VOC emitted per volume of solids  applied  given  the  fol-
lowing data:


               A. VOC content of coating  = 3.0 Ib VOC/gal  coating  less water
               B. Nonvolatiles content    = 55 percent  by volume
               C. Transfer efficiency     = 60 percent
               D. Water Content           = None


      3.0 Ib VOC         1 gal coating less water      1 gal  solids used
gal coating less water       0.55 gal  solids        0.60 gal  solids  applied

= 	9.1 Ib VOC
   1 gallon solids applied

Note:   For a waterborne coating, be careful  of using pounds  of VOC per gallon
        of coating less water and volume nonvolatiles content as a  fraction of
        the total coating including water.   These two items  cannot  simply be
        combined to get pounds of VOC per gallon of solids.   The best method
        is to follow Example 2 in Section 2 and then factor  in transfer effi-
        ciency.  Alternatively, the volume  nonvolatiles  content could be de-
        termined for the coating less water if the volume fraction  water is
        known or calculated as follows:



                       ='••"".
 3.2   CALCULATING AVERAGE TRANSFER EFFICIENCY


 Example 3 -


 A  plant operates two coating lines.  Each line uses  both manual  electrostatic
 spray guns (TE = 60 percent) and rotating-head electrostatic  spray  guns  (TE  =
 80 percent).  Table 1 contains the applicable data.   What is  the average
 transfer efficiency?


 Awpranp TF - total liters of solids deposited _ 38.4 + 36.8    n
 average it -    t()tal mers Qf solids use(J       64 + 46  x 10°


             75.2
             110
                  x 100 = 68 percent
                                       10

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                           TABLE 1.  EXAMPLE CALCULATION OF AVERAGE TE WHEN
                        SEVERAL DIFFERENT COATING APPLICATION METHODS ARE USED
Coating line
A
B
TOTAL
Total
1 i ters
of
coating
used
100
100
Volume
percent
solids
50
60
Total
liters
of
solids
used
50
60
Application Method
Manual electrostatic spray
(TE = 60%)*
Liters
of
coating
used
80
40
Liters
of
solids
used
40
24
64
Liters
of
' solids
deposited
24
14.4
38.4
Rotating-head electro-
static spray (TE = 80%)*
Liters
of
coating
used
20
60
Liters
of
solids
used
10
36
46
Liters
of
solids
deposited
8
28.8
36.8
*These TE values are illustrative values only.  Actual TE must be determined to calculate actual  emissions,

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                                   SECTION 4
                           COMPLIANCE DETERMINATIONS
4.1  CALCULATING COATING COMPLIANCE WITH A STANDARD
Example 1 -
A coater is required to meet an emission limit of 3.5 pounds of VOC per gallon
of coating less water.  Does a coating with a density of 12 pounds per gallon
that contains 25 weight percent VOC comply?  The coating contains no water or
negligibly photochemically reactive solvents.
          12 Ib coating   0.25 Ib VOC           1 gal coating	
           gal coating    Ib coating    (1-0) gal coating less water
                   3 Ib VOC
            gal coating less water
So, the coating complies with the regulation.
Example 2 -
A coater is required to meet an emission limit of 4.0 pounds VOC per gallon of
solids.  Does a coating with a density of 10 pounds per gallon that contains
60 weight percent volatiles, 45 weight percent water, and 30 volume percent
solids comply?
The weight percent organic volatiles is 60-45=15.
    :
The VOC content of the coating is:
     10 Ib coating   0.15 Ib VOC    1 gal coating  =  5 Ib VOC
      gal coating     Ib coating   0.30 gal solids   gal solids
So, the coating does not comply with the regulation.
                                        12

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Example 3 -

A coater is required to meet an emission limit of 10 pounds VOC per gallon of
solids applied.  Does the coating in Example 2 comply if it is applied at a
transfer efficiency of 80 percent?

      5 Ib VOC         1 gal solids used     _     6.3 Ib VOC
     gal solids x 0.80 gallon solids applied ~ gal solids applied

So, the coating meets the regulation.
 Example 4 -

 A metal furniture coater uses a coating containing 0.40 kg VOC/liter of coat-
 ing  (less water and exempt solvents).  The coating contains 55 volume percent
 solids.  The transfer efficiency is 87 percent.  Is the plant in compliance if
 the  maximum allowable emissions are 1.0 kg VOC/liter solids applied?

 The  solution is found by using the following basic equation:

      mass of VOC used           1 _          mass of VOC used
                              /\
 volume of coating solids used   TE   volume of coating solids applied


 Emissions are:

                                1 liter of coating less water
 	0.40 kg VOC	       and exempt solvents	
 1  liter of coating less water        0.55 liter solids
    and exempt solvents

   1 liter solids        0.84 kg VOC
^
In
 0.87  liter solids   1 liter solids applied
    applied

 Since 0.84 is  less than 1.0, the coating operation is in compliance.

 Note:  This example is similar to Example 2 in Section 3.1.  Therefore, the
       note mentioned after Example 2 applies to this example too.
4.2  CALCULATING COMPLIANCE MEN ADD-ON CONTROLS ARE USED

Example 5 -

A coater is required to meet an emission limit of 6 pounds of VOC per gallon
of solids.  What percent emission reduction is needed if the coater uses a
coating with 22 pounds of VOC per gallon of solids?
                                       13

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          22 fi          1 fi
                x 100 =    x 100 = 73 percent emission reduction
Example 6 -

A coater is required to meet an emission limit of 3.7 pounds of VOC per gallon
of coating less water.  What percent emission reduction is needed if the coat-
er uses a solvent-borne coating with 5.0 pounds of VOC per gallon of coating
less water and a volume solids content of 25 percent?

This calculation must be done on a solids basis.  First, the emission limit
must be converted to pounds of VOC per gallon of solids.  To do this, an as-
sumed VOC density of 7.36 pounds per gallon is used to calculate the volume
solids content of the "presumptive" RACT coating.
           3.7 Ib VOC
x 713ja]bV$jc * 100 = 50 volume percent VOC
     gal coating less water

               100-50 = 50 volume percent solids

                3.7 Ib VOC    1 gal coating  = 7.4 Ib VOC
               gal coating   0.50 gal solids ~ gal solids

Next, the VOC content of the coating used must also be calculated on a solids
basis.

                5.0 Ib VOC    1 gal coating  _ 20 Ib VOC
                           A
               gal coating   0.25 gal solids   gal solids

Now the required percent reduction can be calculated.

               20-7.4
                 20

Ndtes:
                      x 100 = 63 percent emission reduction
1. An erroneous result is obtained if this calculation is not done on a solids
basis.  Using pounds of VOC per gallon of coating less water the result would
be:


                 c"n   * 100 = 26 percent emission reduction
                 0 • U

This would not give equivalent emissions as it does not take into account that
the "presumptive" RACT coating not only has lower VOC content, but higher
solids content as well.
                                       14

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2.  An assumed VOC density of 7.36 pounds per gallon is used to calculate the
volume solids content of the "presumptive" RACT coating because this same
value was used to determine the "presumptive" recommended RACT emission limits
from volume solids data.

3.  The volume solids content of actual coatings should be determined directly
from coating formulation data as described in the VOC Data Sheets.  Ocassion-
ally, it may be useful to back calculate volume solids from VOC content and
actual solvent or VOC density, but this must be done with extreme caution.
When an inspector gathers data on the actual coatings used at a facility, the
volume solids content should be obtained from coating formulation data from
the facility or the coating manufacturer.  The volume solids content should
not be back calculated.
                                       15

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                                   SECTION 5
                          EQUIVALENCY DETERMINATIONS

     Equivalency calculations are required when compliance decisions must be
made for replacement coatings, bubbles, offsets, netting, etc.  This type of
calculation relates primarily to the CTG source categories.  This section pre-
sents example equivalency calculations.
     VOC equivalency calculations must be made on a solids basis.  The amount
of solids needed to coat a surface to a particular film thickness is the same
regardless of the coating composition used.  Reducing the solids content of an
organic solvent-borne coating increases the quantity of coating required and
increases VOC emissions because more coating is used and the coating has a
higher VOC content.

5.1  CALCULATING ALLOWABLE HOURLY EMISSIONS FOR A SOLVENT-BORNE COATING*
Example 1 -
A surface coater uses 10 gallons per hour of a coating that contains 5.5 Ib
VOC per gallon of coating and 25 volume percent solids.  New regulations
indicate that the coating formulation must meet an emission limit of 3.0 Ib of
VOC per gallon of coating (with a solvent density of 7.36 Ib per gallon) or
the coater must control VOC emissions to an equivalent level.  Assuming that
the production rate (solids usage rate), transfer efficiency, and film
thickness stay constant, what are the coater's "allowable" hourly VOC
emissions?
For the existing coating, the actual VOC emissions are:
               10 gal coating    5.5 Ib VOC _ 55 Ib VOC
                      h       x gal coating ~      h
*This example presents a method for determining hourly VOC mass emissions for
offset calculations; however, RACT limitations should normally be based on
either applicable coating formulations or control efficiency requirements.  An
hourly cap would normally only be used in addition to these RACT limitations.
                                       16

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The solids usage rate is:

          10 gal coating   0.25 gal solids _ 2.5 gal solids
                 h           gal coating            h

For the complying coating, the VOC (solvent) volume fraction is:

           3.0 1b VOC    1 gal VOC  _ 0.41 gal VOC
          gal coating x 7.36 Ib VOC ~  gal coating

The complying coating solids volume fraction is:

          in   n di - 0.59 gal solids
          l.u - u.4i -      coating
Using the solids usage rate calculated above, the gallons of complying coating
required are:

       2.5 gal solids     gal coating   _ 4.24 gal complying coating
              h       x 0.59 gal solids               h

The emissions rate at the existing solids applied rate is:

           3.0 Ib VOC   4.24 gal coating _ 12.72 Ib VQC
          gal coating           h        ~      h
5.2  EQUIVALENCY CALCULATIONS FOR A CAN COATING OPERATION

Example 2 -

The RACT equivalence requirements for can coating operations are tabulated in
45 FR 80825, dated December 8, 1980.  An analysis of two coatings used in an
actual plant is:

                                                            Coating  Coating
                                                             No. 1    No. 2

     (1)  Actual pounds of VOC per gallon of coating less     5.42     1.09
          water and exempt solvents as applied

     (2)  Gallons of each coating applied                     110      240

     (3)  Control efficiency, percent                         0.81

     (4)  Volume percent water and exempt solvents
          in coatings                                         --      41.3


