EPA-450/3-77-020
June 1977
         STUDY TO SUPPORT
                  MvW >4>»  RC
 PERFORMANCE STANDARDS
            FOR AUTOMOBILE
             AND LIGHT-DUTY
              TRUCK COATING

   U.S ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Waste Management
    Office of Air Quality Planning and Standards
   Research Triangle Park, North Carolina 277 U

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                                EPA-450/3-77-020
STUDY TO SUPPORT NEW SOURCE
 PERFORMANCE STANDARDS FOR
  AUTOMOBILE AND LIGHT-DUTY
           TRUCK COATING

                DRAFT
                     by

               Springborn Laboratories, Inc.
                Enfield, Connecticut 06082
                 Contract No. 68-02-2062
             EPA Project Officer: James A. McCarthy
                   Prepared for

           ENVIRONMENTAL PROTECTION AGENCY
             Office of Air and Waste Management
           Office of Air Quality Planning and Standards
           Research Triangle Park, North Carolina 27711

                   June 1977

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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers.  Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35), Research Triangle Park, North Carolina
27711;  or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Springborn Laboratories, Inc.  Enfield, Connecticut, in fulfillment
of Contract No. 68-02-2062.  The contents, of this report are reproduced
herein as received from Springborji Labqiajories,  Inc. The opinions,
findings, and conclusions expressed are' those of the author and not
necessarily those of the Environmental Protection Agency.  Mention of
company or product names is not to be considered  as.,an endorsement
by the Environmental Protection Agency
                    Publication No. EPA-450/3-77-020
                                ii

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                            CONTENTS


                                                               Page

3.  THE AUTOMOTIVE AND LIGHT-DUTY TRUCK INDUSTRY	3-1

3.1.       GENERAL DESCRIPTION		3-1

3.1.1.     Automotive Industry 	  3-1

3.1.2.     Truck Industry  	  3-8

3.2.       PROCESSES OR FACILITIES AND THEIR EMISSIONS ....  3-13

3.2.1.     The Basic Process - Automotive Industry	3-13

3.2.2.     The Basic Process - Light-Duty Truck Industry .  .  .  3-25

3.3.       REFERENCES	3.37


4.  EMISSION CONTROL TECHNIQUES   	  4-1

4.1.       THE ALTERNATIVE EMISSION CONTROL TECHNIQUES ....  4-2

4.1.1.     Water-Borne Coatings   	  4-2

4.1.2.     Electrodeposition 	   4-2

4.1.3.     Water-Borne Spray 	   4-8

4.1.4.     Powder Coating	4-10

4.1.5.     Higher Solids Coatings 	   4-17

4.1.6.     Carbon Adsorption 	   4-20

4.1.7.     Incineration  	   4-28

4.2.       EMISSION REDUCTION PERFORMANCE OF
           CONTROL  TECHNIQUES   	   4-38

4.2.1.     Electrodeposition of  Water-Bornes .........   4-38

4.2.2.     Water-Borne Spray 	   4-39

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CONTENTS (Continued - 2)                                         Page









4.2.3.     Powder Coating - Electrostatic Spray	   4-42




4.2.4.     Higher Solids Coatings 	   4-42




4.2.5.     Carbon Adsorption	   4-43




4.2.6.     Incineration	   4-43




4.3.       REFERENCES	   4-46







5.  MODIFICATION AND RECONSTRUCTION	   5-1




5.1.       POTENTIAL MODIFICATIONS	   5-2




5.2.       RECONSTRUCTION	   5-5




5.3.       CONSTRAINTS	   5-6




5.4.       OTHER CONSIDERATIONS  	   5-7




5.5.       REFERENCES	   5-8







6.  EMISSION CONTROL SYSTEMS	   6-1




6.1.       ALTERNATIVE  I-P	   6-4




6.2.       ALTERNATIVE  II-P   	   6-4




6.3.       ALTERNATIVE  III-P	   6-5




6.4.       ALTERNATIVE  IV-P	   6-5




6.5.       ALTERNATIVE  I-T	   6-5




6.6.       ALTERNATIVE  II-T	   6-6




6.7.       ALTERNATIVE  III-T	   6-6




6.8.       ALTERNATIVE  II-T  Plus III-T	   6-6




6.9.       ALTERNATIVE  IV-T	   6-6




 6.10.      REFERENCES	    6-20

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CONTENTS (Continued - 3)                                        Page



7.  ENVIRONMENTAL IMPACT	7-1

7.1.      AIR POLLUTION IMPACT	7-1

7.1.1.    State Regulations and Controlled Emissions 	   7-2

7.1.2.    Uncontrolled and Controlled Emissions (Alternatives)   7-3

7.1.3.    Estimated Hydrocarbon Emission
          Reduction in Future Years  	   7-13

7.2.      WATER POLLUTION IMPACTS	7-31

7.3.      SOLID WASTE DISPOSAL IMPACT  	   7-33

7.4.      ENERGY IMPACT	7-35

7.5.      OTHER ENVIRONMENTAL IMPACTS	7-44

7.6.      OTHER ENVIRONMENTAL CONCERNS	7-44

7.6.1.    Irreversible and Irretrievable
          Commitment of Resources	7-44

7.6.2.    Environmental Impact of  Delayed Standards  	   7-44

7.6.3.    Environmental Impact of  No Standards  	   7-45

7.7.      REFERENCES	7-46


8.  ECONOMIC IMPACT

8.1.      INDUSTRY ECONOMIC  PROFILE   	  8-1

8.1.1.    Industry Size	8-1

8.1.2.    Industry Structure 	  8-8

8.1.3.    Marketing   	  8-13

8.1.4.    Financial  Performance   	  8-21

8.1.5.    Capital Structure   	  8-28

8.1.6.    Production	8-31

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CONTENTS (Continued - 4)                                         Page

8.1.7.    References for  Section 8.1  .............   8-32
8.2.      COST ANALYSIS OF ALTERNATIVE  EMISSION
          CONTROL SYSTEMS  ..................   8-33
          Identification  Key for Coding Emission Systems .  .  .   8-36
8.2.1.    Cost Effectiveness Summarized  ...........   8-37
8.2.2.    Water Pollution and Solid Waste Disposal ......   8-39
8.2.3.    New Facilities  ...................   8-39
8.2.4.    Reconstructed Facilities ..............   8-49
8.3.      OTHER COST CONSIDERATIONS   (To be prepared by EPA)

8-4-      sss
8-5-
9.  RATIONALE FOR THE PROPOSED STANDARDS ...........  9-1

9.1.      SELECTION OF SOURCE FOR CONTROL  ..........  9-1

9.2.      SELECTION OF POLLUTANTS AND AFFECTED FACILITIES  . .  9-4

9.3.      SELECTION OF THE BEST SYSTEM OF EMISSION
          REDUCTION CONSIDERING COSTS    (To be prepared by EPA)

9.4.      SELECTION OF THE FORMAT OF THE PROPOSED STANDARD . .  9-14

9.4.1.    Concentration - Airborne Emissions .........  9-14

9.4.2.    Mass/Time - Airborne Emissions ...........  9-16

9.4.3.    Equipment Standard - Airborne Emissions  ......  9-16

9.4.4.    Mass of Emissions/Unit of Coating Material Consumed   9-16

9.5.      SELECTION OF EMISSION LIMITS   (To be prepared by EPA)

9.6.      VISIBLE EMISSION STANDARDS  (To be prepared by EPA)

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CONTENTS  (Continued - 5)                                        Page



9.7.      MODIFICATION/RECONSTRUCTION CONSIDERATIONS 	  9-19

9.7.1.    Raw Material Substitutes  	  9-19

9.7.2.    Reconstruction Compliance Measure   	  9-20

9.8.      SELECTION OF MONITORING REQUIREMENTS  (To be
          prepared by EPA)

9.9.      SELECTION OF PERFORMANCE  TEST METHODS  (To be
          prepared by EPA)


APPENDIX  A  -  EVOLUTION OF PROPOSED STANDARDS                  A-l - A-6

APPENDIX  B  -  INDEX TO ENVIRONMENTAL  IMPACT  CONSIDERATIONS     B-l - B-3

APPENDIX  C  -  EMISSION SOURCE TEST DATA   (To be prepared
               by EPA)

APPENDIX  D  -  EMISSION MEASUREMENT AND CONTINUOUS MONITORING
                (To be prepared by EPA)

APPENDIX  E  -  ENFORCEMENT ASPECTS   (To be prepared by EPA)
Listing of Tables and Figures follows.

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                    LIST OF  TABLES AND FIGURES



TABLES                                                              Page


3-1.        Direct Employment  in the  Production of Automobiles       3-2

3-2.        Share of Total U.S. Production                           3-2

3-3.        Automobile Assembly Plant Production - Model Year 1975   3-3

3-4.        Automobile Assembly Plants - Model Year 1975             3-5

3-5.        Automotive Sales by Car Size                              3-7

3-6.        1975 U.S. Truck and Bus Factory Sales by Body Types      3-9
            and Gross Vehicle  Weight, Pounds

3-7.        Light-Duty Truck Assembly Plants,  Model Year 1975        3-10

3-8.        Light-Duty Truck Assembly Plant Locations,  Model         3-11
            Year 1975

3-9.        Estimated Light-Duty Truck Production                    3-12

3-10.       Material Balance - Automobile  Primer                     3-18

3-11.       Primer - Engergy Balance, Base Case - Automobiles        3-17

3-12.       Material Balance - Automobile  Topcoat                    3-20

3-13.       Topcoat - Energy Balance, Base Case - Automobiles        3-20

3-14.       Average Emissions  for  the Automobile Finishing Process   3-23

3-15.       Estimated Solid Waste  Generated for Base-Case            3-23
            Automotive Finishing Application Process

3-16.       Material Balance - Primer, Light-Duty Truck Bodies       3-30

3-17.       Energy Balance - Primer,  Base  Case - Light-Duty Trucks   3-31

3-18.       Material Balance - Topcoat, Light-Duty Truck Bodies      3-31

3-19.       Energy Balance - Topcoat, Base Case - Light-Duty Trucks  3-32

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LIST OF TABLES AND FIGURES  (Continued - 2)
TABLES
                                                                     Page
3-20.       Average Emissions for the Light-Duty Truck               3-34
            Finishing Process

3-21.       Estimated Solid Waste Generated for Base-Case            3-35
            Light-Duty Truck Finishing  Process
4-1.         Water-Borne Coatings                                     4~3

4-2.         Problem Solvents for Carbon Adsorption                   4~23

4-3.         Theoretical Emission Reduction Potential Associated      4-20
             with Various New Coating Materials for Use as Auto-
             motive Body Paints

4-4.         Reduction of Organic Solvent Emissions
 6-1.        Automobile Coating Lines - Emission Control Systems      6-2

 6-2.        Light-Duty Truck Coating Lines - Emission                6-3
             Control Systems

 6-3.        Alternative Cases - Automobile Bodies, Prime Coating     6-16

 6-4.        Alternative Cases - Automobile Bodies, Topcoating        6-17

 6-5.        Alternative Cases - Light-Duty Truck  Bodies,             6-18
             Prime  Coating

 6-6.        Alternative Cases - Light-Duty Truck  Bodies, Topcoating  7-19
  7-1.         Automobile Body Painting Operation - Primer Coat,         7-5
              Hydrocarbon Emission Factors and Control Efficiency

  7-2.         Automobile Body Painting Operation - Topcoat,            7-7
              Hydrocarbon Emission Factors and Control Efficiency

  7_3.         Light-Duty Painting Operation - Primer Coat,             7-11
              Hydrocarbon Emission Factors and Control Efficiency

  7_4>         Light-Duty Truck Painting Operation - Topcoat,           7-12
              Hydrocarbon Emission Factors and Control Efficiency

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LIST OF TABLES AND FIGURES (Continued - 3)
TABLES                                                               Page

7-5.        Hypothetical Emissions from Uncontrolled Automobile      7-14
            Body Painting Operations,  1976-1985