(continued)
                                       17

-------
                                                            Coating  Coating
                                                             No. 1    No. 2
     (5)  Volume percent solids                              26.4     50.0
     (6)  Allowable emission limit, Ib VOC/gal coating        2.8      2.8
          less water and exempt solvents
Calculate the following:
     (1)  Gallons of solids applied.
     (2)  Pounds of VOC per gallon of solids.
     (3)  Pounds of VOC emitted.
     (4)  Allowable VOC emissions.
Answers:
     (1)  The gallons of solids applied can be calculated as follows:
          Gallons of solids applied = (gallons of coating used) x (volume
          percent solids) * 100%
          (Since the quantity of solids used in the equation appears as a
          percentage it is necessary to divide by 100%.)
          Coating No. 1:
          110 „, coating applied x        '*   29
          Coating No. 2:
          9/in „=,! ,.„*+•!,„, anni-5Q,4 v  50 gal solids    120 gal solids
          240 gal coating applied x 100 jja1 coating -     *pplied
     (2)  As noted on Page 10, the pounds of VOC per gallon of solids can be
          calculated as follows:
              Ib VOC    _ Ib VOC/gal coating less water
          gal of solids "      volume percent solids
                             100-volume percent water
                                       18

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          Coating No. 1:
          5.42 1b VOC   100 gal coating   100 - 0 gal coating less water
          gal coating   26.4 gal solids          100 gal coating
           less water
          _ 20.53 Ib VOC
             gal solids
          Coating No. 2:
          1.09 Ib VOC   100 gal coating   100 - 41.3 gal coating less water
          gal coating   50.0 gal solids           100 gal coating
           less water
          = 1.28 Ib VOC
             gal solids
     (3)  The pounds of VOC emitted can be calculated as follows:
          gal of solids x ga1 of solids x ^ " overa11 control efficiency*)
          Coating No. 1:

                       x 29'° gal solids x (1 ~ °'81) = U3A lb voc
          Coating No. 2:

                            gal Sol1ds x (1 ~ 0) = 153'6 1b VOC
     (4)  The allowable VOC emissions can be calculated as follows:
     As calculated in Item (2), the gallons of solids applied for coatings No,
     1 and No. 2 were 29 and 120, respectively.  Assume that the coater will
     apply the same volume of solids with a RACT complying coating.
     Given:    (1) Emission limit: 2.8 lb VOC/gal coating
               (2) VOC density:    7.36 lb VOC/gal
*The overall control  efficiency is equal  to the fraction of total VOC used
that is destroyed or recovered by the control  system.   Overall control effi-
ciency = capture device efficiency x control  device efficiency.
                                       19

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Allowable pounds of VOC = gallons of complying coating applied x allow-
able emission limit,
=    gal solids applied (per unit of time)           2.8 Ib VOC	
  volume fraction solids in complying coating    gal coating less water
                                                   and exempt solvents
Volume fraction VOC:
           2.8 Ib VOC    1 gal VOC  _ 0.38 gal VOC
          gal coating   7.36 Ib VOC    gal coating
Volume fraction solids:
          ' - °-38 9.1 -tfng -
Allowable pounds of VOC for Coating No. 1:
          29 aal solids x  1 ^ coating     2.8 Ib VOC '
          & gal solids x Q 62 gal Sol1ds x gfll coating
          = 131 Ib VOC
Allowable pounds of VOC for Coating No. 2:
          ^n   i   T-J       gal coating      2.8 Ib VOC
          120 gal solids x 0.6j ga1 So113s  * gal coating
          = 542 Ib VOC
Table 2 shows the calculation sequence.
                                   20

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                         TABLE 2.   SUGGESTED FORMAT FOR DETERMINING COMPLIANCE FOR CAN COATING OPERATIONS.












Lb VOC/
gal
coating
less
water
(a)*





Volume
%
solids
(b)*





Volume
%
solvent
(c)





Volume
%
water
(d)*





Lb VOC/
gal
solids1
(e)




Application
rate (gal/
units
produced
(f)*





Units
pro-
duced
(9)*




Gal
coating
applied
(f x g)
(h)




Gal
solids'
applied
(b x h T 100)
(i)
Over-
all
Add-
on
Con-
trol
effi-
ciency2
(J)*




Lb
of VOC
[e x i]
(1 - J)
(k)
                                                       Actual Emissions3
Sheet coating
Sheet coating
Sheet coating
Side seam
Inside spray
End compound
5.42
1.09
5.06
6.34
3.91
4.20
26.4
50.0
31.2
13.9
16.0
42.9
.
-
-
-
-
-
0
41.3
0
0
65.9
0
20.52
1.28
16.23
45.59
8.33
9.80
22
10
10
1.5
8
1.5
5
24
24
18
24
24
110
240
240
27
192
36
29.0
120.0
74.9
3.8
30.7
15.4
0.81
-
0.81
-
-
-
113.0
153.0
231.0
173.8
255.7
150.0
ACTUAL  TOTAL  EMISSIONS
1,077.5
                                          Allowable Emissions Using Complying Coating''
Shtet coating
Sheet coating
Sheet coating
Side seam
Inside spray
End compound
2.8
2.8
2.8
5.5
4.2
3.7
62.0
62.0
62.0
25.3
42.9
49.7
38.0
38.0
38.0
74.7
57.1
50.3
_
-
-
-
-
-
4.52
4.52
4.52
21.76
9.78
7.44
9.4
8.1
5.0
0.8
3.0
1.3
b
24
24
18
24
24
47
194
121
15
72
31
29.0
120.0
74.9
3.8
30.7
15.4
.
.
.
_
-
-
131.0
542.0
338.0
82.7
300.2
114.6
ACTUAL TOTAL EMISSIONS
                                                                                                                1,509.5
*Note:  Data in columns a, b, d, f, g, and j (under actual  emissions)  were obtained  from plant  records  including thinning
        solvent.  Data in columns a, b, and d were determined using procedures in the VOC Data  Sheets.
'For actual  coatings, e
 For complying coatings, e = 1 - K

-------
                      TABLE  2.   (continued)
no
ro
                      D  =  Presumed  density  of VOC  for  complying  coating  (7.36  Ib/gal).

                      2Control  efficiency varies with  emission control devices used.  The percent capture and control efficiency must be established by
                      using  approved  test  methods.  The  source  must  always maintain process and control system parameters as close as possible to
                      those  used  in the original  capture and control efficiency demonstration.  If there are any significant changes in these para-
                      meters,  the  source must make a  new capture  and/or control efficiency demonstration as deemed appropriate by the compliance au-
                      thority.

                      3Concept  based on  the following  principal  for comparing actual and allowable emissions:  Ib VOC emitted = Ib VOC/gal of solids x
                      gal  of solids applied per unit.  (Same gal  of  solids applied for actual and allowable emissions.)

                      ''Complies  with State  VOC emission limitations.

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                                   SECTION 6

                             COMPLEX CALCULATIONS


     This section presents example calculations demonstrating situations that

may require a series of calculations.
6.1  COMPLIANCE DETERMINATION FOR AUTO PLANT PRIMER-SURFACER (GUIDE COAT)
     OPERATION

Example 1 -

An auto primer-surfacer operation uses a coating that contains 3.58 Ib VOC/gal
of coating with a transfer efficiency of 50 percent.  The RACT emission limit
is 2.8 Ib VOC/gal of coating less water at 30 percent transfer efficiency
(waterborne equivalence).  Is the operation in compliance?

     Given:  (1)  The manufacturer's data show that the undiluted coating has
                  50.0 volume percent solids.

             (2)  The plant adds 0.05 gal of thinner blend per gallon of un-
                  diluted coating:

                  (a)  0.02 gallon of thinner No. I/gallon undiluted coating
                       (thinner density 7.36 Ib/gal).

                  (b)  0.02 gallon of thinner No. 2/gallon undiluted coating
                       (thinner density 5.43 Ib/gal).

                  (c)  0.01 gallon of thinner No. 3/gallon undiluted coating
                       (thinner density 9.52 Ib/gal).

             (3)  The density of the undiluted coating is 10.25 Ib/gal.

             (4)  Weight fraction of VOC in undiluted coating =

                            0.333 Ib VOC solvent
                            Ib undiluted coating
                                       23

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First, verify the VOC content of the coating.  In order to do this, the VOC
content of the undiluted coating and the thinners must be calculated.  The
mass of VOC in the undiluted coating is:

         0.333 Ib VQC       10.25 Ib undiluted coating =      3.41 Ib VOC
     Ib undiluted coating x    gal undiluted coating     gal undiluted coating

The mass of thinner added per gallon of undiluted coating is:

0.02 gal thinner No. 1   7.36 Ib thinner No. 1 + 0.02 gal thinner No. 2
 gal undiluted coating      gal thinner No. 1     gal undiluted coating

  5.43 Ib thinner No. 2 + 0.01 gal thinner No. 3   9.52 Ib thinner No. 3
    gal thinner No. 2      gal undiluted coating     gal thinner No. 3


= 0.147 + 0.109 + 0.095 =    °'351 1b thinner
                          gal undiluted coating

The mass VOC per volume coating at application is:

3.41 Ib VOC/gal undiluted coating + 0.351 Ib thinner/gal undiluted coating
                  1.05 gal coating/gal undiluted coating

= 3.58 Ib VOC/gal coating


The undiluted coating has 50.0 volume percent solids.  After the coating is
diluted with 0.05 gallon of thinner per gallon of coating, the volume percent
c r* 1 T H c -i c •
solids is:
                           0.50   _ 0.48 gal solids
                         1 + 0.05 ~ volume coating
The equivalency calculations must be made on a solids basis.  The formula for
determining the maximum allowable emissions on a solids basis is:

Allowable emissions = allowable mass of VOC per volume coating
                       (baseline TEJ (baseline volume solids)

As noted in earlier examples, an assumed VOC density of 7.36 gal is used to
calculate the volume solids content of the "presumptive" RACT coating.

The volume of VOC in the "presumptive" RACT coating is:

                2.8 Ib VOC    1 gal VOC  _ 0.38 gal VOC
               gal coating * 7.36 Ib VOC "  gal coating
                                       24

-------
Therefore, the baseline volume of solids is:

                         !   n ,o _ 0.62 gal solids
                         1 " u
-------
6.2  DETERMINING COMPLIANCE FOR A LARGE APPLIANCE COATING LINE USING SEVERAL
     TYPES OF SPRAY EQUIPMENT

Example 2 -

A large appliance manufacturer has a coating operation that employs electro-
static spray coating equipment and manual spray coating equipment.  The
following data are available regarding the operation.  Determine the
compliance status.  If the large appliance manufacturer is out of compliance,
what percent reduction is required to achieve compliance?