7-6.        Automobile Body Painting Operation, Estimated            7-16
            Emissions from Water-Borne Primer - 1976-1985

7-7.        Automobile Body Painting Operation, Estimated            7-17
            Emissions from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Solvent-Borne Topcoat

7-8.        Automobile Body Painting Operation, Estimated            7-18
            Emission from Topcoat with Incinerator on Oven

7-9.        Automobile Body Painting Operation, Estimated            7-19
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Organic Solvent-Borne Topcoat

7-10.       Automobile Body Painting Operation, Estimated            7-20
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Water-Borne Topcoat

7-11.       Automobile Body Painting Operation, Estimated            7-21
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat) /Powder Topcoat

7-12.       Hypothetical Emissions from Uncontrolled Light-Duty      7-23
            Truck Painting Operations

7-13.       Light-Duty Truck Body Painting Operation, Estimated      7-24
            Emission from Combined Water-Borne Primer (With
            Solvent-Borne Guide Coat)/Uncontrolled Topcoat

7-14.       Light-Duty Truck Painting  Operation, Estimated           7-25
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Solvent-Borne Topcoat

7-15.       Light-Duty Truck Painting  Operation, Estimated           7-26
            Emission from Topcoat with Incinerator on Oven

7-16.       Light-Duty Truck Painting  Operation, Estimated           7-27
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Water-Borne Topcoat

7-17.       Light-Duty Truck Painting Operation, Estimated           7-28
            Emission from Combined Water-Borne Primer (With
            Water-Borne Guide Coat)/Powder Topcoat

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LIST OF TABLES AND FIGURES  (Continued - 4)
TABLES                                                               Page
7-18.       Light-Duty Truck Painting Operation, Estimated           7-29
            Emission from Combined Water-Borne Primer  (With
            Water-Borne Guide Coat)/Organic Solvent-Borne Top-
            coat with Incinerator on Topcoat Spray Booth(s) and
            Oven(s)

7-19.       Energy Balance - Base Case Model and Process             7-36
            Modification - Passenger Car, Prime Coat

7-20.       Energy Balance - Add-On Emission Control Systems -       7-37
            Passenger Car, Prime Coat

7-21.       Energy Balance - Base Case Model and Process             7-38
            Modification - Passenger Car, Topcoat

7-22.       Energy Balance - Add-On Emission Control Systems -       7-39
            Passenger Car, Topcoat

7-23.       Energy Balance - Base Case Model and Optional            7-40
            Pollution Reduction Coatings -  Light-Duty  Truck,
            Prime Coat

7-24.       Energy Balance - Add-On Emission Control Systems -       7-41
            Light-Duty  Truck,  Prime Coat

7-25.       Energy Balance - Base Case Model and Optional            7-42
            Pollution Reduction Coatings -  Light-Duty  Truck,
            Topcoat

7-26.       Energy Balance - Add-On  Emission Control Systems -       7-43
            Light-Duty  Truck,  Topcoat
 8.1-1.       Direct Employment in the Production of Automobiles       8-3

 8.1-2.       Automotive-Related Employment in Support Industries      8-3

 8.1-3.       Motor Vehicle and Equipment Manufacturing Employment     8-4

 8.1-4.       Employment Data for Motor Vehicle and Car Bodies         8-5
             Industry (SIC 3711)

 8.1-5.       1975 U.S. Truck and Bus Factory Sales by Body Types      8-6
             and GVW Pounds

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LIST OF TABLES AND FIGURES (Continued - 5)


TABLES                                                               Page

8.1-6.      General Statistics on Motor Vehicles and Car Bodies      8-7
            Industry (SIC 3711)

8.1-7.      Market Share of U.S.  Automobile Registrations for        8-11
            Medium- and High-Priced Lines Vs. Total Market

8.1-8.      U. S. Truck Production Trends                            8-12

8.1-9.      Price Indexes for Consumer Goods, 1960 and 1974          8-18

8.1-10.     User-Operated Transportation Costs, 1973                 8-19

8.1-11.     Revenue and Earnings  Before Taxes by Line of             8-24
            Business for Checker  Motors Corporation, 1971-1975

8.1-12.     Annual Profits After  Taxes (Loss) by Company             8-25

8.1-13.     Profit After Taxes as a Percent of Equity, Assets,       8-26
            and Sales by Company

8.1-14.     Income Statements for Motor Vehicle Manufacturers -      8-27
            1974 and 1975
8.2-1.      Alternative Cases - New Facilities, Passenger Car         8-41
            Bodies,  Prime Coating - Part I

8.2-!-2.      Alternative Cases - New Facilities, Passenger Car         8-42
            Bodies,  Prime Coating - Part II

8.2-3.      Alternative Cases - New Facilities, Passenger Car         8-43
            Bodies,  Topcoating - Part I

8.2-4.      Alternative Cases - New Facilities, Passenger Car         8-44
            Bodies,  Topcoating - Part II

8.2-5.      Alternative Cases - New Facilities, Light-Duty Truck     8-45
            Bodies,  Prime Coating - Part I

8.2-6.      Alternative Cases - New Facilities, Light-Duty Truck     8-46
            Bodies,  Prime Coating - Part II

8.2-7.      Alternative Cases - New Facilities, Light-Duty Truck     8-47
            Bodies,  Topcoating - Part I

8.2-8.      Alternative Cases - New Facilities, Light-Duty Truck     8-48
            Bodies,  Topcoating  -  Part II

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LIST OF TABLES AND FIGURES  (Continued - 6)
TABLES
                                                         Paqe
8.2-9.      Alternative Cases - Reconstructed Facilities,
            Passenger Car Bodies, Prime Coating - Part I

8.2-10.     Alternative Cases - Reconstructed Facilities,
            Passenger Car Bodies, Prime Coating  -  Part II

8.2-11.     Alternative Cases - Reconstructed Facilities,
            Passenger Car Bodies, Topcoating  -  Part I

8.2-12.     Alternative Cases - Reconstructed Facilities,
            Passenger Car Bodies, Topcoating  -  Part II

8.2-13.     Alternative Cases - Reconstructed Facilities,
            Light-Duty Truck Bodies, Prime Coating  -  Part I

8.2-14.     Alternative Cases - Reconstructed Facilities,
            Light-Duty Truck Bodies, Prime Coating - Part II

8.2-15.     Alternative Cases - Reconstructed Facilities,
            Light-Duty Truck Bodies, Topcoating  -  Part I

8.2-16.     Alternative Cases - Reconstructed Facilities,
            Light-Duty Truck Bodies, Topcoating  -  Part II
                                                         8-50
                                                         8-51
                                                         8-52
                                                         8-52
                                                         8-54
                                                         8-55
                                                         8-56
                                                         8-57
FIGURES
3-1.

3-2.


3-3.


3-4.


3-5.
Automobile Production Trends                             3-6

Traditional Coating Operations of an Automobile          3-14
Assembly Line

Flow Diagram - Application of Solvent-Borne Primer       3-16
and Topcoat, Automobile Bodies

Traditional Coating Operations of a Light-Duty Truck     3-26
Assembly Line

Flow Diagram - Application of Solvent-Borne Primer       3-28
and Topcoat, Light-Duty Truck Bodies

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LIST OF TABLES AND FIGOBES (Continued - 7)
FIGURES
                                                                     Page
4-1.        Typical Electrodeposition System Diagram                 4-4

4-2.        Schematic of Electrostatic Powder Spray Process          4-12

4-3.        Sophisticated Recovery System                            4-14

4-4.        Diagram of an Activated-Carbon Adsorber System           4-21

4-5.        Effluent Concentration Curve of Butane Vapor  from       4-25
            an Activated Carbon Bed as Function of Time

4-6.        Forced-Draft System Eliminating Solvent Vapors           4-29
            from Surface Coating  Process

4-7.        Coupled Effects of Temperature and Time on Rate of      4-32
            Pollutant Oxidation

4-8.        Schematic Diagram of  Catalytic Afterburner Using        4-36
            Torch-Type Preheat Burner with Flow of Preheat
            Waste  Stream Through  Fan to Promote Mixing

4-9.        Effect of Temperature on Oxidative Conversion of        4-37
            Organic Vapors  in a Catalytic Incinerator

4-10        Emission Reduction Potential  (Percent) with Use of      4-44
            Higher Solids Coatings in Place of 16 Volume  Per-
            cent lacquers  (50 Percent Deposition Efficiency)

4-11.       Emission Reduction Potential  (Percent) With Use of      4-45
            Higher Solids Coatings in Place of 28 Volume  Percent
            Lacquers  (50 Percent  Deposition Efficiency)
 6-1.         Flow Diagram - Alternative  I-P,  Application of           6-7
             Electrodeposition (EDP)  Prime Coat

 6-2.         Flow Diagram - Alternative  II-P, Application of          6-8
             Electrodeposition (EDP)  Prime Coat with Solvent-
             Borne Guide  Coat (Surfacer)

 6-3.         Flow Diagram - Alternative  III-P, Application of         6-9
             Electrodeposition (EDP), Prime Coat with Water-
             Borne Guide  Coat (Surfacer)

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LIST OF TABLES AND FIGURES  (Continued - 8)
FIGURES                                                              Page
6-4.        Flow Diagram - Alternative IV-P, Application of          6-10
            Solvent-Borne Primer Coat, Base Case with Inciner-
            ator on Primer Oven

6-5.        Flow Diagram - Alternative I-T, Application of           6-11
            Water-Borne Topcoat

6-6.        Flow Diagram - Alternative II-T, Application of          6-12
            Solvent-Borne Topcoat, Base Case with Carbon Adsorber
            on Topcoat Oven

6-7.        Flow Diagram - Alternative III-T, Application of         6-13
            Solvent-Borne Topcoat, Base Case with Incinerator on
            Spray Booth

6-8.        Flow Diagram - Alternative IV-T, Application of          6-14
            Electrostatic Spray Powder Coating
7-1.        Daily Emissions of  Coating  Systems Vs. Daily             7-9
            Production of Automobiles

7-2.        Automobiles, Emission  Control Alternatives               7-22

7-3.        Light-Duty Trucks,  Long-Range Emission Prediction        7-30



8.1-1.      Share of Domestic Auto Production, by Company            8-9

8.1-2.      Share of New Car Registrations  in the United States      8-10

8.1-3.      Share of Auto Sales by Size of  Domestic  Cars             8-20

8.1-4.      Company Profits as  a Percent of Earnings Versus          8-23
            Share of New Car Registrations,  1967-1974

8.1-5.      Capital Structure of the Auto Industry  (Ten-Year         8-29
            Average)

8.1-6.      Volatility of Total Profits of  GM, Ford, Chrysler,       8-30
            and AMC For  All Products

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LIST OF TABLES AND FIGURES (Continued - 9)
FIGURES                                                              Page'
9.1-1.      Concentration of Assembly Lines for Automobiles           9-3
            and Light-Duty Trucks in Zoned Areas of the U.S.