                                                  (A)           (B)
                                             Electrostatic    Manual
                                                coating       coating

     Transfer efficiency, percent                 90            40

     Average volume percent of solids in
      coating                                     39            39

     VOC content, Ib VOC/gal coating
      less water                                   4.5           4.5

     Gallons of coating used per day              30.4          47.1

     Emission limit, Ib/gallon less                2.8           2.8
      water

     Baseline transfer efficiency for             60            60
      large appliances, percent

The baseline transfer efficiency is 60 percent for a large appliance coater.
Table 3 is a tabulation of the available data and calculation results.   The
actual calculations follow.
                                       26

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TABLE 3.  LARGE APPLIANCE MULTITRANSFER EFFICIENCY CALCULATION.

Spray
type
Gallons
of coat-
ing/day
Solids,
vol.
%
Lb VOC/
gallon
coating
Lb VOC/
gallon
solids

%
TE
Lb VOC/gal-
lon solids
applied
Gallons
of solids
applied/day
Pounds
of
VOC/day
                            Actual emissions
A
B
30.4
47.1
39
39
4.5
4.5
11.5
11.5
90
40
12.8
28.8
10.7
7.3
136.8
212.0
Total 348.8
Allowed emissions
A
B
28.8
19.6
62
62
2.8
2.8
4.5
4.5
60
60
7.5
7.5
10.7
7.3
80.6
54.9
Total 135.5

-------
Under the actual emissions category, the following calculations can be made.

For A and B, the mass of VOC per volume of solids is:

                4.5 Ib VQC    1 gal coating  _ 11.5 1b VOC
               gal coating x 0.39 gal solids ~ gal solids


For As the mass of VOC per volume of solids applied is:

 4.5 Ib VOC    1 gal coating         1 gal solids       =    12.82 Ib VOC
gal coating   0.39 gal solids   0.90 gal solids applied   gal solids applied


For B, the mass of VOC per volume of solids applied is:

 4.5 Ib VOC    1 gal coating          1 gal solids      _    28.85 Ib VQC
gal coating   0.39 gal solids   0.40 gal solids applied ~ gal solids applied

For A, the volume of solids applied per day is:

                                         0.90 gal
30.4 gal coating   0.39 gal solids    solids applied _ 10.7 gal solids applied
       day       x   gal coating   x gal solids used             day

For B, the volume of solids applied per day is:

                                         0.40 gal
47.1 gal coating   0.39 gal solids    solids applied _ 7.3 gal  solids applied
      day            gal coating   x gal solids used ~          day

For A, the mass of VOC emissions per day is:

                4.5 Ib VOC   30.4 gal coating = 136.8 Ib VOC
               gal coating          day              day

For B, the mass of VOC emissions per day is:

                4.5 Ib VOC   47.1 gal coating _ 212.0 Ib VOC
               gal coating          day       ~      day

Under the allowed emissions category, the following calculations can be made.

For A and B, the volume fraction of VOC in the baseline coating is:

                2.8 Ib VOC    1 gal VOC  = 0.38 gal VOC
               gal coating   7.36 Ib VOC    gal coating
                                       28

-------
The volume fraction solids in the coating is:

                    1 . 0.38 gal VOC _ 0.62 gal solids
                      " "gal coating     gal coating


The baseline mass of VOC per volume solids is:

                2.8 Ib VOC    1 gal coating  _ 4.5 Ib VOC
               gal coating   0.62 gal solids ~ gal solids


For A and B, the maximum allowable emissions are:

 2.8 Ib VOC    1 gal coating       1 gal solids used    _     7.5 Ib VOC
gal coating   0.62 gal solids   0.60 gal solids applied   gal solids applied

The volume of solids applied remains the same.  Therefore, for A, the gallons
of complying coating used per day would be:

10.7 gal solids applied    1 gal coating       1 gal solids used
          day             0.62 gal solids   0.6 gal solids applied

_ 28.8 gal coating
         day

For B, the gallons of complying coating used per day would be:

7.3 gal solids    1 gal coating    1 gal solids used _ 19.6 gal coating
      day      x 0.62 gal solids     0.6 gal solids         day
                                         applied

For A, the mass of VOC emissions allowed per day is:

                2.8 Ib VOC   28.8 gal coating = 80.6 Ib VOC
               gal coating         day        ~     day


For B, the mass of VOC emissions allowed per day is:

                2.8 Ib VOC   19.6 gal coating ^ 54.9 Ib VOC
                           /\
               gal coating          day             day

The total actual VOC emissions from A and B are 348.8 Ib VOC per day.  The
total allowable VOC emissions are  135.5 Ib VOC per day.  Therefore, the opera-
tion is out of compliance.  To achieve compliance, the required reduction in
emissions is:


                             '348.S35'5 x 100 = 61 percent
                                       29

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                                   SECTION 7
                   GRAPHS AND TABLES USEFUL IN APPROXIMATING
               AND DOUBLE-CHECKING SURFACE COATING CALCULATIONS

     Figure 1 can be used to evaluate compliance alternatives for waterborne
and organic-borne coatings.  This can be done by drawing a horizontal line
from the required VOC content of coating (less water and exempt solvents) to
the appropriate curve (depending on ratio of water to organic solvent in coat-
ing).  A vertical line is then drawn from the point of intersection to the
x-axis which yields the volume percent solids.  All of the coatings represent-
ed by the horizontal line have the same pounds of VOC solvent per gallon of
coating (less water and exempt solvents).  A vertical line in Figure 1 from
the volume percent solids to the organic-borne line represents all of the
coatings with the same volume percent solids.  Horizontal lines drawn from the
appropriate waterborne curves yield the VOC contents of the coatings less wa-
ter and exempt solvents.  Note that these values are considerably different
for coatings with the same solids contents.
     Figures 2 and 3 are the same graph, only Figure 2 is drawn to a larger
scale.  If the pounds of VOC solvent per gallon of coating (less water and
exempt solvents) is known, these figures can be used to approximate the pounds
of VOC solvent per gallon of coating solids, assuming a solvent density of
7.36 pounds per gallon.
     Table 4 presents volume percent solids equivalency data for different
coating operations.  Table 5 presents CTG Equivalency Data.  A VOC density of
7.36 pounds per gallon is assumed in these tables.  Table 6 provides equiva-
lent solids deposited limits.  Table 7 presents some useful conversion fac-
tors.
                                       30

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OO
           10
20    30     40    50    60

   VOLUME % SOLIDS IN COATING
70"
80    90    100
   Figure 1.  Graph for determining equivalent solids/VOC (solvent)
         contents of waterbome and organic-borne coatings.
                                  31

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 POUNDS OF VOC (SOLVENT)  PER GALLON OF COATING
       (MINUS WATER AND EXEMPT SOLVENTS)

    Figure 2.  Graph for determining pounds
of VOC (solvent) per gallon of coating solids.
                       32

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    POUNDS OF VOC  (SOLVENT)  PER  GALLON  OF  COATING
          (MINUS WATER  AND EXEMPT  SOLVENTS)
   Figure 3.   Smaller-scale graph  for determining
pounds of VOC (solvent)  per gallon of coating solids,
                          33

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            TABLE  4.   CTG  VOLUME  PERCENT  SOLIDS  EQUIVALENCY  DATA
Industrial finishing categories
CAN INDUSTRY
Sheet basecoat (exterior and
interior) and over-varnish;
two-piece can exterior (basecoat
and over-varnish)
Two- and three-piece can interior
body spray, two-piece can exteri-
or end (spray or roll coat)
Three-piece can side-seam spray
End sealing compound
COIL COATING
Prime and topcoat or single coat
operation
FABRIC COATING
Fabric coating line
Vinyl coating line
PAPER COATING
Coating line
AUTOMOTIVE AND LIGHT-DUTY TRUCK
ASSEMBLY PLANT
Primer (electrodeposited) applica-
tion, flashoff area and oven
Surfacer (guide-coat) application,
flashoff area and oven
Topcoat application, flashoff
area and oven
Kg VOC
per liter
of coating
less water
0.34
0.51
0.66
0.44
0.31
0.35
0.45
0.35
0.14
0.34
0.34
Lb VOC
per gallon
of coating
less water
2.8
4.2
5.5
3.7
2.6
2.9
3.8
2.9
1.2
2.8
2.8
Solvent-borne
coating
equivalent
volume % solids
62.0
42.9
25.3
49.7
64.7
60.6
48.4
60.6
83.7
62.0
62.0
(continued)
                                      34

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TABLE 4.  (continued)
Industrial finishing categories
AUTOMOTIVE AND LIGHT-DUTY TRUCK
ASSEMBLY PLANT (continued)
Final repair application,
flashoff area and oven
METAL FURNITURE
Coating line
MAGNET WIRE INSULATION
Wire coating oven
LARGE APPLIANCES
Prime, single, or topcoat
application area, flashoff
area and oven
MISCELLANEOUS METAL PARTS
Air-dried items
Clear-coated items
Frequent-color-change items
Powder-coated items
Extreme performance coatings
Kg VOC
per liter
of coating
less water
0.58
0.36
0.20
0.34
0.42
0.52
0.36
0.05
0.42
Lb VOC
per gallon
of coating
less water
4.8
3.0
1.7
2.8
3.5
4.3
3.0
0.4
3.5
Solvent-borne
coating
equivalent
volume % solids
34.8
59.2
76.9
62.0
52.4
41.6
59.2
94.6
52.4
                                      35

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                            TABLE 5.  CT6 EQUIVALENCY DATA (VOC DENSITY = 7.36 LB/GAL)


Industrial finishing categories
Can Industry
Sheet basecoat (exterior and interior)
and over-varnish; two-piece can ex-
terior (base-coat and over-varnish)
Two- and three-piece can interior body
spray, two-piece can exterior end
spray or roll coat
Three-piece can side-seam spray
End sealing compound
Coil Coating
Prime and topcoat or single coat op-
eration
Fabric Coating
Fabric coating line
Vinyl coating line
Solvent-
borne
coating
equivalent
volume %
solids
62.0
42.9
25.3
50.3
64.7
60.6
48.4


Lb VOC
per gallon
of coating
less water
2.8
4.2
5.5
3.7
2.6
2.9
3.8


Kg VOC
per liter
of coating
less water
0.34
0.51
0.66
0.44
0.31
0.35
0.45


Lb VOC
per gallon
of solids
4.5
9.8
21.7
7.4
4.0
4.8
7.9


Kg VOC
per liter
of solids
0.55
1.19
2.61
0.88
0.48
0.58
0.93
co
en
      (continued)