9.2-1.      Comparison of Energy Requirements for Percent             9-6
            Reduction of Organic Emissions in a Model Plant -
            Prime Coating Operation, Automobiles

9.2-2.      Comparison of Energy Requirements for Percent             9-7
            Reduction of Organic Emissions in a Model Plant -
            Prime Coating Operation, Light-Duty Trucks

9.2-3.      Comparison of Energy Requirements for Percent             9-8
            Reduction of Organic Emissions in a Model Plant -
            Topcoating Operation,  Automobiles

9.2-4.      Comparison of Energy Requirements for Percent             9-9
            Reduction of Organic Emissions in a Model Plant -
            Topcoating Operation, Light-Duty Trucks

9.2-5.      Comparison of Cost Effectiveness for Organic              9-10
            Emission Reduction Systems in a Model Plant -
            Prime Coating Operation, Automobiles

9.2-6.      Comparison of Cost Effectiveness for Organic              9-11
            Emission Reduction Systems in a Model Plant -
            Primp Coating Operation, Light-Duty Trucks

9.2-7.      Comparison of Cost Effectiveness for Organic              9-12
            Emission Reduction Systems in a Model Plant -
            Topcoating Operation, Automobiles

9.2-8.      Comparison of Cost Effectiveness for Organic              9-13
            Emission Reduction Systems in a Model Plant -
            Topcoating Operation, Light-Duty Trucks

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               3.  THE AUTOMOTIVE AND LIGHT-DUTY TRUCK INDUSTRY

3.1.  GENERAL DESCRIPTION
3.1.1.  Automotive Industry
     The automotive industry is the largest manufacturing industry in the
United States.  Motor vehicle and allied industries account for one-sixth  of
the Gross National Product.
     In 1975 the four major automotive manufacturing companies  -  General
Motors Corporation, Ford Motor Company, Chrysler Corporation, and American
Motor Corporation  -  had a combined sales of $73.7 billion, 8.5 percent of
the total sales of the five hundred largest United States corporations.
     Any significant change in the automotive industry affects the entire
United States economy.  According to the U. S. Department of Commerce, for
                                       *
every ten workers producing automobiles  , trucks, and parts, fifteen addi-
tional people are employed in industries that provide the materials and
manufactured components for these industries.
     Employment figures for the automotive industry are given in Table 3-1 .
     Among the four automotive manufacturers, General Motors accounts for the
largest portion, 57.1 percent, of the total market.  Table  3-2 shows domestic
production by manufacturer.
                                                                  2
     The automotive assembly plants are  located in eighteen states  and forty-
two cities, as shown in Table 3-3.  Over 33 percent of all  automobiles are
manufactured in Michigan, and the remaining are produced in the other states.
*
  The  terms  automobile,  passenger car,  and car are
  used interchangeably throughout this  report.
                                     3-1

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                 Table 3-1.  DIRECT EMPLOYMENT IN THE

                      PRODUCTION OF AUTOMOBILES
1967
1971
1972
1973
1974
1975
1976 (Est.)
341,000
382,000
412,000
450,000
350,000
380,000
390,000
              Table 3-2.  SHARE OF TOTAL U. S. PRODUCTION
Make
American Motors
Chrysler Corp.
Ford Motor Co.
General Motors
Miscellaneous
6-Month Total
12-Month Total
New Car Registration
by Make in U.S.
1967
237,785
1,341,392
1,851,440
4,139,037
787,767
1972
301,973
1,466,141
2,549,296
4,635,656
5,326
8,357,421 8,958,392
6-Month U. S. Car
Production
1/2-6/26
1976
122,688
651,196.
1,159,375
2,572,551
2,740
4,508,550
8,600,000
Per-
cent
2.7
14.4
25.7
57.1
0.1
100.0
Estimated
Production
1977
270,000
1,440,000
2,570,000
5,710,000
100,000
10,090,000
1975 Total U.S. Production = 6,725,682
1974 Total U.S. Production = 7,309,763
1973 Total U.S. Production = 9,667,118
Sources:  Auto News.  1975 Almanac Issue (April 23, 1975)
          Auto News.  June 28, 1976.  Chart, page 39
          See Reference 3 of this report.
                                 3-2

-------
Table 3-3.  AUTOMOBILE ASSEMBLY PLANT PRODUCTION
                Model Year 1975
Location
CALIFORNIA
Fremont
Los Angeles
San Jose
South Gate
Van Nuys
DELAWARE
Newark
Wilmington
FLORIDA
Sebring
GEORGIA
Atlanta
Doraville
Lakewood
ILLINOIS
Belvidere
Chicago
KANSAS
Fairfax
KENTUCKY
Louisville
MARYLAND
Baltimore
MASSACHUSETTS
Framingham
MICHIGAN
Dearborn
Detroit
Flint
Hamtramck
Kalamazoo
Units
443,238
98,139
58,379
60,371
112,725
113,624
232,087
94,955
137,132
1,193
1,193
359,100
121,494
173,864
63,742
299,715
162,852
136,863
148,898
148,898
85,991
85,991
214,465
214,465
61,545
61,545
2,178,497
164,594
477,676
278,532
288,251
3,171
Per-
cent
6.8
1.5
0.9
0.9
1.7
1.7
3.5
1.4
2.1
—
-
5.5
1.9
2.7
1.0
4.6
2.5
2.1
2.3
2.3
1.3
1.3
3.3
3.3
0.9
0.9
33.2
2.5
7.3
4.2
4.4
—
Location
Units
MICHIGAN (Continued)
Lansing
Pontiac
Wayne
Willow Run
Wixom
MINNESOTA
Twin Cities
MISSOURI
Kansas City
Leeds
St. Louis
NEW JERSEY
Linden
Mahwah
Metuchen
NEW YORK
Tarrytown
OHIO
Avon Lake
Lorain
Lords town
Norwood
TEXAS
Arlington
WISCONSIN
Janesville
Kenosha

U. S. TOTAL


300,706
158,478
218,613
164,887
126,298
83,192
83,192
637,918
161,078
91,981
384,859
424,437
101,114
187,972
135,351
107,795
107,795
680,555
17,431
188,292
244,994
229,838
195,793
195,793
404,019
159,078
244,941

6,561,610


Per-
cent

4.6
2.4
3.3
2.5
1.9
1.3
1.3
9.7
2.5
1.4
5.9
6.5
1.5
2.9
2.1
1.6
1.6
10.2
0.3
2.9
3.7
3.5
3.0
3.0
6.2
2.4
3.7

100.0


                   3-3

-------
     Table 3-4 summarizes the automobile assembly plants by manufacturer,
location, and make of automobile.
     The operating hours for automobile assembly plants average approximately
4000 hours of production per year  at production rates averaging over 45 vehi-
cles per hour for mid-size to full-size passenger cars.
     In 1973, production of automobiles was 9.7 million, a 10 percent in-
crease over 1972.  Since 1973, production of cars has decreased considerably
to 7.3 million in 1974 and 6.7 million in 1975.  Figure 3-1 shows the esti-
mated production trends for passenger cars.  The major factor which brought
about the decline in production was the serious shortages of gasoline and
diesel fuel developed at the end of 1973.  Consequently the consumers began
seeking small economical models, which were not yet available in the domestic
market.  Many American assembly plants producing large cars were converted to
production of compact and sub-compact models.  As a result, plants had to
close down, production fell sharply, and at one time there were nearly 150,000
auto workers out of work.
     In  1976, however, production showed an upward trend, reaching the level
of 8.6 million cars.  There are several factors to which the increase in de-
mand may be attributed.  One factor is the economic recovery during 1976,
which allowed higher automotive sales.  Also, there was a wide availability in
sizes such as sub-compacts, compacts, intermediate, and full-size automobiles.
Demand for domestic new cars is expected to be nearly  constant over the  next
four years, with 1980 sales projected at 10,400,000 units  , as summarized  in
Table 3-5.
     All producers have announced their product mix plans  through 1980,  and
there is evidence of down-sizing with each car size category.
     Sales of imported  cars,  which  reached a peak of  18.4  percent of  the U.S.
market  in 1975,  were down to 14.4 percent  for  the first eight months  of 1976.
Foreign car  manufacturers such as Volkswagen and Volvo plan to produce cars
in the  United,States.   In 1978 Volkswagen  expects to produce 50  percent of
its cars for sale in America at its new plant  in New Stanton, Pennsylvania.
Presently Volvo's plans to begin  production in 1977 at its plant near
 Richmond, Virginia,  have been postponed "indefinitely".
                                     3-4

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                 Table 3-4.  AUTOMOBILE ASSEMBLY PLANTS

                              Model Year 1975
  Manufacturer
       Location
       Make of Automobile
American Motors
Kenosha, Wisconsin
Hornet, Gremlin, Pacer, Matador
Chrysler Corp.
Belvidere, Illinois
Hamtramck, Michigan
Jefferson Av.,Detroit
Lynch Rd., Detroit
Newark, Delaware
St. Louis, Missouri
St. Louis, Missouri
Gran Fury, Royal Monaco, Chrysler
Volare, Aspen
Chrysler
Monaco, Fury
Volare, Aspen
Volare, Aspen
Voyager, Sportsman
Ford Motor Co.
Atlanta, Georgia
Chicago, Illinois
Dearborn, Michigan
Kansas City, Missouri
Lorain, Ohio
Los Angeles, Calif.
Louisville, Kentucky
Mahwah, New Jersey
Metuchen, New Jersey
St. Louis, Missouri
San Jose, California
Twin Cities, Minnesota
Wayne, Michigan
Wixom, Michigan
LTD II, Cougar
Thunderbird
Mustang
Maverick, Comet
Couger, LTD II, Club Wagon
Ford, Thunderbird
Ford
Granada, Monarch
Pinto, Bobcat
Mercury
Pinto, Mustang, Bobcat
Ford
Granada, Monarch
Lincoln, Mark V
General  Motors
Arlington,  Texas
Baltimore,  Maryland
Detroit,  Michigan
Doraville,  Georgia
Fairfax,  Kansas
Flint,  Michigan
Framingham, Mass.
Fremont,  California
Janesville, Wisconsin
Lakewood, Georgia
Lansing,  Michigan
Leeds,  Missouri
Linden, New Jersey
Lordstown,  Ohio
Norwood,  Ohio
Pontiac,  Michigan
St.  Louis,  Missouri
South Gate, Calif.
Tarrytown,  New York
Van Nuys, Califorina
Chevelle, Monte Carlo, Cutlass
Chevelle, Monte Carlo, Cutlass
Cadillac, Eldorado,  Seville
Chevelle, Monte Carlo, Cutlass
Pontiac, Oldsmobile,  Buick
Buick,  Century, Riviera
Century, Cutlass
Chevelle, Monte Carlo, Century
Chevrolet
LeMans, Grand Prix
Oldsmobile,  Cutlass,  Toronado
Nova,  Monte  Carlo, Skylark
Cadillac, Oldsmobile, Buick
Vega,  Astre, Sportvan
Camaro, Firebird
Pontiac, LeMans,  Grand Prix
Chevrolet, Corvette
Chevrolet, Buick, Oldsmobile
Nova,  Ventura, Skylark
Nova,  Omega, Ventura, Skylark,
   Camaro
                                                          ...Continued
                                       3-5

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Table 3-4.   (Continued)
Manufacturer
General Motors
Checker Motors
Sebring-Vanguard
Location
Willow Run, Michigan
Wilmington, Delaware
Kalamazoo , Michigan
Sebring, Florida
Make of Automobile
Nova, Omega, Ventura
Chevette , Acadian
Checker
CitiCar
Source:  Ward's 1976 Automotive Yearbook
                   Figure  3-1.  AUTOMOBILE PRODUCTION TRENDS
              do6)
           co
           0>  9.0
              8-5
           <  8.0

           o
           w  7.5
           §
           •H
           2  7.0
              6.5
                    J_
                                     (10.09).
                                                             10.2
                                                         J.
                  1974    1975   1976    1977     1978   1979

                                      Years
                                     3-6

-------
Table 3-5.  AUTOMOTIVE SALES BY CAR SIZE
Type
Sub-Compact
Compact:
Intermediate
Full Size
Specialty
TOTAL
Sales, 103 Units
1976 1977 1978
1,180 1,280 1,460
2,298 2,648 3,120
2,636 3,142 3,220
2,250 2,771 2,390
253 215 240
8,577 10,050 10,400
Percent Market Share
1976 1977 1978
13.8 12.7 14.0
26.8 26.4 30.0
30.8 31.3 31.0
26.4 27.6 23.0
2.2 2.0 2.2
_
                   3-7