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      TABLE 5.   (continued)
Industrial finishing categories
Paper Coating
Coating line
Automotive and Light-Duty Truck
Assembly Plant
Primer (electrodeposition) application,
flashoff area and oven
Surfacer (guide coat) application,
flashoff area and oven
Topcoat application, flashoff area and
oven
Final repair application, flashoff
area and oven
Metal Furniture
Coating line
Magnet Wire Insulation
Wire coating oven
Solvent-
borne
coating
equivalent
volume %
solids

60.6
83.7
62.0
62.0
34.8
59.2
6.9
Lb VOC
per gallon
of coating
less water

2.9
1.2
2.8
2.8
4.8
3.0
1.7
Kg VOC
per liter
of coating
less water

0.35
0.14
0.34
0.34
0.58
0.36
0.20
Lb VOC
per gallon
of solids

4.8
1.4
4.5
4.5
13.8
5.1
2.2
Kg VOC
per liter
of solids

0.58
0.17
0.55
0.55
1.67
0.61
0.26
GJ
      (continued)

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      TABLE 5.  (continued)
Industrial finishing categories
Large Appliances
Prime, single, or topcoat application
area, flashoff area and oven
Miscellaneous Metal Parts and Products
Air-dried items
Clear-coated items
Frequent-color-change items
Powder-coated items
Extreme performance coatings
Solvent-
borne
coating
equivalent
volume %
solids
62.0
52.4
41.6
59.2
95.6
52.4
Lb VOC
per gallon
of coating
less water
2.8
3.5
4.3
3.0
0.4
3.5
Kg VOC
per liter
of coating
less water
0.34
0.42
0.52
0.36
0.05
0.42
Lb VOC
per gallon
of solids
4.5
6.7
10.3
5.1
0.4
6.7
Kg VOC
per liter
of solids
0.55
0.80
1.25
0.61
0.05
0.80
CO
00

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                            TABLE 6.  EQUIVALENT CTG SOLIDS DEPOSITED LIMITS

Auto and Light-duty Truck*
Surfacer
Topcoat
Metal Furniture
Coating line
Large Appliances
Coating Line
Lb/gal-H,0
(kg/1)
2.8
(0.34)
2.8
(0.34)
3.0
(0.36)
2.8
(0.34)
Volume % Solids
62.0
62.0
59.2
62.0
Baseline T.E.
30
30
60
60
Lb/gal solids deposited
(kg/1)
15.1
(1.83)
15.1
(1.83)
8.4
(1.01)
7.5
(0.91)
*Waterborne equivalence

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                      TABLE  7.   METRIC  CONVERSION  FACTORS
            Metric
           abbrevation
           kg
           liter
           Mg
           MT
           dscm
           scmm
      Metric unit
kilogram (103 grams)
liter
megagram (106 grams)
metric ton (106 grams)
dry standard cubic meters
standard cubic meter per min
  Equivalent
 English unit
    2.2046 Ib
    0.2642 gal, 0.353 ft3
2,204.6 Ib
2,204.6 Ib
   35.31 dry St. ft3
   35.31 ft3/min
B.  Multiply Ib/gal  x 0.12 to get kg/liter
C.  Multiply kg/liter x 8.34 to get Ib/gal
D.  Temperature:   Degrees Celsius or centigrade (°C)  can  be  converted  to
    degrees Fahrenheit (°F) by the following forumla:
                              t°F = 1.8 (t°C) + 32
                                       40

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                                 REFERENCES


1.  "Compliance with VOC Emission Limitations for Can Coating Operations,"
    45 FR 80824, dated December 8, 1980.

2.  "Glossary for Air Pollution Control of Industrial Coating Operations."
    Second Edition.  Emission Standards and Engineering Division, U.S. Envi-
    ronmental Protection Agency.  EPA-450/3-83-013R.  December 1983.

3.  Memorandum entitled "Appropriate Transfer Efficiencies for Metal  Furni-
    ture and Large Appliace Coating," from G.T.  Helms, Chief, Control  Pro-
    grams Operations Branch, to Chief, Air Programs Branch, Regions I-X,
    dated November 28, 1980.

4.  Memorandum entitled "Appropriate Transfer Efficiency for Water-Borne
    Equivalence," from R.G. Rhoads, Director, Control Programs Development
    Division to Director, Air and Hazardous Materials Division, Regions I-X,
    dated July 3, 1979.

5.  Memorandum entitled "Determination of Capture Efficiency," from J. Berry,
    Chief, Chemical Analysis Section, to D. Cook, EPA Region IV, dated July
    7, 1980.

6.  Memorandum entitled "Equivalency Calculations with the CTG Recommenda-
    tions for Surface Coating," from R.G. Rhoads, Director, Control Programs
    Development Division, to David Kee, Director, Air and Hazardous Materials
    Division, Region V, dated October 17, 1980.

7-  Memorandum entitled "Procedure to Calculate Equivalency with the CTG
    Recommendations for Surface Coating, from R.G. Rhoads, Director,
    Control Programs Development Division, to Chief, Air Programs Branch,
    Regions I-X, dated May 5, 1980.

8.  Memorandum entitled "RACT Options for Can Coating Operations," from R.G.
    Rhoads, Director, Control Programs Development Division to Director, Air
    and Hazardous Materials Division, Regions I-X, dated November 21, 1978.

9.  Memorandum entitled "Role of Improved Transfer Efficiency in Demonstrat-
    ing Compliance with the CTG Recommendations for Surface Coating", from
    G.T. Helms, Chief, Control Programs Operations Branch, to W.S. Baker,
    Chief, Air Programs Branch, Region II, dated December 2, 1980.
                                      41

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10.   "Procedures  for  Certifying  Quantity  of  Volatile  Organic  Compounds  Emitted
     by Paint,  Ink, and  Other  Coatings."   Emission  Standards  and  Engineering
     Division,  U.S. Environmental  Protection Agency.   EPA-450/3-84-019.   De-
     cember 1984.

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                 APPENDIX A

          GLOSSARY OF TERMS USED IN
      AIR POLLUTION CONTROL OF EMISSIONS
      FROM INDUSTRIAL COATING OPERATION
EPA PUBLICATION NO. 450/3-83-013R, PAGES 26-29
                      A-l

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A-2

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°    HOW MUCH COATING  IS NEEDED TO DO A PARTICULAR JOB?

     The same volume of coating solids must be deposited on an object
to coat  it to  a  desired  film  thickness  regardless  of  the type  of
coating  or  volatile  organic  compound content  of the coating  used.
Solids make the film.  Volatiles (VOC. water, and non-photochemlcally
reactive solvents) evaporate.

     Four gallons of a 25 volume percent (v/o) solids coating must be
used to get one gallon of coating sol Ids.
But, only two  gallons  of a 50 v/o solids coating must be used to get
one gallon of  coating solids.
                                   26
     This means that  twice as much work can be done with a gallon of
50 v/b~"sb1ids coating than with a gallon of Zb v/o sonds coating.
Twice as many  gallons  of  25 percent solids  coating  are needed than
gallons of 50 percent sol Ids coating to do the same Job.
e    HOW DO EMISSIONS FROM DIFFERENT  COATINGS  COMPARE?

     Comparisons of the percent difference  1n emissions between  two
coatings, or between a coating and an emission limit, must  be done on
a solids basis.
                                                                                  VOC.
                                                                                       Each gallon of the 25 v/o  solids  coating  contains  5.5  pounds  of
                                                                                       So, for each  gallon of coating  solids,  22.0 pounds of VOC  are
                                                                                  emitted.
                                                                                       5.5 pounds VOC
                                                                                       gallon coating
                              4 gallons coating
                               gallon solids
     Each gallon  of  the 50  v/o  solids  coating  contains 3.7 pounds
of VOC.
                                                                                                                    27

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      So, for  each  gallon of  coating  solids,  7.4 pounds  of VOC are
 emitted.
           3.7 pounds VOC
           gallon coating
                                  2 gallons coating
                                   gallon solids
      Thus, emissions from the  50  v/o  solids coatings are 66 percent
 less than  from the  25  v/o   solids  coating when  providing  an equal
 amount of solids to the process.
                   22.0-7.4
                                    0.66
 0  WHAT EMISSION REDUCTION IS NEEDED TO  MEET AN EMISSION LIMIT?

      This calculation,  which  must  also be  done on a  solids basis,
 is the  same  as  that   used   above  Eo  compare   emi ssions   from  two
 different coatings.

      A coater who uses  a 25 v/o solids  coating containing 5.5 pounds
 of VOC per  gallon,  less  water, must reduce emissions  by  66 percent
 to meet an emission  limit of  3.7 pounds  of VOC per gallon,
 less  water.
   HOW MUCH DO  IMPROVEMENTS  IN TRANSFER EFFICIENCY HELP A SOURCE TO
   COMPLY?
     The coater may want  to use a coating that does not comply with a
regulation and compensate by  improvements in the transfer efficiency
with which  the  coating  is applied  to meet  an  equivalent  emission
level.  In order  to  calculate credit for VOC reductions which result
from improvements in transfer efficiency, calculations should be done
using units of:

                             Ib VOC
                      gallon solids deposited

     These units  are determined  by dividing Ib  VOC/gallon  solids  by
the transfer efficiency expressed as a decimal  fraction.  For
example, if the  starting transfer efficiency is 60 percent,  the units
would be:
                                                  1.0 gal  solids
                                                  in coating used
     Ib VOC
gal solids deposited
(with the old system)
   Ib VOC
gal  solids
in coating used
                                                  U.6U gal  solids
                                                    deposited
                                28
                                                                                            If  the  same  paint  were  now  to  be  sprayed  with  90  percent
                                                                                       transfer efficiency, the new value would he:
                                                                 Ib VOC
1 b VOC
gallon solids
in coating used
1.0 gal solids
in coating used
0.90 gal solirls
   deposited
                                                            gallon solids
                                                              deposited
                                                            (with new s'ystem)

                                                                 If  both  the  solvent  content of  the  coating  and  the  transfer
                                                            efficiency are changed, the situation becomes:

                                                                                                              1.0 gal  solids  in
                                                                                                           j   new coating used
                                                                                                                T gal solids
                                                                                                                  deposited
                                                                                            Ib VOC
                                                                                                                        Ib VOC
                                                                                       gal  solids  deposited
                                                                                       (with  new paint and
                                                                                       new  transfer  efficiency)
      gal soiids in
      new coating
      used
                                                                                       where  j   =   the   new  transfer  efficiency  expressed  as  a  decimal

                                                                                           Expressed in  these units, the  emissions from  the  old  and new
                                                                                       systems  can  be directly compared to determine the reduction achieved.

                                                                                       NOTE:  For  'metal  furniture  and  appliance  coating,  the  EPA  has
                                                                                       recommended*  that credit for transfer efficiency  be given from a base-
                                                                                       line of   60  percent  transfer  efficiency  (TE).   For  example,  if  a
                                                                                       company  goes  from 35 percent TE  to 85 percent TE,  credit should only
                                                                                       be given for  going  from  60 percent  TE to  85  percent  TE  to avoid
                                                                                       rewarding a  source that has  historically had  poor transfer efficiency
                                                                                       -  hence  a high emission rate.

                                                                                           The rationale  for this  is  that  60  percent TE  is  a reasonable
                                                                                       transfer efficiency  to  achieve  for  these  industries,  and  credit
                                                                                       should only  be given for exceeding 60  percent TE.

                                                                                           For the automobile industry,  the  CTG  recommendation for baseline
                                                                                       transfer efficiency  is 30  percent TE  for both primer  surfacer and
                                                                                       topcoat. This  is the  efficiency  at which waterborne coatings were
                                                                                       applied  at  two existing assembly plants.
                                                                                       * Memo froni  G.  T.  Helms, Chief, Control  Programs  Operations Branch,
                                                                                       EPA, to  Chief,  Air Programs  Branch,  EPA  Regions  I-X,  "Appropriate
                                                                                       Transfer Efficiencies for Metal Furniture and Large Appliance
                                                                                       Coating", November 23, 1980.
                                                                                                                      29

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             APPENDIX B

PROCEDURES FOR CERTIFYING QUANTITY OF
 VOLATILE ORGANIC COMPOUNDS EMITTED
  BY PAINT, INK, AND OTHER COATINGS
                 B-l

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            United States      Office of Air Quality        EPA-450/3-84-019
            Environmental Protection  Planning and Standards      December 1984
            Agency         Research Triangle Park NC 27711

            Air
&EPA      Procedures for
            Certifying
            Quantity of
            Volatile  Organic
            Compounds
            Emitted by Paint,
            Ink,  and Other
            Coatings
                    NOTICE


             THIS EDITION INCLUDES PAGES III-4

             AND III-9 AS REVISED JUNE 19,1986

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                                 EPA-450/3-84-019
 Procedure for Certifying Quantity of
Volatile  Organic Compounds Emitted
  By  Paint,  Ink, and Other Coatings
             Emission Standards and Engineering Division
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Air and Radiation
             Office of Air Quality Planning and Standards
             Research Triangle Park, North Carolina 27711

                     December 1984

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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.
                                                  ti

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                                PREFACE

     This manual  was conceived as  a  way to  provide  simple step-by-step
instructions for certifying the quantity of volatile  organic compounds
(VOC) that will  be released by a coating.   It  has not turned out that
way.  The guidance is here, but in spite of great diligence, the
instructions remain imposing.

     The manual  was prepared for several reasons.   First, the coatings
industry, as represented by the National Paint and  Coatings Association,
had  requested a certification procedure which  would relieve their custom-
ers the expense of analysis.  Second, the complexity of  the calculations
necessary to determine compliance, for example, when  dilution solvent is
added to a coating, continue to confound Federal, State  and Local enforce-
ment personnel.  Finally, results  of a recent  review  of  the Agency's
reference method for determining VOC reemphasized the importance of
analytical procedures to verify VOC  content.

     In response to the results of the review  of the  test methods, this
manual  reaffirms that Reference Method 24 or its constituent methods
developed by the American Society for Testing  and Materials (ASTM),
are  the procedures by which the VOC  content of a coating will be deter-
mined for compliance with Federal  regulations.  The earliest guidance
was  not so  specific.  In 1977, the first report*, written to assist
States  in developing regulations for sources of VOC emissions,  provided
recommendations  for the maximum allowable VOC  content for complying
coatings in a variety of industries.  These values  were  expressed in
mass of VOC per  unit volume of coating.  In deriving  the recommended
limitation, the  VOC content of a coating was calculated  based on the
solids  content  provided by  the coating manufacturer.   The Agency calcu-
lated the mass of  VOC in the coating by assuming the YOC had a  density
of 7.36 pounds  per gallon.

     Solvent and VOC were  used somewhat  interchangebly even though  it
was  recognized  that organics  such as resin monomer, oligimers,  and
reaction by-products could be released  by a coating  during  the cure.
There was no accepted analytical method  available for measuring the
total VOC which  would be released by a  coating.  The initial  guidance*
provided an analytical method for use only  for  air-dry coatings, those
where all VOC emissions  would be  expected  to  come  as a  result of evapor-
ation of solvent.   On a  volume  basis,  air  dry coatings constituted the
largest catagory of coatings  then in use.

      The Agency subsequently  developed  a more  general analytical proce-
dure that could be used  to determine the total  YOC in a coating.  On
October 3,  1980, the Agency published  "Reference Method 24 (RM-24)  -
 Control of Volatile Organic Emissions from  Stationary Sources -
 Volume II:   Surface Caoting of Cans,  Coils,  Paper,  Fabrics, Automobiles,
 and Light-duty Trucks,  Document No.  EPA-450/2-77-008.
                                     m

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Determination of Volatile Matter Content, Density, Volume Solids, and
Weight Solids of Surface Coatings," in the Federal Register  (45 FR 65958).
For the first time the Agency formally specified  an  analytical method
for the VOC content of those  coatings that cure by chemical  reaction.
Even then, the announcement continued to  allow the manufacturer's formu-
lation to be used to calculate  the VOC content but specified that the
analytical technique, RM-24,  woul d be the reference  in  any conflict
between the two.

     During 1981 and 1982,  as more State  and Federal  regulations were
established, the demand for low-solvent coatings  began  a continuing
increase  in the sales volume  of reaction-cure coatings.  There was some
concern voiced by the industry in how appropriate the reference method
was for these type coatings.   To find out, the Agency began  a review of
RM-24 to  determine the effect of temperature and  exposure time on the
indicated VOC "content".   It  was concluded that  the  maximum  effect of
those time-temperature combinations that  were examined  amounted to only
about a 10 percent variation.  Somewhat more surprising was  that the
solvent sometimes accounted for only 50 to 70 percent of the total
VOC measured by the reference method.

     The  obvious conclusion was that RM-24 is a better  measure of the
total organics freed by a  coating than  is the solvent.  This manual
implements a policy based  on  that conclusion.  Certification of VOC
content on the attached Data  Sheets must  be based on an analysis using
RM-24.  No longer will solvent  content be permitted  as  a surrogate for
VOC unless a showing is first made  that  its use  is a reasonable alter-
native or equivalent method of determining the VOC content of that
particular coating.

     One  final comment.  Since VOC  is  not always  synonomous  with solvent,
it follows that the amount of solids in a coating cannot be  obtained by
subtracting the solvent from  the total  volume of  coating.  The original
Federal Register proposal  for RM-24, published on October  3, 1980, recom-
mended the American Society of Test Materials test Number  D2697 as the
appropriate method of determining  solids  content. Subsequent comments
from the  industry maintained  that  this  test  is unreliable.   As a result,
when promulgated in 1980,  RM-24 specified that the solids  content of a
coating can  be obtained only from  the  manufacturer's formulation of  the
coating.
                                    Dennis Crumpler
                                    December 14, 1984
                                    IV

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                          TABLE OF CONTENTS

CHAPTER                                                          Page

         PREFACE	111

         GLOSSARY OF TERMS AND SYMBOLS	vi

   1     INTRODUCTION 	  1-1

   2     -VOC CONTENT OF PAINT, INK, AND OTHER COATINGS
            "AS SUPPLIED" BY THE COATING MANUFACTURER  	  II-l

         2.1  VOC DATA SHEET FOR  "AS SUPPLIED" COATINGS ....  11-2

         2.2  IMPLEMENTING  INSTRUCTIONS	11-3

   3     VOC CONTENT OF PAINT, INK AND OTHER COATINGS
            "AS APPLIED" TO  THE SUBSTRATE BY THE USER	III-l

         3.1  VOC DATA SHEET FOR  "AS APPLIED" COATINGS	II1-2

         3.2  IMPLEMENTING  INSTRUCTIONS 	  III-4

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                            GLOSSARY OF TERMS
"As Applied"     the  condition  of  a  coating  after  dilution by  the user
                just prior to  application to the  substrate.
"As Supplied"    the  condition  of  a  coating  before dilution, as sold
                ana  delivered  by  the coating manufacturer to  the user.
      (Dc)a     coating density "as applied"
      (Dc)s     coating density,  "as supplied"
      Dj        density of dilution solvent
      D^       density of organic  solvent/water  mixture
      Dw        density of water (8.33 Ib/gal)
      Rd        dilution solvent ratio,  equals  the volume of  VOC added
                per unit volume of  coating  "as  supplied"
      Rdt       equals the voluue of premixed water and VuC  added  per
                unit volume of coating "as  supplied"
      (Vn)a     Volume percent solids  of coating "as applied"
      (Vn)s     Volume percent solids  of coating "as supplied"
      (VOC)a    VOC content of "as applied" coating, expressed  as  mass
                of VOC per unit volume of coating less water or as mass
                of VuC per unit volume of solids
      (VOC)S    VOC content of "as supplied" coating, expressed as mass
                of VOC per unit volume of coating less water or as mass
                of  VOC per unit volume of solids
      (Vw)a     the water content, in volume percent, of coating "as applied"
      (Vw)d     the water content, in volume percent, of the dilution solvent
                added  to  the  "as supplied" coating
       (Vw)s     the water content, in volume percent, of the coating
                 "as  supplied"
       (W0)a      the organic volatile  content,  in weight percent,  of the
                 coating  "as applied"
       (W0)s      the organic volatile  content,  in weight percent,  of the
                 coating  "as supplied"
                                    VI

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(Wv)a     the  weight  percent  of  total  volatiles  in  the  coating
          "as  applied"
(Wv)s     the  weight  percent  of  total  volatiles  in  the  coating
          "as  supplied"
(Ww)a     the  weight  percent  water  in  the  coating  "as applied"
(Ww)
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                            1.   INTRODUCTION

     This Manual  provides step-by-step instruction for preparation of two
data sheets developed by the Environmental  Protection Agency which may be
used by coating manufacturers and users to present information on the
quantity of volatile organic compounds* (VOC) emitted from a coating.
One of the data sheets may be prepared by the manufacturer of the coating;
the second would be used by the company that applies the coating to a
substrate.

      The first VOC data sheet, which would be prepared by the manufacturer,
provides information on the volatile organic content of a coating as it is
delivered to a customer.  This is referred to as the VOC content of the
coating "as supplied" (by the manufacturer to the user).

     The second VOC data sheet, which would be prepared by the user or coater,
provides information on the quantity of volatile organic compounds present  as
the coating is used or applied to the substrate and includes the effect
of any dilution solvent added before application.  This is referred to as the
VOC content of the coating  "as applied" (to the substrate).