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3.1.2.  Track Industry
     The track industry manufactures a wide range of vehicles designed for
personal and commercial applications.  Different models of vehicles are
classified by gross vehicle weight (GVW)  and body type, as summarized in
Table 3-6.
     Close to 43 percent of the total production are vehicles with gross
vehicle weights of under 6,000 pounds, and 75 percent of the total produc-
tion is accounted for by trucks with less than 8,500 pounds GVW.
     The term "light-duty truck" as used in this study indicates all vehi-
cles with ratings of 8,500 pounds or less GVW.  Thirty-six  (36) percent of
all light-duty trucks are produced in Michigan, and the remaining 64 per-
cent are made in the other states.
     Table 3-7 shows light-duty truck assembly locations  in cities and
states.  Table 3-8  summarizes  the light-duty  truck  assembly plants by manu-
facturer and location.
     As with the automobile  industry, the truck industry  has been affected
by recession in the past few years.  After  the record production of 3,007,495
units  in 1973, production slackened  in 1974 and 1975.  In 1976, however, pro-
duction of trucks reached almost the same level as  in  1973  (3,015,000 units).
     The major factors contributing to this growth  were:  the overall eco-
nomic  growth, the new popularity of light-duty trucks and vans for personal
use, and the improved availability of gasoline.
     Assuming that  there is not going to be another petroleum embargo and
that  the improvement in the general economy continues as  forecast, the annual
growth rate  is expected to be  4 percent per annum for 1977  to 1980  .  A mod-
est growth of 1 percent per annum is projected for  1980 to  1985  .  However,
as with the  automobile industry, the demand for light-duty  trucks will be  in-
fluenced by  monetary policy, fiscal policy, and other  economic development.
     As in the automotive market. General Motors as a  total entity dominates
the light-duty truck market with 45 percent of the  total  production in 1975.
Light-duty truck production by model is shown in Table 3-9.
                                    3-8

-------
                                 Table 3-6.  1975 U.S. TRUCK AND BUS FACTORY SALES

                                  BY BODY TYPES AND GROSS VEHICLE WEIGHT, POUNDS
            Body Type
                       6,000   6,0001-   10,001-  14,001-  16,001-  19,501-
                     and Less  10,000    14,000   16,000   19,500   26,000
                                                        26,001-   Over    Total
                                                        33,000   33,000
u>
Pickup

General Utility

Panel

Van

Multi-Stop

Station wagon  (on
truck chassis)

Buses  (including
school bus chassis)

Other body types
680,646  510,189

101,701   94,925

  1,143

191,645  191,168

     23   23,161


  2,741   80,501
                                                12,188
391
1,256
                                                                     307   35,070
                                                           989
      1,190,835

        196,626

          1,143

        382,813

         37,019


         83,242


4,164    40,530
                               4,612   63,043    2,154
                               738    9,019  139,148    26,321   94,917   339,952
       TOTAL
                      982,511  962,987   14,342    1,129   10,582  174,218    27,310   99,081 2,272,160
      Source:  Ward's 1976 Automotive Yearbook

-------
                Table 3-7.  LIGHT-DOTY TRUCK ASSEMBLY PLANTS

                              Model Year 1975
Location of Plant
CALIFORNIA
Fremont
San Jose
GEORGIA
Atlanta
Lakewodd
KENTUCKY
Louisville
MARYLAND
Baltimore
MICHIGAN
Detroit
Flint
Warren
Wayne
MISSOURI
Kansas City
St. Louis
NEW JERSEY
Mahwah
OHIO
Avon Lake
Lordstowa
Toledo
VIRGINIA
Norfolk
WISCONSIN
Jonesville
TOTAL
Units
130,829
53,000
77,829
61,925
13,228
48,697
153,404
153,404
72,175
72,175
601,456
10,543
250,050
212,033
128,830
181,377
67,946
113,431
42,925
42,925
357,502
143,895
102,763
110,844
54,777
54,777
62,153
62,153
1,718,523
Percent
8
3
5
4
1
3 '
9
9
4
4
35
1
14
12
8
10
4
6
3
3
20
9
6
3
3
3
4
4
100
Sources:  Ward's 1976 Automotive Yearbook;  Automotive News, 1975 Almanac;
          and DeBell fi Richardson's estimated breakdown .
                                   3-10

-------
Table 3-8.  LIGHT-DUTY TRUCK ASSEMBLY PLANT LOCATIONS

                   Model Year  1975
 Manufacturer
        Location
 Chrysler Corporation
 Ford Motor Company
 General  Motors
  Jeep
Warren, Michigan
St. Louis, Missouri

Atlanta, Georgia
Kansas City, Missouri
Lorain, Ohio
Louisville, Kentucky
Mahwah, New Jersey
Wayne, Michigan
Norfolk, Virignia
San Jose, California

Baltimore, Maryland
Detroit, Michigan
Flint, Michigan
Fremont, California
Jonesville, Wisconsin
Lakewood, Georgia
Lordstown, Ohio
St. Louis, Missouri

Toledo, Ohio
 Source:   Auto News, 1975 Almanac
                            3-11

-------
Table 3-9.  ESTIMATED LIGHT-DUTY TRUCK PRODUCTION
Make
Chevrolet
Dodge
Ford
General Motors
International
Jeep
TOTAL
1974
724,052
309,810
687,788
138,625
77,411
114,132
2,051,818
1975
624,061
270,926
493,182
128,954
32,772
106,704
1,656,599
Sources:  Auto News.  1975 and 1976 Almanac
          Issues.  DeBell & Richardson esti-
          mated breakdown3.
                     3-12

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3.2.  PROCESSES OR FACILITIES AND THEIR EMISSIONS
3.2.1.  The Basic Process  -  Automotive Industry
     The finishing process of an automobile body is a multistep operation car-
ried out on a conveyor system known as the assembly line.  Such a line oper-
ates at a speed of 20 to 25 feet per minute and produces 30 to 70 units per
hour.  The plant may operate on the basis of one, two, or three shifts per
day.  Usually the third shift is used for cleaning the spray booths.  Plants
usually stop production for several weeks during the summer season for inven-
tory and model changeover.
     Although finishing lines vary from plant  to plant,  they have some common
characteristics which allow us to  show  the  following major steps of such lines
employing organic  solvent-borne paint  systems.
                       *
          Solvent  wipe
          Phosphating treatment
          Application of primer  coat
          Curing of the primer coat
          Application of  the topcoat(s)
          Curing of the  topcoat(s)
          Paint touch-up operations
      The block diagram of these consecutive steps of the automobile finishing
 process is presented in Figure 3-2.  Sanding operations may take place at
 various points of the operation, depending on the manufacturer.  Sealer appli-
 cation generally occurs after the primer application, and sealants are usu-
 ally cured together with the primer in the primer coat oven.
      Touch-up coating operations  are carried  out at various stages of the top-
 coat finishing line to yield a uniform appearance of the coated area.  Touch-
 up coating is cured in the oven except for the final touch-up, which is gener-
 ally a highly catalyzed air-drying coating.   The air-drying type materials are
 preferred for the  last touch-up since  at this stage heat-sensitive plastics
 and rubber automotive parts are already built into the  automobile.
    The term  "solvent"  is  used to mean organic solvent.
                                       3-13

-------
                      Figure 3r-2.   TRADITIONAL COATING OPERATIONS OF AN AUTOMOBILE ASSEMBLY LINE
H
*.
Body welded and
solder applied
and ground down
(Sealants applied
1
1
*
Primer coat
(and sealant)
cured in oven
I
[
)
L, 	 .
r^—^

Solvent wipe
(Kerosene wipe)

Primer coat
applied (spray
or dip)

Sanding of


Second topcoat
sprayed in booth
— —






Topcoat cured
in oven
4
Second topcoat
cured in oven


Paint
touch-up





7-Stage phosphating
t






Cooling with
water spray

Topcoat
sprayed
in booth
. 1
(Sanding)

Paint touch-up
cured in oven
or air dried



           Solvent-borne primers are applied by spraying in booth;
           water-borne primers are applied in a dip tank.

           Solvent-borne primers are applied on an oven-dried bodyj

           water-borne primers are applied on a wet body.

-------
3.2.1.1.  Preparation of Metal Prior to Coating -
     The automobile body is assembled from a number of welded metal sections
to yield the complete unit.  Parts such as hoods and front fenders may or may
not be coated on the same finishing line with the body, depending on the plant.
However, bodies, fenders, and hoods are all passed through the same metal
preparation process.  This document is intended to cover all parts that are
coated in the assembly plant.
     First, parts are wiped with solvent to eliminate traces of oil and grease.
Second, there follows a phosphating process to prepare parts for the primer
application.
     Both iron  and  steel  rust readily, and phosphate treatment is necessary
to prevent such rusting.  Phosphating also improves the adhesion of the metal
to the coating.  The phosphating process occurs in a multistage washer in the
following sequence:
     1.   Alkaline  cleaner  wash  -  20 to  30  seconds
     2.   First hot water rinse  -  60°C (140°F)  -  5  seconds
     3.   Second hot water  rinse  -  60°C  (140°F) -  5  seconds
     4.   Phosphating  with  zinc or iron acid  phosphate -  15 seconds
     5.   Water rinse,  ambient  -  5 seconds
     6.   Dilute  chromic acid rinse  -  5  seconds
     7.   Deionized water rinse  -  5 seconds
     8.   Deionized water rinse  -  5 seconds
     The parts and bodies proceed into a water spray cooling process and are
 then passed through a dry-off oven.
 3.2.1.2.  Primer Coating -
      A primer is applied prior  to the topcoat to protect the metal surface
 from corrosion and to insure good adhesion of the topcoat.  Figure 3-3 is a
 flow diagram showing process steps of both primer and topcoat operations.
      DeBell & Richardson field  work indicates that approximately half of the
 primer is solvent-borne, and the remaining is water-borne.
      Water-borne primer most often is applied by electrodeposition.  The com-
 position of the bath is  about  10 percent solids, 4 percent solvent, with the
 remaining portion  water.   The  solvents used are typically higher molecular

                                     3-15

-------
                  Figure 3r-3.   FLOW DIAGRAM - APPLICATION OF SOLVENT-BORNE PRIMER AND TOPCOAT

                                            AUTOMOBILE BODIES
U)

H
O\
                   Stack
                              Stack
         Body
                    1
                Over-Spray
                (Solvents)
     Prime coat
     spray booth
       Paint
      Thinner
 _n
                  1
        (Solvent Emissions)
                                         Stack
          Evaporation
           (Solvents)
                Flash-off
               of solvents
                       Prime coat
                        cure oven
 Over-spray loss
     (Solids)
                 Stack
                  1
                Over-Spray
                 (Solids)
               Stack                   Stack


                     (Solvent Emissions)
                Topcoat
               spray booth
1
                          Flash-off
                         of solvents
I
Evaporation
 (Solvents)
      Paint
     Thinner
.-T    I
                                     Topcoat
                                     cure oven
                                         To final assembly
Over-spray
 (Solids)

-------
weight alcohols such as butanol or ethylene glycol monobutyl ether.  More
detail on electrodeposition  is supplied in Chapter 4  ~   Emission Control
Techniques.
     Solvent-borne primer is applied by a combination of manual and automatic
spraying.
     Organic solvent emissions were derived from  information collected from
the automotive manufacturers.  Average solvent emission was calculated to be
1.46 gallons per vehicle  for the  primer application.  Assuming that a car pro-
duction line operates  at  a production  rate of 55  cars per hour for two  (8-
hour) shifts per day,  this will mean that 880 cars are produced per day and
that approximately 9000 pounds of solvent are discharged daily from the pri-
mer application process.
     A material balance is  shown  in Table  3-10, which includes the discharge
of emissions  at  steps  in the process.   Discharge  of  solvents  in the primer
application occurs in  the following manner:   88 percent loss  at the applica-
tion step and 12 percent loss in the cure oven step  of the operation.
     Energy requirements of the primer coat are tabulated in  Table 3-11.