     The coating user may submit, and the Agency enforcing a regulation may
accept, these data sheets as prima facie evidence of the actual VOC content
of a coating.  The referee  method for ultimate determination of compliance,
however, will continue to be the method specified in the applicable regula-
tion  (for example, LPA Reference Method 24 or individual AbTM methods).
 *Volatile Organic Compound (VOC)  - Any organic compound which participates
  in atmospheric photochemical  reactions; that is,  any organic compound
  other than those whicn the Administrator designates as having negligible
  photochemical  reactivity.  VOC may be measured by a reference method,
  an equivalent method,  an alternative method, or by procedures specified
  under any regulation.
                                    1-1

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2.  VOC CONTENT OF PAINT, INK AND OTHER COATINGS



    "AS SUPPLIED" BY THE COATING MANUFACTURER TO THE USER
                        II-l -

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              VOC DATA SHEET:

          PROPERTIES OF THE COATING "AS SUPPLIED" BY THE MANUFACTURER
Coating Manufacturer:
Coating Identification:

Batch Identification:	

Supplied To:	
Properties of the coating  as  supplied^ to the customer:

   A.   Coating Density  (Dc)s  :    _ Ib/gal      _ kg/1

         I  7 ASTM D147b       /  J Other2

   B.   Total Volatiles  (Wv)s  :    _ Weight Percent

              ASTM D2369       f~T Otner2
   C.   Water Content:   1.   (Ww)s  _ Weight Percent

               ASTM D3792       /~7 ASTM D4017        ~  Other2
                        2.   (Vw)s  _ Volume Percent

         /  7  Calculated       /  7 Other?

   u.   Organic Volatiles (WQ)S  :  _ Weight Percent

   £.   Nonvolatiles Content (Vn)s :  _ Volume Percent

   F.   VOC Content (VOC)S:   1.  _ Ib/gal coating less water

                               or _ kg/1 coating less water

                             2.  _ Ib/gal solids

                               or _ kg/1 solids
 Remarks: (use reverse side)
 iThe  subscript "s" denotes each value is for the  coating  "as  supplied"
 by  the  manufacturer.

 2Explain  the other method used under "Remarks".

                             Signed:	


                                     II-2 '

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2.2  IMPLEMENTING INSTRUCTIONS FOR THE VOC DATA SHEET FOR "AS SUPPLIED"  COATINGS


     This UATA SHEET is normally completed by the coating manufacturer and
provided to the user.l   It will henceforth be referred to as the "AS SUPPLIEu"
VUC UATA SHEET.

A.  The "as supplied" coating density, (Dc)s^, is determined using
    "ASTM J1475 - Standard Test Method for Density of Paint, Lacquer,
    and Related Products."

B.  The weight percent of total volatiles in a coating, (Wv)s, is determined
    by "ASTM u23b9 - 81 Standard Method for Volatile Content of Coatings."
    drying conditions to be used are 11G°C for 1 hour3.

C.  Water Content

    1.  The weight percent water,  (Ww)s,  is determined by "ASTM D3792 -
        Standard Test Method  for Water Content of Water-Reducible Paints
        by Direct Injection Into a bas Chromatograph," or "ASTM 1)4017 -
        Standard Test Metnod  for Water in Paints and Paint Materials by
        the Narl Fischer Method."^  An  acceptable alternative to thtse
        procedures  for purposes of preparing  the data  sheet would be to
        calculate the weight  percent  water from the manufacturer's coating
        formulation.
 lEPA's Reference Method 24 (40 C.F.R.  Part  faO,  App. A), contains the
 ASTM methods referenced in these instructions.

 2The subscript "s"  denotes those parameters of  a  coating  when measured
 in the "as supplied"  condition, before dilution by  the  user.

 3If the manufacturer  believes a specified method  does  not give  results
 that are representative of the actual  cure mechanism,  he  may  petition the
 enforcement authority for approval of an alternate  analytical method.   Any
 alternate method or alteration to the methods and procedures  in these instruc-
 tions or in any applicable regulation would be subject to review and approval
 by the appropriate State and Federal enforcement  agency.

 ^Volatile compounds classified by EPA as having negligible photochemical
 reactivity such as 1,1,1-trichloroethane and methylene chloride, etc.,  and
 listed as exempt in the applicable Federal and State VOC regulation should
 be treated in the same manner as water.  The weight percent.of negligibly
 reactive compounds in a coating should be  determined from the manufacturer's
 formulation.  The volume percent can  then  oe calculated using equation  II-l
 when the weight percent and  density of the negligibly reactive compounds are
 substituted for those of water.  The  weight and volume percent can be used in
 Equations II-2  and 11-6,  respectively, in  place of (Ww)s and (Vw)s.
                                      II-3

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    2,   The water  content, in volume percent, (Yw)s, can be calculated
        by the  equation:

                where  Dw  is the density of water, 8.33 Ibs/gal.

D.  The organic volatiles content, (W0)s, i.e., the VOC content
    expressed as a  percent by weight, is determined by the following
    equation^:


                (W0)s  =  (Wv)s - 
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F.  The  VOC content of the "as supplied" coating (VOC)S can now be calculated
    and  thereby expressed in terms used by most State or Federal  regulations.

    1.   The mass  of VOC per unit volume of coating less water:

        a.   If  the coating contains no water, the equation is calculated
            as  follows:
                             ruos

        b.  If the coating  contains  water, Equation II-5 becomes:
                 (VOC)   .
                     '
                          1001 -
    2.  The VOC content may also be calculated  in terms of mass of VOC per
        unit volume of solids (nonvolatiles).   For both solvent-borne and
        waterborne coatings, the equation  is:
                 (VOC)s =
                                (DcJs                                   M-7
                                       II-5 .

-------
3.  VOC CONTENT OF PAINT,  INK AND  OTHER  COATINGS



    "AS APPLIED" TO THE SUBSTRATE  BY  THE USER
                     ni-i

-------
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              VOC DATA SHEET:
            PROPERTIES OF THE COATING "AS  APPLIED" TO THE SUBSTRATE
Coating Manufacturer:
Coating Identification:
Batch Identification:	
User:
User's Coating Identification:
Properties of the  coating as applied1 by the User:
   A.   Coating Density (Dc)a:  	kg/1, or  	 Ib/gal
        /  7 ASTM  D1475      f~7 Other2
   B.   Total Volatiles (Wv)a:  	Weight Percent
        /~7 AS™  D2369
     	                 r~T Other2
C.   Water Content: 1. (Ww)a	
     /7 ASTM D3792      f~7 ASTM D4017   /   J Other2
                   2- (Vw)a 	
     I  7 Calculated
                                 Other2
                                                               Weight Percent
                                                               Volume Percent
D.   Weighted Average Density of the dilution solvent (Dd)3:
     /~7  ASTM D1475     l~~l  Handbook    f~7  Formulation
                                                                       Ib/gal
   (Continued on Reverse  Side)
  iThe  subscript "a" denotes  each value is for the coating "as applied"  to  the
    substrate.
  2Explain the other method used under "Remarks" on reverse side
  JThe  subscript "d" denotes  values  are for the dilution solvent
                                     III-2

-------
     Dilution Solvent Ratio (Rj):
                                           or
       gal  diluent
       (gal  coating)
                                                  liter diluent
F.
G.
H.
Organic Volatiles Content (WQ)a:
Non-Volatiles Content (Vn)a:
VOC Content (VOC);,: 1. -
(1

Ib/gal of
Her coating) 4
Weight Percent
Volume Percent
coating less water
                           or
                         2.
                           or
kg/1 of coating less  water

Ib/gal  solids

kg/1 solids
REMARKS:
                         Signed:
               Date:
4The subscript "s" denotes values are for the coating "as supplied" by the
manufacturer.

5This terminology is used to be consistent with Method 24.  It refers to
all photochemically reactive oryanic compounds emitted from the coating
including reactive by-products of the cure reaction, exactly the same
matter as indicated in Paragraph H, i.e., volatile organic compounds,
or VOC.

                                III-3

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                                                     PAGE  REVISED JUNE 19, 1986
3.2. IMPLEMENTING  INSTRUCTIONS  FOR  THE  VOC  DATA  SHEET  FOR  "AS APPLIED" COATINGS

     This DATA SHEET,  henceforth referred to  as  the  "AS APPLIED" VOC  DATA
SHEET, is to be completed by the company which applies a coating.   It
provides information on the amount  of volatile organic compounds  (VOC) in
the coating "as applied" to the substrate by  accounting for the quantity of
diluent solvent added to the "as supplied"  coating prior to application.
If a coating is diluted only with water or  a  solvent of negligible  photo-
chemical reactivity, the user merely doucments the fact  (see Step E.I. and
also Footnote 4, Pg. III-5.).  Otherwise, several avenues  exist for the
coater to certify the VOC content:
(1) Maintain adequate records of how much  organic solvent  is  added  to each
coating and use that information and the  "AS  SUPPLIED" VOC DATA SHEET2 to
calculate the VOC content "as applied." In  this  case begin with Step  D.
(2) If the  "AS SUPPLIED" DATA SHEET is available, but  dilution  records are
not, begin  the "As Applied" determination with  Step  A, skip Steps  B and  C,
and proceed to Step D.
(The user may choose to  analyze an "As Supplied" coating  using  Reference
Method 24 and complete the  "AS SUPPLIED"  VOC  DATA SHEET  rather  than have
the coating manufacturer complete it.  The volume percent  solids,  however,
will necessarily continue to be supplied  by the  coating  manufacturer.)
 (3) Analyze each diluted coating with the same method  used to generate the
data provided by the coating manufacturer on the "AS SUPPLIED"  VOC  DATA
SHEET.   (See Chapter 2  of this Manual.) In this  case begin with Step A.1


A.  The  "as applied" coating density,  (Dc)a  , is determined using "ASTM  D1475-
    Standard Test Method for Density of Paint, Lacquer,  and Related Products."

B.  The  weight percent  of total volatiles in the coating,  (Wv)a is determined
    by  "ASTM 02369-81 Standard Method  for Volatile Content of Coatings."
    The drying conditions to be used are 110°C for 1 hour3.
 iEPA's Reference Method  24  (40 C.F.R. Part 60, App. A), contains the
 ASTM methods  referenced  in  these .instructions.

 ^The subscript  "a"  denotes  those parameters of a coating  in the
 "as applied"  condition,  i.e., after  dilution  by the user.  The subscript
 "s" denotes the parameters  of a coating  in the "as supplied"  condition,
 before dilution by  the  user.

 3If the manufacturer believes the  specified method gives  results  that
 are not representative  of the VOC  released during the normal  cure,  he
 may petition  the enforcement authority  for approval of an alternative
 analytical  method.   Any  alternate  method or alteration to the methods
 and procedures  in these  instructions or  in any applicable regulation
 would be subject  to review and  approval  by the appropriate State and/or
 Federal enforcement agency.

                                    III-4

-------
C.  The water content is necessary only if the coating has been diluted
    with a" mixture of organic solvent and water. 4, 5   if the dilution
    solvent is 100 percent organic, or if the weight and volume percent
    water in the mixture is known, proceed directly to Step D.

    The weight percent water, (Ww)a, is determined by "ASTM U3792 -
    Standard Test Method for Water Content of Water-Reducible
    Paints by Direct Injection Into a Gas Chroma tograph," or "ASTM D4017
    - Standard Test Method for Water in Paints and Paint Materials by
    the Karl Fischer Method."  (Also see Footnote 3, Pg. III-4.)

    The water content, in volume percent, (Vw)a, can be calculated by
    the equation:

                     - 'Va  'Dc'.                                    Ill-i
              where bw is the density of water, 8.33 Ib/gal.
 ^Volatile compounds"classified  by  EPA  as  having  negligible photochemical
 reactivity such  as  1,1,1-trichloroethane  and methylene chloride, etc., and
 listed as exempt in the  applicable Federal  and State VuC regulation, should
 be treated in the same manner as water.   The weight percent of  negligibly
 reactive compounds  in  the  dilution solvent  must  be known either from the
 coater's mixing  records  or the  dilution  solvent  supplier's formulation.
 The volume percent  can then be  calculated using  Equations  1II-1 or  III-5
 when the weight  percent  and density of the  negligibly  reactive  organics
 are substituted  for those  of water.  The  weight  and volume percent  of
 the negligibly reactive  compounds  can  be  substituted in  all equations
 where the weight and volume percent water,  (Ww)  and  (Vw),  respectively,
 are used.

 5The precision limit adjustments  permitted  by  Reference  Method  24  for
 experimentally determined  mean  weight percent  water  and  total  volatiles,
 kw and *v respectively,  may be  made only by enforcement  agencies  tor
 determination of compliance.  The adjustment is  not  to be  used  for the
 purposes of completing the "AS  APPLIED" VUC
                                   III-5

-------
D.  If the dilution solvent consists  of a single  compound  the density
    may be obtained from the literature.

    If the dilution solvent is a mixture of organic  compounds,  the
    density, Ddb, can be determined analytically  via Ai>TM  uK75,  or
    an average density can be estimated from the  solvent formulation
    as shown below.  This estimation  assumes that volumes  are additive,


              Q       100%
               d
                     m   W,                                           IH-2
        or

                          m
                                                                      III-3
            where: Dj, Wj, and V, denote the density, weight percent,
            and  volume percent or each solvent in the dilution solvent
            mixture and "m" is the number of organic solvents in the
            dilution  solvent mixture.

     If the  dilution solvent is a mixture of photocneuically reactive
     organics  and water, the coater must know the weight percent, (Wy/)^,
     or volume percent, (Vw)d  "df                                      IH-5
                           uw

                 where "Dw"  is  the  density  of water.
 6The subscript "d" denotes a parameter that pertains to that solvent
 used by the coater to dilute the "as supplied"  coating.
                                   III-6

-------
E.  The dilution solvent ratio, R^, is defined as the volume of
    photochemically reactive organic solvent, (VOC), added per unit
    volume of "as supplied" coating.  Stated mathematically-.

    R    =   Volume photochenrically reactive dilution solvent added
     d                   Volume of "as supplied" coating

    1.  If the "as supplied" coating is subsequently diluted with
        water or a solvent which is of negligible photochemical
        reactivity, the VOC content will be unchanged from that reported
        on the "AS SUPPLIED" VOC UATA SHEET.  This should be reported on
        the "AS APPLIED" VOC DATA SHEET by entering "0" for the dilution
        solvent ratio, R^.

    2.  In the absence of  adequate dilution records, R,j can be
        calculated from entries on the VOC UATA SHEETS by one of the
        following equations:

        a.  When the  dilution  solvent consists only of VOC,

                       s - (Oc)a                                      III-6
               a   _
               d  "
                          -  iudy
         b.   When  the dilution  solvent  is  a mixture of water and
             photochemical ly  reactive organic  solvent, Equation IiI-6
             may be expressed as:
                       where:  k^ is the ratio of the  volume  of  water
                       and organic dilution solvent to the  volume  of "as
                       supplied" coating to which it is added.   (Also  see
                       Footnote 4, Pg.  III-5.)

         The dilution solvent ratio, K
-------
F-  The organic  volatile  content  (W0)a, i.e. the YOC content expressed
    as a percent by  weight  of  the diluted coating, can now be calculated
    by either of two ways:

    1.  From analyses of  the coating using the following equation:

              (W0)a  = 
-------
                                          PAGE REVISED JUNE  19,  1986
      .  (2).  If the coating contains water the following  equation
             must be used:

          (VOC)  = (U'°)a  (°c)a                                    111-14
          V   ;a   -UU* -  (Vw)a

   b.   Using the VOC content of the "as supplied" coating, (VOCS),
        the dilution solvent ratio, and the density of the solvent,
        the equation is:
                _  L(VOC)S  (100%  -  (Vw)s)/100%] + (RdDd)          HI-15
               3 "           1  + Rd  -  (VW)S/10U%

          Where (VOC)S  in this case must be in units of
          Ibs  VOC/gal coating  .less  water.

2.   The VOC content may also be calculated in terms of mass of VOC
    per unit volume of  solids  (nonvolatiles).

    a.   Using  the  results  obtained  by analyzing the coating with EPA
        Reference  Method 24 or its  constituent ASTM  methods,
        the equation for both solvent-borne and waterborne coatings,
        is:

          (VOC)  = (W°!a (Dc)a                                    111-16


    b.   Using dilution information and calculation  procedures only,
        the equation is:

                 _ C(voc)5  (100% - (vw)5)/ioo%3 + (Rdod)          in-17
           1    a                 (vn)s/iuu%

          Where (VOC)S in this case  must be in units of
          Ibs VOC/gal  coating less water.
                                III-9

-------
                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
i. REPORT NO.
  EPA 450/3-84-019
                                                           3. RECIPIENT'S ACCESSION NO.
\. TITLE AND SUBTITLE
  Procedures for  Certifying Quantity of Volatile Organic
  Compounds Emitted  by Paint, Ink, and Other  Coatings
           5. REPORT DATE
               December  1984
           6. PERFORMING ORGANIZATION CODE
7. AUTHOH(S)
                                                           8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Office of Air Quality Planning and  Standards
  U. S. Environmental  Protection Agency  (MD-13)
  Research  Triangle Park, NC  27711
                                                            10. PROGRAM ELEMENT NO.
           11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
                                                                     EPA/200/04
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
                 This manual provides procedures by which  firms may voluntarily
            certify the quantity of volatile organic compounds which will be emitted
            by a paint, ink, or other coating.  Two data sheets are provided.  One
            is to be used by the manufacturer of the coating, the other  by  the user.
            Analytical test methods and procedures  for preparing the data sheets are
            included, as are the equations and instructions necessary  to convert the
            analytical results into a format  suitable  for determining  compliance with
            State or Federal regulations.
 17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                               D.IDENTIFIERS/OPEN ENDED TERMS
                                                                             COSATl Field/Croup
   Air Pollution
   Coatings
   Compliance Calculations
   Pollution Control
   Reference Method 24
   Test Methods
   Volatile Organic Comoounds
Air Pollution  Control
13-B
                                                19. SECURITY CLASS (This Report/
                                                  Unclassified
                                                !0. SECURITY CLASS /This pa?e;
                                                  Unclassified
                           21. NO. OF PAGES

                                 15
                           22. PRICE
 EPA Form 2220-1 (Rev. 4-77)
                        PREVIOUS EDITION IS OBSOLETE

-------
    APPENDIX C



REFERENCE METHOD
         C-l

-------
C-2

-------
Pt. 60, App. A, M«th. 24
                                        Title 40—Protection of Environment
METHOD  24—DETERMINATION  or VOLATILE
  MATTER CONTEND WATER CONTENT. DENSI-
  TY, VOLUME SOLIDS, AND WEIGHT SOLIDS or
  SURTACE COATINGS
  1.1
 1. Applicability and Principle
Applicability. This method applies to
the determination  of  volatile  matter con-
tent, water content, density, volume solids,
and weight solids of paint, varnish, lacquer,
or related surface coatings.
  1.2  Principle. Standard methods are used
to determine  the volatile matter content,
water content, density, volume solids, and
weight solids of the paint, varnish, lacquer,
or related surface coatings.

      2. Applicable Standard Methods

  Use the apparatus,  reagents, and proce-
dures specified in the  standard methods
below:
  2.1  ASTM D1475-60 (Reapproved  1980).
Standard Test Method for Density of Paint,
Varnish. Lacquer, and Related Products (in-
corporated by reference—see 5 60.17).
  2.2  ASTM   D2389-81,  Standard   Test
Method  for  Volatile Content  of Coatings
(incorporated by reference—see 8 60.17).
  2.3  ASTM   D3792-79,  Standard   Test
Method for Water Content of Water-Reduc-
ible Paints by Direct  Injection into a Gas
ChromatOKraph  (incorporated  by   refer-
ence—see { 60.17).
  2.4  ASTM   D4017-81,  Standard   Test
Method for Water in Paints and Paint Ma-
terials  by  the   Karl  Fischer Tltratlon
Method   (Incorporated  by  reference—see
J 60.17).
  3. Procedure.
  3.1  Volatile Matter Content. Use the pro-
cedure In ASTM D2369-81 (incorporated by
reference—see  f 60.17)  to  determine  the
volatile matter content (may include water)
of the coating. Record the following infor-
mation:
W,« Weight of dish and sample before heat-
    ing, g.
Wt««Weight of dish and sample after heat-
    Ing, g.
W.-Sample weight, g.
Run  analyses  in pairs (duplicate sets) for
each  coating until the criterion In  section
4.3 is met. Calculate the weight fraction of
the volatile matter (W.) for each analysis as
follows:
             w.-
                             (Eq. 34-1)
 Record the arithmetic average (W,).
  3.2  Water   Content.   For   waterborne
 (water reducible)  coatings only, determine
the weight fraction of water (w) using either
"Standard Content Method Test for Water
of Water-Reducible Paints by Direct Injec-
tion Into a Oas Chromatograph" or "Stand-
ard Test Method  for Water in Paint and
Paint Materials by Karl Fischer Method."
(These  two methods are  Incorporated by
reference—see {60.17.) A waterborne coat-
Ing Is any coating which contains more than
5 percent water by weight  In Its volatile
fraction. Run duplicate sets of determina-
tions until the criterion in section 4.3 Is met.
Record the arithmetic average (W.).
  3.3  Coating Density. Determine the den-
sity (De, kg/liter) of the surface coating
using the  procedure in  ASTM  D1475-60
(Reapproved 1980) (Incorporated by refer-
ence—see { 60.17).
  Run duplicate sets of determinations  for
each coating until the criterion in section
4.3  is met. Record the  arithmetic average
(Dc>.
  3.4  Solids   Content.   Determine   the
volume fraction (V.) solids of the coating by
calculation using the manufacturer's formu-
lation.