                    Table 3-11.   PRIMER - ENERGY BALANCE
                           BASE CASE -  AUTOMOBILES
Operation Steps
Application
Cure
Total
106Btu/Yr a
5,177
73,656
78,836
              a Annual  energy consumption  calculations were based
                on  211,200 cars produced per year, working from the
                followingt  (1)   Production rate  - 55 cars/hr.
                 (2)   Time - 2 shifts (8 hr/shift)/day; 240 days/
                year;  3840 hr/year;  or, 55 cars/hr x 3840 hr/yr =
                211,200 cars/yr.
                                       3-17

-------
   Table 3-10-  MATERIAL BALANCE  - AUTOMOBILE PRIMER
Process Steps
1.

2.

3.
4.

5.
Coating applied
Paint
Thinner
Material loss in the application
Solid
Solvent discharge
Total coating on body
Oven evaporation loss
Solvent discharge
Net dry solids on body
Liters Per
211,200 Cars a

952,533
648,363

217,178
1,072,078
310,223

146,389
163,834
211,200 cars is the annual production figure based on the
following:   (1)   Production  rate - 55 cars/hr.  (2) Time -
2 shifts (8 hr/shift)/day; 240 days/year; 3840 hr/year.
(55 cars/hr x 3840 hr/yr - 211,200 cars/yr.)
                          3-18

-------
3.2.1.3.  Solvent-Borne Topcoat -
     The solvent-borne topcoat is generally applied by a combination of man-
ual and automatic spray.  Average percent solids content in the paint is in
the range of 31 percent volume basis for solvent-borne topcoat enamel type
automotive finish, and 15 percent volume basis for solvent-borne topcoat
lacquer type automotive finish.
     Because of the length of time  that the body is in the spray booth, 85 to
                                                                    4
90 percent of solvent evaporates in the booth and its flash-off area .  Or-
ganic solvent emissions vary with each automotive plant - depending mainly on
the number of units produced daily, the surface area of each unit, and the
amount of solvent in the paint.
     A  flow diagram designating the process  steps of the organic solvent-
borne topcoat operation is  shown in Figure  3-3, page 3-16.
     The loss of paint or the  overspray ranges  from 20-35 percent  for  solvent-
borne topcoats.  Most automotive companies  are  using water-washed  spraying
booths.  The water used  in  spray booth curtains is  discharged  into sludge
tanks where solids are  removed as the water is  recirculated.   The  sludge
tanks are  cleaned once  a year when organic solvent-borne  coating is used .
     Topcoat  application is made in one or more steps (as many as three)  to
insure  sufficient coating thickness.   An oven bake follows each topcoat ap-
plication.   The topcoat energy balance is shown in Table 3-12.
      Following the application of  the topcoat,  the painted body goes to the
 trim operation area where vehicle  assembly is completed.
      A final step of the finishing operation is generally the paint-repair
 process where damaged paint is repaired in a spray booth.
                                      3-19

-------
      Table  3-12.  MATERIAL  BALANCE - AUTOMOBILE TOPCOAT
Process Steps
1.

2.

3.
4.

5.
Coating applied
Paint
Thinner
Material loss in the application step
Solid
Solvent discharge
Total coating on body
Oven evaporation loss
Solvent discharge
Net dry solids
Liters Per
211,200 Cars3

1,881,053
480,269

332,383
1,564,815
464,124

213,381
66,159
a 211,200 cars is the annual production figure based on the
  following:  (1)  Production rate - 55 cars/hr.  (2) Time -
  2 shifts  (8 hr/shift)/day; 240 days/year; 3840 hr/year.
  (55 cars/hr x 3840 hr/yr = 211,200 cars/yr.)
          Table 3-13.  TOPCOAT - ENERGY BALANCE

                BASE CASE - AUTOMOBILES
Operation Steps
Application
Cure
Total
106 Btu/Yra
13,316
189,422
202,738
  Annual energy consumption calculations based on 211,200 cars
  produced per year, derived as follows:   (1) Production rate -
  55 cars/hr.   (2)   Time - 2 shifts (8 hr/shift)/day; 240 days/
  year.  (55 cars/hr x 3840 hr/yr = 211,200 cars/yr.)
                             3-20

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3.2.1.4.  Equipment Characteristics -

      Equipment of the automotive finishing line associated with organic emis-
sions consists of:  the spraying booths, dip tanks, and bake ovens.  Other
equipment required includes, specialized conveyors for moving the bodies to be
painted through the process system.
      Solvent-borne primer and topcoat are applied by a combination of manual
and automotic spraying techniques.  Spray booth lengths vary from 100 to 200
feet.  Because of the length of the time that  the body is in the spraying
booth, the majority of solvents are emitted in the spraying area.  Air flow
rates in the booth carry  the vapors away to such a degree that the existing
concentration of organic  solvent vapor is very low.
      To comply with OSHA regulations, a minimum air velocity for exhaust de-
vices is required.  As a  result, organic vapors are in the vicinity of 50 to
150  ppm in the spray area.  However, even though the solvent concentration
is low, the volume of exhaust  is high and the  total amount of solvent emitted
can easily exceed the limit of 3000 pounds per day required by many state
regulations.  The temperature  in the  spray booths ranges  from 15 C  (60 F) to
35°C  (95°F).
      Water-washed  spray booths are  the  type most used  in automobile produc-
tion  facilities.  In  a typical design of booths, the  overspray paint parti-
cles  are removed by  means of a curtain of water flowing  down the  side  sur-
faces of the booth  enclosure.
      Water-wash systems in  several booths  are connected  to one  or more  large
sludge  tanks.   The  floating  sludge is skimmed off the surface of the water
and passed  through  a filter,  then recirculated to the booth.
      Bake  ovens for the primer and topcoats usually have four or  more  heat
zones.   Oven temperatures range from 93°C C200°F)  to 232°e C45Q9Fl, depending
on the  type of coating and the zone.
 * Threshold limit for solvent toluene, xylene, 100 parts/million.
   American Conference of Governmental Industrial Hygienist. 1973.
                                       3-21

-------
      A paint bake oven can safely operate at 25 percent of the lower explo-
sive limit (LEL) and in many industries such concentrations are maintained.
In the automotive industry, however, concentrations are much lower for several
reasons.  Ovens are very long with large openings, hence large amounts of air
are pulled into them.  Ovens are designed to provide a bake environment that
is not saturated with solvent, as air pressures present in the oven tend to
force available solvent vapors into the panel insulation .
      The two major automobile manufacturers report solvent concentrations at
5 percent of the LEL7'8.  According to another source, solvent concentration
                                                              9
in the oven may reach a maximum of about 10 percent of the LEL .
3.2.1.5.  Emission Characteristics -
      The three types of organic  solvent-borne coatings used  in  the automo-
tive industry  are paints,  enamels,  and lacquers.
      Paints represent  a small fraction of the total quantity of the  coatings
used in automotive coating operations.  Paints are highly pigmented drying
oils diluted with a  low solvency  power solvent known as thinner.  Applied
paints  dry and cure  in  the oven by evaporation of the thinner and by  oxida-
tion, in which the drying  oil polymerizes  to  form the resinous film.
      Enamels  are the same as paints  except that  they contain a  higher concen-
tration of synthetic drying oils  in the enamel coating composition.
      Lacquers, in contrast to enamels, do not undergo a chemical reaction
when exposed  to heat.   Applied lacquers are dried by evaporation of the  sol-
vent to form the coating film.
      The amount of  solvent and thinners used in  surface coating compositions
varies,  depending upon  the plant  in which  they are used.  The solvents are:
aromatic hydrocarbons,  alcohols,  ketones,  ethers, and esters  - used in enamels,
lacquers, and varnishes.   The thinners  are:  aliphatic hydrocarbons,  mineral
spirits, naphtha, and turpentine  - used in paints, enamels, and  varnishes.
      As it was mentioned  previously,  organic solvent emissions  occur at the
application  and cure step  of the  coating operation.  Calculations of  solvent
emissions  from plants visited result  in the  following emission factors for the
primer  and topcoat operations  (Table 3-14):
                                       3-22

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                  Table 3-14.  AVERAGE EMISSIONS FOR THE
                       AUTOMOBILE FINISHING PROCESS
                              Liters Per Car
Coating
Primer -
Solvent-borne spray
coat
Topcoat -
Solvent-borne topcoat
TOTAL
Applica-
tion

4.85

7.47
12.32
Cure

0.67

1.02
1.69
Total

5.52

8.49
14.01
Assuming that the production rate of a finishing line is 880 cars per day
(two 8-hour shifts), 22,800 pounds of solvents are discharged daily from the
finishing operation.

Solid waste loss from the automotive lines was also calculated based on data
collected from the industry.  Table 3-15. shows solid waste loss factors for
the automotive coating operation.
             Table  3-15.  ESTIMATED SOLID WASTE  GENERATED FOR
            BASE-CASE AUTOMOTIVE FINISHING APPLICATION PROCESS
Coating
Primer -
Solvent-borne spray
Topcoat -
Solvent-borne spray
TOTAL
Average Transfer Loss
of Solids in Coatings,
Kg/Vehicle
0.49
1.04
1.53
                                     3-23

-------
      Effluents from water wash in spray booths contain contaminants from
overspray of coatings.  Coating transfer efficiency ranges from 30-68 percent
depending on coating technique used.  The water used in the spray booth cur-
tain is discharged into sludge tanks, where solids are removed and the water
is recirculated.  The sludge tanks are cleaned once a year when organic sol-
vent-borne coatings are used, and four times when water-borne coatings are
used  .
3.2.1.6.  Parameters Affecting Emissions -
       There  are  several factors which affect emissions discharged by the auto-
motive industry.  Naturally the greater the quantity of solvent in the coat-
ing composition  the greater will be the air emissions.  Lacquers having 15-
17 volume percent solids  are higher in organic solvents than  enamels having
30-35 volume percent  solids.
       Because of inventory and model style changes, plants close down  for  sev-
eral  weeks during the summer.  Plants also close down  for several weeks at the
year's end.   Production affects the amount of  discharge organic solvent emis-
sions:  the  higher  the production  rate, the greater the emissions.  This rate
can also be  influenced by the  area of the parts being  coated.
       Emissions are also  influenced by  the thickness of the coating and the
transfer efficiency of the coating technique used.  There are no transfer
problems when electrodeposition is used; essentially all  the  paint solids  are
transferred  to the  part.   There can be  dripping associated with dragout, but
this  material is normally recovered in  the rinse water and returned to the dip
tank.  In the case  of spray coating, the efficiency varies depending on the
type  of spraying technique used.   Coating  loss with nonelectrostatic spraying
ranges from 40-70 percent; with electrostatic  spraying the range is from 13-
          *10
32 percent  .
       Also influencing emissions are state or  intrastate  regulations.  Thir-
teen  states  have in effect statewide regulations for  the  control of airborne
emissions from stationary sources.  Eight  states have  promulgated  individual
district regulations.  Of all  statewide and  intrastate regulations, the
Rhode Island regulations  appear to be the most stringent, allowing only 100
pounds of solvent emission per affected facility per  day.
                                   3-24

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3.2.2.  The Basic Process - Light-Duty Truck Industry
      The finishing process of a light-duty truck body is a multistep opera-
tion carried out on a conveyor system known as the assembly line.  Such a line
produces 35-38 units per hour.  The plant may operate on the basis of one, two,
or three shifts per day.  Usually the third shift is used for cleaning the
spray booths.  Plants usually stop production for several weeks during the
summer season for inventory and model changeover.
      Although finishing lines vary from plant to plant, they have some com-
mon characteristics which allow us to show the following major steps of such
lines employing organic solvent-borne paint systems:
          Solvent wipe
          Phosphating treatment
          Application of primer coat
          Curing of the primer coat
          Application of the topcoat(s)
          Curing of the topcoat(s)
          Paint touch-up operations
      Figure  3-4 presents a block diagram showing, these consecutive  steps of
the light-duty truck  finishing process.   Sanding operations may  take place  at
various points of  the  system, depending on the manufacturer.   Sealer applica-
tion  generally occurs  after the primer application,  and sealants are usually
cured together with the primer  in the primer coat oven.
      Touch-up coating operations are carried out at various  stages  of the
topcoat  finishing line to yield a uniform appearance of the coated area.
Touch-up coating  is cured in the oven except for the final touch-up, which  is
generally carried out using a highly catalyzed,  air-drying type  of coating
material.  The  air-drying type materials are preferred for the last  touch-up
because  at this  stage heat-sensitive plastics and rubber automotive  parts are
already  built into the light-duty truck.
 3.2.2.1.  Preparation of Metal Prior to Coating -
       The light-duty truck body is assembled from a number of welded metal
 sections to yield the.complete unit.  Parts such as hoods and front fenders
 may or may not be coated on the same finishing line as the body, depending on
                                      3-25

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         Figure 3-4.  TRADITIONAL COATING OPERATIONS OP A LIGHT-DUTY TRUCK ASSEMBLY LINE
Body welded and
solder applied
and ground down
I Sealants applied
j
4
Primer coat
(and sealant)
cured in oven

Second topcoat
sprayed in booth
i
Second topcoat
cured in oven
L

Solvent wipe
(Kerosene wij
1 l 	
u 	
^^



£
36)

Primer coat
applied (spray
or dip)

Sanding of
primer




Topcoat cured
in oven

Paint
touch-up

^•MMM








7-stage phosphating
r




•— •*
Cooling with
water spray

Topcoat
sprayed
in booth
1
(Sanding)


Paint touch-up
cured in oven
or air dried


Solvent-borne primers are applied by spraying in booth;
water-borne primers are applied in a dip tank.

Solvent-borne primers are applied on an oven-dried body?
water-borne primers are applied on a wet body.

-------
the plant.  However, bodies, fenders, and hoods are all passed through the
same metal preparation process.
      First, parts are wiped with solvent to eliminate traces of oil and
grease.  Second, phosphating follows, to prepare parts for the primer appli-
cation.  Iron and steel rust most readily, and therefore the metal is pre-
treated with phosphate to prevent such rusting.  Phosphating also improves
the adhesion of the metal to the coating.  The phosphating process takes
place in a multistage washer which  involves the following steps:
      1.  Alkaline cleaner wash  -   20 to 30 seconds
      2.  First hot water rinse, 60°C  (140°F)  -   5 seconds
      3.  Second hot water rinse, 60°C  (140°F)  -  5  seconds
      4.  Phosphating with zinc or  iron acid phosphate  -  15 seconds
      5.  Water rinse, ambient -   5 seconds
      6.  Dilute chromic acid  rinse - 5 seconds
      7.  First deionized water rinse   -   5  seconds
      8.  Second deionized water rinse  -   5  seconds
      The parts and bodies proceed  to a water spray cooling process  and are
then passed through a dry-off  oven.
3.2.2.2.  Primer Coating -
      A primer  is  applied prior  to  the  topcoat to protect the metal  surface
from corrosion  and to  insure good adhesion of the topcoat.   The flow diagram
in Figure 3-5 shows process steps to both primer and topcoat operations for
light-duty trucks.    Either solvent-borne or water-borne primer coat materi-
als may be used in the light-duty truck process .
       Water-borne  primer is applied by electrodeposition.  The composition of
the bath  is about  10 percent solids, 4 percent solvent, with the remainder
water.  The solvents used are typically highest molecular weight alcohols
such as butanol or ethylene glycol monobutyl ether.  More detail on the elec-
trodeposition method of coating is supplied in Section IV, Emission Control
 Systems.   Solvent-borne primer is applied by a combination of manual and
 automatic spraying.
       Organic solvent emissions were derived from information collected from
 the light-duty truck manufacturers.  The average  solvent emission of plants

                                      3-27

-------
                   Figure 3-5.  FLOW DIAGRAM - APPLICATION OF SOLVENT-BORNE PRIMER AND TOPCOAT

                                            LIGHT-DUTY TRUCK BODIES
to
to
00
                    Stack
                              Sts
                            Over-Spray
                             (Solvents)
                  Prime coat
          Body  I spray booth
        Paint _
        Thinner
_n
                   ck
                                                                     Sta
                                     (Solvent Emissions).
                             Flash-off
                            of solvents
                                                          ck
                                                  Evaporation
                                                   (Solvents)
                                       Prime coat
                                        cure oven
Over-spray loss
    (Solids)
                   Stack
                    1
               Over-Spray
                (Solids)
              Stack                    Stack

                    (Solvent Emissions)
                  Topcoat
                spray booth
1
                          Flash-off
                         of solvents
i
Evaporation
 (Solvents)
                                      Topcoat
                                     cure oven
                                           To final assembly
        Paint
       Thinner

              Over-Spray
               (Solids)

-------
using solvent-borne primer was calculated to be 1.22 gallons per vehicle for
the primer application.  Assuming that a light-duty truck production line op-
erates at a production rate of 38 light-duty trucks per hour for two (8-hour)
shifts per day, this will mean that 608 light-duty trucks are produced per day
and that approximately 5200 pounds of solvents are discharged daily from the
primer application process.
      A material balance showing the discharge of emissions at the steps in
the primer application process is presented in Table 3-16.
      Discharge of solvents in the primer application occurs in the following
manner:  88 percent loss at the application step, and 12 percent loss in the
cure oven step of the operation.
      Energy requirements of  the primer coat  are tabulated in Table 3-17.
3.2.2.3.  Solvent-Borne Topcoat -
      Solvent-borne topcoat is generally applied by a combination of manual
and automatic  spraying.  Average percent solids content in the paint is  in the
range of 31 percent volume basis  for solvent-borne  topcoat for light-duty
trucks.
      Because  of  the  length of time that the  body is in the  spray booth, 85-
                                                                     4
90 percent of  solvent evaporates  in the booth and its  flash-off  area .
      Organic  solvent emissions vary with each light-duty truck  plant,  depen-
ding mainly on the number of units produced daily,  the surface area of each
unit, and the  amount of solvent content in the paint.
      Table  3-18  presents the Material Balance for the topcoat operation.   A
 flow diagram showing the process steps of the organic solvent-borne topcoat
 operation is given in Figure 3-5 on page 3-28.
      The amount of  the  overspray  ranges from  20 to  35  percent for
 solvent-borne topcoating.  Jtost light-duty truck companies are using water-
 washed spraying booths.  The water used in spray booth curtains is discharged
 into sludge tanks where solids are removed as the water is recirculated.  The
 sludge tanks are cleaned once a year when organic solvent-borne coating is
    ,,5
 used .
                                        3-29

-------
      The topcoat is applied in one or more steps  (as many as three) to in-
sure sufficient coating thickness.  Oven baking follows each topcoat applica-
tion.  The topcoat energy balance is shown in Table 3-19.
      Following the application of the topcoat, the painted body goes to the
trim operation area where vehicle assembly is completed.
      A final step of the finishing operation may be the paint-repair process
where damaged paint is repaired in a spray booth.

                     Table 3-16.  MATERIAL BALANCE - PRIMER
                            LIGHT-DOTY TRUCK BODIES
Process Steps
1.

2.

3.
4.

5.
Coating applied
Paint
Thinner
Material loss in the application step
Solid
Solvent discharge
Total coating on body
Oven evaporation loss
Solvent discharge
Net dry solids on body
Liters Per
145,920 Vehicles

829,555
276,518

189,140
681,340
235,594

92,984
142,686
       a 145,920 vehicles is the annual production figure based on the
         following:  (1) Production rate - 38 vehicles/hour.  (2)  Time -
         2 shifts  (8 hours/shift) per day; 240 days/year,- 3840 hours/
         year.  (38 vehicles/hr x 3840 hr/yr = 145,920 vehicles/yr.)
                                    3-30

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               Table 3-17.  ENERGY BALANCE - PRIMER

                  BASE  CASE - LIGHT-DUTY TRUCKS
Operation Steps
Application
Cure
TOTAL
106 Btu/Yeara
4,233
37,517
41,750
      Annual energy consumption calculations were based on the
      figure 145,920 vehicles, as follows:   (1) Production
      rate - 38 vehicles/hour.   (2)  Tine:  2 shifts (8 hours/
      shift) per day; 240 days/year; 3840 hours/year. (38 vehi-
      cles/hr x 3840 hr/yr = 145,920 vehicles/yr.)
              Table 3-18.  MATERIAL BALANCE - TOPCOAT

                      LIGHT-DUTY TRUCK BODIES
Process Steps
1.
2.
3.
4.
5.
Coating applied
Paint
Thinner
Material loss in the application step
Solid
Solvent discharge
Total coating on body
Oven evaporation loss -
Solvent discharge
Net dry solids on body
Liters Per
145,920 Vehicles
1,603,807
182,500
283,393
1,134,430
368,482
154,698
213,786
a 145,920 vehicles is the annual production figure based on the fol-
  lowing:   (1)  Production  rate -  38 vehicles/year.   (2)  Time - 2
  shifts  (8 hours/shift)/day;  240  days/year;  3840 hours/year.  (38
  vehicles/hr x 3840 hr/yr  = 145,920 vehicles/yr.)
                                3-31

-------
                    Table 3-19.   ENERGY BALANCE  -  TOPCOAT
                         BASE CASE - LIGHT-DUTY TRUCKS
Operation Steps
Application
Cure
TOTAL
106 Btu/Year a
10,852
96,322
107,324
     el
       Annual energy consumption calculations were based on the yearly
       production  figure of 145,920 vehicles, as follows:   (1) Produc-
       tion rate - 38 vehicles/hour.   (2)  Time - 2 shifts  (8 hours/
       shift)/day; 240 days/year; 3840 hours/year.   (38 vehicles/hr x
       3840 hr/yr  = 145,920 vehicles/yr)

3.2.2.4.  Equipment Characteristics -
     Equipment of  the light-duty truck finishing line associated with organic
emissions includes:  the spraying booths, dip tanks, and bake ovens.  Other
requirements include:  specialized conveyors for moving the bodies to be
painted through the process.
     Solvent-borne primer and topcoat are applied by a combination of manual
and automatic spraying techniques.  Spray booth lengths vary from 100 to 200
feet each.  Because of the length of the time that the vehicle body is in the
spray booth, the majority of solvents are emitted in the spraying area.  Air
flow rates in the booth carry the vapors away to such a degree that the exist-
ing concentration of organic solvent vapor is very low.  To comply with OSHA
regulations, a minimum air velocity for exhaust devices is required.  As a
result, organic vapors are in the vicinity of 50 to 150 ppm  in the spray
area.  Even though the solvent concentration is low, however,  the volume of
exhaust is high and the total amount of solvent emitted can easily exceed
the limit of 3000 pounds per day required by many state regulations.  The
temperature in the spraying booths ranges from 15°C (60°F)  to 35°C (95°F).
  Threshold limit for solvent toluene, xylene, is 100 parts/million.
  American Conference of Governmental Industrial Hygienist.  1973.
                                   3-32

-------
     Water washed spray booths are the type most used in light-duty truck
production facilities.  In a typically designed booth, the overspray paint
particles are removed by means of a curtain of water flowing down the side
surfaces of the booth enclosure.
     Water-wash systems in several booths are connected to one or more large
sludge tanks.  The floating sludge is skimmed off the surface of the water
and passed through a filter, and is then recirculated to the booth.
     Bake ovens for the primer and topcoats usually have four or more heat
zones.  Oven temperatures range from 200-450°F, depending on the type of
coating and the zone.
     A paint bake oven can safely operate at 25 percent of the lower explo-
sive limit (LEL) and in many industries such concentrations are maintained.
In the light-duty truck industry, however, concentrations are much lower for
several reasons.  Ovens are very long, with large openings, hence large
amounts of air are pulled into the oven.  The ovens are designed to provide
a bake environment that is not saturated with solvent, as air pressures pres-
ent in the ovens tend to force available solvent vapors into the panel
insulation .
     The two major light-duty truck manufacturers report solvent concentra-
                             7 8
tions at 5 percent of the LEL ' .  According to another source, solvent con-
                                                                   9
centration in the oven may reach a maximum of 10 percent of the LEL .
3.2.2.5.  Emission Characteristics -
     The three types of organic solvent-borne coatings used in the light-
duty truck industry are:  paints, enamels, and lacquers.
     Paints represent a small fraction of the total quantities of the coat-
ings used in the light-duty truck coating operations.  Paints are highly pig-
mented drying oils diluted with a low solvency power  solvent known as thinner.
Applied paints dry and cure in the oven by evaporization of the thinner and
by oxidation in which the drying oil polymerizes to form the resinous film.
     Enamels are the  same as paints with the exception of a higher concentra-
tion of synthetic drying oils in the enamel coating.
                                     3-33