       4. Data, Validation Procedure

  4.1  Summary- The variety  of  coatings
that may be subject to analysis makes it
necessary to verify the ability of the analyst
and the analytical procedures to obtain re-
producible  results  for the coatings tested.
This Is done by running duplicate analyses
on  each sample tested  and  comparing  re-
sults with  the within-laboratory precision
statements for each  parameter. Because of
the inherent increased  Imprecision in the
determination of the VOC content of water-
borne coatings as the weight percent water
increases, measured  parameters for water-
borne coatings are modified by the appro-
priate confidence limits based on  between-
laboratory precision statements.
  4.2  Analytical Precision Statements. The
within-laboratory  and  between-laboratory
precision statements are given below:


Wat* content Ww 	 	
Dwwtty, De 	
Within*
1— *>--—».» — .
wuQfWDry

Z9petWw 	
0.001 kg/KMr...
0**ftn-
woofvtofy
4.7 pet W..
7.5 pet W,
0.002 kg/ttw.
                                       4.3 Sample Analysis Criteria. For W, and
                                      W., run duplicate analyses until the differ-
                                      ence between the two values in a set Is less
                                      than or equal to the within-laboratory pre-
                                      cision statement for that parameter. For D.
                                      run duplicate analyses until each value in a
                                      set deviates from the mean of the set by no
                                      more than the within-laboratory precision
                                      statement.  If after several  attempts  it  is
                                      concluded  that  the  ASTM  procedures
                                        634
                                        C-3

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Chapter I—Environmental Protection Agency
                                         Pt. 60, App. A, Math. 24A
cannot be used for the specific coating with
the established within-laboratory precision.
the Administrator will assume responsibility
for providing the necessary procedures for
revising the method or precision statements
upon written request to: Director. Emission
Standards and Engineering Division, (MD-
13)  Office of Air Quality Planning  and
Standards, U.S.  Environmental Protection
Agency.  Research  Triangle  Park,  North
Carolina 27711.
  4.4 Confidence  Limit Calculations  for
Waterbome  Coatings. Based  on  the be-
tween-laboratory precision  statements, cal-
culate the confidence limits for waterborne
coatings as follows:
  To calculate the lower confidence limit,
subtract the  appropriate between-laborato-
ry precision value from the measured mean
value for that parameter. To calculate the
upper confidence limit, add the appropirate
between-laboratory precision value to the
measured mean value for that parameter.
For W, and  Dc, use the lower confidence
limits, and for Ww, use the upper confidence
limit. Because V. is calculated, there is no
adjustment for the parameter.

              5. Calculations
  5.1 Nonaqueous Volatile Matter.
  5.1.1   Solvent-borne Coatings.
W.=W.
Eq. 24-2
Where:
W0=Weight  fraction nonaqueous volatile
    matter, g/g.
  5.1.2  Waterborne Coatings.

We=W.-W.         Eq. 24-3

  5.2  Weight fraction solids.

W.=1-W,         Eq. 24-4

Where: W.=Weight solids, g/g.

METHOD  24A—DETERMINATION  OF VOLATILE
  MATTER CONTENT AJTD  DENSITY OF PRINT-
  ING INKS AND RELATED COATINGS

  1. Applicability and Principle.
  1.1  Applicability. This method applies to
the determination of the  volatile organic
compound  (VOC)  content  and  density of
solvent'bome  (solvent  reducible)  printing
inks or related coatings.
  1.2  Principle.  Separate  procedures  are
used to determine the VOC weight fraction
and density of the coating  and the density
of the  solvent in the  coating. The  VOC
weight fraction is determined by measuring
the weight  loss of a known  sample quantity
which  has  been  heated  for  a specified
length of time at  a  specified  temperature.
The density of both the  coating and solvent
are measured by a standard  procedure.
Prom this information,  the VOC  volume
fraction is calculated.
  2. Procedure.
  2.1  Weight Fraction VOC.
  2.1.1 Apparatus.
  2.1.1.1  Weighing Dishes. Aluminum foil.
58 mm in diameter by 18 mm high, with a
flat bottom.  There must be at least  three
weighing dishes per sample.
  2.1.1.2  Disposable syringe. 5 ml.
  2.1.1.3  Analytical Balance. To measure to
within 0.1 mg.
  2.1.1.4  Oven.  Vacuum  oven capable of
maintaining a temperature of 120±2'C and
an absolute pressure of 510 ±51 mm Hg for
4 hours.  Alternatively, a farced draft oven
capable of maintaining a temperature of 120
±2°C for 24 hours.
  2.1.1.5  Analysis. Shake or mix the sample
thoroughly to assure that all the solids are
completely suspended. Label and weigh to
the nearest  0.1 mg a weighing  dish and
record this weight (M*).
  Using a 5-ml  syringe  without a needle
remove a sample of the coating. Weigh the
syringe and sample to the nearest 0.1 mg
and record this weight (M.T,). Transfer 1 to
3 g of the  sample to the tared weighing
dish. Reweigh the syringe and sample to the
nearest 0.1 mg and record this weight (!£,»).
Heat  the weighing dish and  sample  in a
vacuum oven at  an absolute pressure of 510
±51 mm Hg and a temperature of 120 ±2'C
for 4 hours. Alternatively, heat the weigh-
ing dish and sample in a forced  draft oven
at a temperature of 120 ±2'C for 24 hours.
After the weighing dish has cooled, reweigh
it to  the nearest 0.1  mg and record  the
weight (Mil). Repeat  this  procedure  for a
total  of  three   determinations  for  each
sample.
  2.2  Coating Density. Determine the den-
sity of the ink or related coating according
to the procedure outlined in ASTM D 1475-
60 (Reapproved 1980), which is incorporated
by reference. It is available from the Ameri-
can Society  of Testing and Materials, 1916
Race  Street, Philadelphia,  Pennsylvania
19103. It is also available for inspection at
the Office of the Federal Register, Room
8401. 1100 L Street, NW.. Washington, D.C.
This  incorporation by  reference was ap-
proved by the Director of the Federal Regis-
ter on November 8, 1982. This material is in-
corporated as it exists on the date of ap-
proval and a notice of any change in these
materials  will be published in the  FEDERAL
REGISTER.
  2.3  Solvent Density. Determine the den-
sity of the solvent  according to the proce-
dure  outlined in ASTM  D 1475-60  (reap-
proved 1980). Make a total of three determi-
nations for each coating. Report the density
D0 as the arithmetic average of the three
determinations.
  3. Calculations.
                                        635
                                      C-4

-------
Pt. 60, App. A, Meth. 25                    Title 40—Protection of Environment
                      *
  3.1  Weight Fraction VOC. Calculate the
weight fraction volatile organic content W.
using the following equation:
      W.=
                   M.y,-McY,
                              (Eq.24A-l>
  Report the weight fraction VOC W0 as the
arithmetic average of the three determina-
tions.
  3.2  Volume Fraction VOC.  Calculate the
volume fraction volatile organic content V,
using the following equation:
 ... _

                             Eq.24A-l
  v   W0DC
                          Eq. 24A-2
  4. Bibliography.
  4.1  Standard Test Method for Density of
Paint. Varnish, Lacquer, and Related Prod-
ucts.  ASTM Designation D 1475-60 (Heap-
proved 1980).
  4.2  Teleconversation.  Wright,   Chuck,
Inmont  Corporation  with Reich,  R. A..
Radian Corporation.  September  25,  1979.
Oravure Ink Analysis.
  4.3  Teleconversation.     Oppenhelmer,
Robert. Oravure Research Institute  with
Burt. Rick. Radian Corporation, November
5,1979. Gravure Ink Analysis.
                                       636
                                     C-5

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TECHNICAL REPORT DATA .
(Please read Inurucnons CT the reverie before complennrl
1 REPORT NO. 2.
EPA 340/1-86-016
4 TITLE AND SUBTITLE
A Guideline for Surface Coating Calculations
7 AUTMOR(S)
PEI Associates, Inc.
9 PERFORMING ORGANIZATION NAME AND ADDRESS
PEI Associates, Inc.
1006 North Bowen Road
Suite 201
Arlington, Texas 76012
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Stationary Source Compliance Division
401 M Street, S.W.
Washington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
February 1985
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3963
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSOHING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The calr.ulatinn nf vnlatilp nraanir rnmnnunrl pmi<;<;inn<; frnm <;urfarp rnat-
ing operations to determine compliance is often a complicated task, sometimes
creating confusion with compliance authorities and sources alike.  In an attempt
                                            periodically issued guidance in this
                                            the EPA Regional Offices.  The most
                                            Certifying Quantity of Volatile
                                            Other Coatings," published December
           confusion with
  to minimize this confusion,  EPA (OAQPS)  has
  area, generally in the form of memoranda to
  recent document is entitled "Procedures  for
  Organic Compounds Emitted by Paint,  Ink  and
  1984, EPA 450/3-84-019.
       "A Guideline for Surface Coating Calculations" takes the above guidance
  process one step further for surface coating operations.  Guidance is provided
  on how to compute existing and allowed emissions based on the above document as
  well as previously issued Control Technique Guidelines for the individual cate-
  gories.  Example calculations are included for basic emission problems, com-
  pliance determinations,  equivalency determinations, application of transfer
  efficiency, and calculations involving complex multiproduct plants.  The approp-
  riate data sheets, a list of various equations and notations, and graphs and
  tables useful in making the above calculations are also included.
17.
                              KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                            b.IDENTIFIERS/OPEN ENDED TERMS
                                                                       COSATi I-itId/Cioup
  Air Pollution
  Surface Coating
  VOC Data Sheets
  Calculations
  Compliance Determination
  Control Strategy Evaluation
                                           Air Pollution Control
                                           Organic Chemicals
                                           Coating Operations
  Release Unlimited
                                             19 SICuHl T » CL AiS 
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