-------
      The amount of solvent and thinners used in surface coating compositions
varies with the plant.  The solvents are aromatic hydrocarbons, alcohols, ke-
tones, ethers, and esters and are used in enamels, lacquers and varnishes.
The thinners are aliphatic hydrocarbons, mineral spirits, naphtha, and turpen-
tine - used in paints, enamels, and varnishes.
      As it was mentioned previously, organic solvent emissions occur at the
application and cure steps of the coating operation.  Calculations of solvent
emissions  from plants visited result in the following emission factors for the
primer and topcoat operations  (Table 3-20):

                  Table  3-20.   AVERAGE  EMISSIONS FOR THE
                     LIGHT-DUTY TRUCK FINISHING  PROCESS
                              Liters Per Truck
Coating
Primer -
Solvent-borne spray coat
Topcoat -
Solvent-borne topcoat
TOTAL
Applica-
tion

4.05

9.58
13.63
Cure

0.55

1.31
1.86
Total

4.60

10.89
15,49
       Assuming that the production rate of a finishing line is 608 light-duty
 trucks per day (two 8-hour shifts), 17,400 pounds of solvent will be dis-
 charged daily from the finishing operation.
       Solid waste loss from the light-duty truck lines was also calculated
 based on data collected from the industry.  Table 3-21 shows solid waste loss
 factors for the light-duty truck coating operation.
       Effluents from water-wash in spray booths contain contaminants from over-
 spray of coatings.  Coating transfer efficiency ranges from 30-68 percent, de-
 pending on coating technique used.  The water used in spray booth curtains is
 discharged into sludge tanks where solids are removed and the water is
 recirculated.
                                       3-34

-------
             Table 3-21.  ESTIMATED SOLID WASTE GENERATED FOR
               BASE-CASE LIGHT-DUTY TRUCK FINISHING PROCESS
Coating
Primer -
Solvent-borne spray
Topcoat -
Solvent borne spray
TOTAL
Average Transfer Loss
of Solids in Coatings,
Kg/Vehicle
0.38
1.04
1.57
3.2.2.6.  Parameters Affecting Emissions -
      There are several factors which affect emissions discharged by the
light-duty truck industry.  Naturally, the greater the quantity of solvent in
the coating compisition, the greater will be the air emissions.
      Because of inventory and model style changes, plants close down for sev-
eral weeks during the summer.  Plants also close down for several weeks at the
year's end.  Production, therefore, affects the amount of discharged organic
solvent emission  -  the higher the production rate, the greater the emissions.
This rate can also be influenced by the area of the parts being coated.
      Emissions are also influenced by the thickness of the coating and the
transfer efficiency of the coating technique used.  There are no transfer
problems involved with the use of  electrodeposition; essentially all of the
paint solids are transferred to the part.  There can be dripping associated
with dragout, but this material is normally recovered in the rinse water and
returned to the dip tank.  In the  case of spray coating, however, the effi-
ciency varies depending on the type of spraying technique used.  Coating loss
with nonelectrostatic spraying ranges from 40-70 percent; with electrostatic
                                           10
spraying the range is from 13 to 32 percent   .
                                      3-35

-------
     Emissions are also Influenced by state or intrastate regulations.  Thir-
teen states have in effect statewide regulations for control of airborne emis-
sions from .stationary sources.  Eight states have promulgated individual dis-
trict regulations.  Of all statewide and intrastate regulations, the Rhode
Island regulations appear to be the most stringent - allowing only 100 pounds
of solvent emissions per affected facility per day.
                                   3-36

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3.3.  REFERENCES
      1.  Larson, C. J.  Transportation and Capital Equipment Division,
          U. S. Industrial Outlook 1975.  U. S. Department of Commerce.
          p. 133.
      2.  Ward's 1976 Automotive Yearbook.  Ward's, Communications, Inc.
          1976.  p. 90-91.
      3.  Wark, D.  Automotive Study.  DeBell  & Richardson, Enfield,
          Connecticut.  1977. pp 24-27.
      4.  Air Pollution Engineering  Manual.  U. S. Department of Health,
          Education, and Welfare; Cincinnati,  Ohio.   1967.  p 711.
      5.  Telephone conversation, Tibor  Gabris of DeBell  & Richardson with
          spokesman of General Motors  Assembly Division,  General Motors
          Corporation, Van Nuys Plant.  October 29,  1976.
      6.  Johnson, W. R.   General Motors Corporation, Warren, Michigan.
          Letter to J. A.  McCarthy of  EPA.   August 13, 1976.
      7.  Letter of V. H.  Sussman, Ford Motor Company, One Parklane Blvd.,
          Dearborn, Michigan,  to  Radian Corporation,  commenting on report
          "Evaluation of  a Carbon Adsorption/Incineration Control  System
          for  Auto Assembly  Plants." March 15, 1976.
      8.  Comments of  General Motors Corporation on EPA "Guidelines for
          Control  of Volatile Organic Emissions from Existing Stationary
          Sources".  V.  H. Sussman to J. A. McCarthy of EPA.   August 13,
          1976.
      9.  Conversation,  J. A. McCarthy of EPA with Fred Porter of Ford
          Motor Company,  Dearborn,  Michigan.  September 23,  1976.
      10.  Waste Disposal from Paint Systems Discussed at Detroit,
          Michigan.  American Paint & Coating Journal.  February 23,
           1945. pp 35-36.
                                        3-37

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                     4.   EMISSION CONTROL TECHNIQUES

     This chapter and Chapter 6 are both analyses of available emission con-
trol technology for the automobile and light-duty truck industry.  The pur-
pose of this chapter is to define the emission reduction performance of spe-
cific control techniques, while Chapter 6 evaluates complete systems which
include finishing processes in combination with one or more emission reduc-
tion techniques.
     The purpose of the control techniques as referred to in this chapter is
to minimize emissions of volatile organic compounds to the air.  These com-
pounds - ketones, alcohols, esters, saturated and unsaturated hydrocarbons,
and ethers - make up the major portion of solvents used for paints, thinners,
and cleaning materials associated with industrial finishing processes.
     There are several types of control techniques presently in use within the
automotive and light-duty truck industry.  These methods can be broadly cate-
gorized as either "add-ons" or "new coating" systems.  Add-ons are used to
reduce emissions by either recovering or destroying the solvents before they
are emitted into the air.  Such techniques include thermal and catalytic in-
cinerators and carbon adsorbers.  New coatings refers to application methods
which use coating materials containing relatively low levels of organic sol-
vents.  Such methods include electrodeposition or air spray of water-borne
coatings and electrostatic spray of water-borne and powder coatings.  Because
of the lower solvent content of the "new" coating materials, these application
methods are inherently less polluting than processes which use "conventional"
organic solvent-borne coatings.
     The following discussion characterizes the control techniques and defines
the emission reduction performance associated with each technique in use in
the auto and light-duty truck industry.
                                    4-1

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4.1.  THE ALTERNATIVE EMISSION CONTROL TECHNIQUES
4.1.1.  Water-Bome Coatings
      Of the control techniques presently in use in the automobile and light-
duty truck industry, water-borne coatings are the roost common.  Most of the
water-bornes are being applied by electrodeposition for use as primers.
Water-borne spray topcoats are being used to a lesser extent.
      The terminology for water-borne coatings tends to be confusing; the
names of the various coating types are often misused or used synonymously.
The  term water-bornes as discussed here refers to any coating material which
uses water primarily as the carrier, and is meant to distinguish such coat-
ings from organic solvent-borne paints.
      There are three types of water-borne coating materials:  latex or emul-
sion paints, partially solubilized dispersions, and water-soluble coatings.
Table 4-1 lists the significant characteristics of these three types of coat-
ing materials.
      The majority of water-borne industrial  finishes are based on partially
solubilized resins in the 3.5 to 8.0 x 10  molecular weight range  and are
applied by electrodeposition  (EDP).
4.1.2.  Electrodeposition
      Only water-borne coatings can be applied by  the electrodeposition  (EDP)
process.  Currently, electrocoating or electrodeposition is used in almost
half of the existing assembly plants  for application of automotive primers to
bodies and associated parts  such  as  fenders and  hoods.  Such  systems have been
                    345
described in detail  '  '  .
      In applying  electrodeposition  coatings,  the  parts are immersed in a bath
of  low-solids  water-borne coating solution; the  tank or grids on the periphery
of  the tank are  subjected to a negative  charge while the parts are grounded.
The process is analogous to  electroplating; negatively charged polymer is
attracted to the metal  item and is deposited  as  a  highly uniform coating  .
Systems of the opposite polarity can also be  used.
      Figure 4-1 shows  a typical closed-loop  electrocoating  line.
                                    4-2

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                    Table 4-1. WATER-BORNE COATINGS
Properties
Resin particle
size
Molecular
weight
Viscosity
Viscosity control
Solids at appli-
cation
Gloss
Chemical resis-
tance
Exterior durabil-
ity
Impact resistance
Stain resistance
Color retention
on oven bake
Reducer
Washup
Latex or
Emulsion Paints
0.1 micron
1 million
Low - not depen-
dent on molecu-
lar weight
Requires thick-
eners
High
Low
Excellent
Excellent
Excellent
Excellent
Excellent
Water
Difficult
Partially
Solubilized
Dispersions
Ultrafine
50,000 - 200,000
Somewhat dependent
on molecular wt.
Thickened by addi-
tion of cosolvent
Intermediate
Low to medium-
high
Good to excellent
Excellent
Excellent
Good
Excellent to good
Water
Moderately
difficult
Water-Soluble
Coatings
-
20,000 - 50,000
Very dependent
on molecular
weight
Governed by mo-
lecular weight
and solvent per-
cent
Low
Low to highest
Fair to good
Very good
Good to excel.
Fair to good
Good to fair
Water or water/
solvent mix
Easy
Source:  Industrial Finishing  (July 1973) p 13
                                  4-3

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                                                                        141
              Figure  4-1.  TYPICAL ELECTRODEPOSITION SYSTEM DIAGRAM
                                                  Deionized Water
 Electrodeposition
     Dip Tank
    Paint Supply
          Rinse Tank 12
                                                  Rinse Tank  13
                   Paint Return
—  Ultrafiltration
Ultrafiltrate
                                        Holding Tank
                                                                              Drain

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     Most of the solubilized water-borne coatings used for EDP are based on
alkyd, polyester, acrylic, modified silicone, and epoxy resins - often made
crosslinkable with amine resins such as hexamethoxymethyl melamine .  A com-
mon method of solubilizing is to incorporate carboxyl-containing materials
such as maleic anhydride and acrylic acid into the polymer backbone.  The
acids are then "solubilized" with low molecular weight amines such as tri-
ethylamine, or to a lesser extent with potassium hydroxide .
     The solubilized resins used for auto primers are generally based on mal-
enized oils or malenized polyester.  These resins are combined with pigments
such as carbon black and iron oxide and are dissolved in water/solvent ratios
ranging from 98%/3% to 90%/10%.  The organic solvents used are typically
higher molecular weight alcohols such as butanol or  glycol ethers such as
                                                  g
ethylene glycol  monobutyl  ether  (butyl cellosolve)  .
     After electrodeposition,  the  coatings are  baked and the  amine,  solvent,
and water evaporate to leave a cured film that  closely resembles an  organic
                    9
solvent-borne finish  .
      In a typical EDP operation, bodies or parts are loaded on a conveyor
which carries them first  through a pretreatment section.  The treated and
washed bodies or parts are lowered automatically into the EDP tank containing
the water-borne  paint, a  6-12% dispersion of a  colloidal polymer '   '   .  The
body or part becomes the  anode of  the electrical system while the tank or
grids mounted in the tank become the cathode.   To avoid stripping the coating
the DC current is not applied  until the part is totally submerged.   Current
flow  through the bath causes the paint  "particles"  to be attracted to the
metal surface, where they deposit  as a uniform  film. The polymer film  that
builds up tends  to insulate the  part and prevent further deposition.  Dwell
time  in the tank is typically  1-1/2 to  2 minutes '   '   '   .
      The current is then  shut  off  and the parts are raised out of the bath,
allowed to drain, rinsed  to remove "dragout", and then baked. Solids from the
dragout are collected in  the rinse water and usually are returned to the EDP
                                                                     14 15
tank.   This recovery can result in a paint  savings of  from 17 to 30%
Excess water is  removed from the paint bath  using an ultrafilter.
      The conveyors, pretreatment section, and bake  oven used  for EDP are
                                                              6,16
conventional items; the critical components  of  the  system are    :

                                   4-5

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(1)  Dip Tank
     The dip tank is a large rectangular container generally with a
capacity of 121,120 to 321,725 liters  (32,000 to 85,000 gallons),
depending on part size   .  Larger tanks are used for priming bodies
while the smaller units  are used for painting associated parts such
as fenders and hoods.  The tanks are coated internally with a dielec-
tric material such as epoxy and are electrically grounded for
      5 12
safety '  .  Shielded cathodes are submerged and usually run along
both sides of the tank.
(2)  Power Supply
     Direct current electrical power is supplied by a rectifier with
a capacity of approximately 250 to 300 volts and 300 to 2,500 am-
peres, depending on the  number of square feet per minute to be fin-
ished.
(3)  Heat Exchangers
     Paint drawn from the dip  tank is  passed through a heat exchanger
to dissipate heat which  is developed during the "painting" operation.
The temperature is normally maintained at  within ±  1 C of 20-24  C
(± 2°F of SS-TS^)5'11'12.
(4)  Filters
     An  "in-line"  filter is also  placed in the  recirculating  system to
remove dirt and polymer  agglomerates  from the paint.
 (5)  Pumps
     Circulating pumps  are  used to keep the paint solution moving.
 (6)  Paint Mixing  Tanks
     Paint mixing  tanks  are used to premix and store paint  solids  for
addition to  the  dip tank as needed.
 (7)  Control Panel
     The electrodeposition process is generally controlled  from a  cen-
tral control console.   This panel contains all start-stop switches plus
instruments for monitoring voltage, amperage,  paint temperature, and pH.
                                 4-6

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     Proper pretreatment can be critical to paint performance - particularly
if the substrate has grease or oil on the surface.  Solvent-borne paints will
                                                                      18
generally "dislodge" an occasional oil spot, but water-bornes will not
Cleaners developed for conventional systems are generally adequate for EDP.
     Painting in the dip tank is affected by voltage, current density, tem-
                                            19
perature, dwell time, pH, and solids content
     By increasing the voltage or the temperature in the bath, the film thick-
ness can be increased.  Excessively high voltage will cause holes in the films
due to gassing, however.  Too high a temperature is also undesirable; some
                                                     o
paints will flocculate at temperatures approaching 90 C.
     At high pH, there is a reduction in the deposition; if the pH drops be-
low the isoelectric point, the entire tank of paint can coagulate.
     If the solids content in the tank is too high, the voltage cannot "wring"
the moisture from the deposited film; if the bath is too dilute, then the film
will be thin, below one mil.
     For successful operation of an  EDP system it is necessary to monitor on a
regular basis:  voltage, amperage, pH, temperature, and solids.  For satisfac-
tory appearance of the final finish, it is  important to rinse the parts thor-
oughly after painting; the final  rinse should be with deionized water.
     Parts painted with EDP are normally baked  from 15 to  30 minutes at 163-
190°C  (300-400°F), with the higher  temperatures being used for auto pri-
    3,5,16,20,21
mers  '  '   '
      Solvent emissions are related  to both paint composition and production
rate.   The greater the quantity of  solvent in  the water-borne coating, the
greater the air emissions.  Solvents used are  high  molecular weight alcohols,
added to aid in fusing the paint  particles into a continuous film.
      Production in terms of square  meters per hour  has  an  influence on emis-
sions:   the higher the rate,  the  greater the emissions.  This rate depends on
the area of the parts, their  spacing on the conveyor,  and  the conveyor speed.
      Emissions are also  influenced by coating thickness; thicker coatings will
carry a greater amount of solvent.   The thickness depends  on the "throwing
power" used during the  deposition - i.e., the voltage and  amperage  applied
across the electrodes.   Normally there are no transfer efficiency problems

                                      4-7

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with electrodeposition; nearly all of  the paint solids are transferred to the
part.  There can be dripping associated with dragout, but this material is
recovered in the rinse water and  returned to the dip tank.
     The emission reduction capacity of EDP is related to the solvent content
of the paint, and the percent solids of the paint  as the part emerges from
the bath, both of which influence the  weight of solvent associated with apply-
ing a given weight of dry paint solids. Of course the percent emission re-
duction is also related to the emission level  for  the solvent-borne primer
being replaced, which can also vary, depending on  the percent solvent in the
paint and the transfer efficiency.
     EDP is not used alone, however, for most  automotive  and light-duty truck
primers.  Most employ a  "primer  surfacer",  commonly called  a guide coat, to
build film thickness and  permit  sanding between  the primer  and topcoat.  These
primer surfacers are applied  by  spray coating and can be  either  organic-
solvent or water-borne; because  of the organic solvent  content,  they have a
significant effect  on  the overall solvent emissions for primer operations
 (see Chapter  6 - Emission Control Systems).
4.1.3.  Water-Borne Spray
     Since  the application of water-bornes by EDP is limited to  one-coat pri-
ming, auto  manufacturers have chosen  spray coating for applying water-borne
 topcoats22'23'24-   Two General Motors plants are in production with water-
 borne topcoats22'23,  and there is one Ford Motor Company experimental line  in
 Canada
      The topcoat materials used  are thermosetting acrylics with 25-35 volume
 percent solids7'2'24'25,  and a ratio  of from 82/18 to 88/12 water to organic
 solvent in the volatile portion  of  the paint.  These compositions correspond
 to organic solvent to solids ratios in the range  of 0.22-0.54 by volume.
      The general finishing processes  for both General Motors plants are
 similar22'23.  The finishing process  at the General Motors  Southgate plant
 has been described in detail25;  the steps  are as  follows:
                                       4-8

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     1.    A conventional eight-step cleaning and phosphating -
          no dry-off.
     2.    An electrodeposition primer application following by
          baking.
     3.    Application  of sealers.
     4.     Painting with an epoxy ester based water-borne spray
           primer surfacer  (guide coat) using automatic and
           manual air spray.
     5.     Flash-off for 5-8 minutes in a 77-93°C  (170-200°F) tunnel.
     6.     A partial bake.
     7.     Application of interior paint plus additional sealant.
           The paint used here is a water-borne acrylic enamel.
     8.     Final baking of the primer.
     9.     Wet-sanding and masking of the interior.
     10.   Application of the water-borne acrylic enamel topcoat
           in two separate booths with a flash-off and set-up bake
           after each application.
     11.   Painting of the trunk with a water-borne emulsion coating.
     12.   Itouch-up and accent color application in a third booth.
     13.   A final bake at 163°C (325°F) for 30 minutes.

     In addition to automotive top coats, water-borne paints are also being
used in the auto industry to finish components such as wheels and en-
     26,27,28
gxnes        .
     As with any water-borne, the emissions of volatile organics into the
air is dependent on the percent solids and organic solvent in the paint, and
the thickness of the coating that is applied.
     In addition, the emissions are influenced by the number of units pro-
duced per hour and the surface area of each unit.
                                   4-9

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     One critical factor in any spray operation, a factor that can have a
serious effect not only on emissions but on cost and secondary pollutants,
is transfer efficiency - that percentage of the spray paint that actually
deposits on the part.  With the conventional spray being used, transfer
efficiencies are probably in the range of 30-60 percent.  If electro-
                                                                29
static spray were used, transfer could increase to 70-90 percent  , and
                                                                     . ,  30
technically electrostatic application of water-bornes presents no problem  .
4.1.4. Powder Coating
     Powder coating, although considered here as a new coating method, has
                            2ft
been in use since the 1950's   .  Fluidized-bed  coating began in the early
1950's and electrostatic spray  in  the early  1960's.  Powder coating, re-
gardless of process, involves the  application of 100 percent solid materi-
als in dry powder form; no  solvents are used, although traces of organics
can be driven off from  the  resins  during curing.
     Powder coating materials are  available  as  both thermoplastic and ther-
mosets, but the  thermosets  are  the only materials  of  interest here  for thin,
high-performance finishes  for  autos and  light-duty trucks.
     Powder coating is  being used  throughout the  industrial  finishing  indus-
try for such diverse painting  applications as metal  furniture, wire goods
                                                                     32
 (baskets, racks, and  shelves),  piping and tubing,  fencing and posts  ,
                                   33              34
garden tractors  and  lawn equipment  ,  and bicycles  .   In the automotive
industry  in the  United States,  powder coating has been used  on two pilot
lines for applying topcoats  -  one at a General Motors Company auto assem-
bly plant in Framingham,  Massachusetts35,  and one at a Ford  Motor Company
assembly  plant in Metuchen, New Jersey36.   Powder coatings are also being
applied to  under-the-hood parts such as oil filters and air cleaners
as well as  bumpers,  trailer hitches, and emergency brake cable guides
40,41
      •
      In Japan, Honda is reported to be in production topcoating cars with
powder at the rate of 55 units per hour, while Nissan Motor Company plans
 to begin  applying powder topcoats to trucks sometime during 1977   .  Nissan
 is constructing a new plant at Kanda, North Kyushu, where the powder top-
 coats will be applied to light-duty trucks at the rate of 2,100 units per
                                     4-10

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month.  Trucks will be finished in one of eight colors; all colors will
                                    118
be applied from a single spray booth
     The leading materials in powder coating today are thermosetting epoxy
             42
and polyester  ; these materials provide hard, smooth surfaces that have
excellent adhesion to most metallic substrates.  The coatings are tough,
with good resistance to abrasion and chemicals.  Thermosetting acrylic is
of lesser importance but is growing in usage.
     The three significant application techniques in use commercially for
applying powder coatings are:  fluidized bed, electrostatic fluidized bed,
                       43
and electrostatic spray  .  Of these, only the last is of interest here
for the application of thin, uniform coatings to large parts.
     The electrostatic powder spray process is shown schematically in Fig-
                                        44
ure 4- 2 and can be described as follows   :
          Powder is drawn from the hopper and is carried to the gun
     by compressed air.  As the powder passes through the gun, it
     picks up an electrostatic charge from the electrodes in the tip
     of the gun.  The part to be coated is grounded and at a lower po-
     tential than the powder particles.  When an electrostatic field is
     generated between the tip of the gun and the part, the powder par-
     ticles are attracted to the part and adhere.  As the coating
     forms, the part becomes insulated and the deposited powder begins
     to repel additional particles.  The result is a uniform film rela-
     tively free of voids.
          The powder adheres to the part until it is fused to the surface
     and heat-cured in the oven.  Film thickness normally varies from
     1.5 to 6 mils (0.038 to 0.127 mm), depending on the preheated tem-
     perature of the part, the particle size of the powder,  the elec-
                                                    45
     trical potential, and the duration of the spray   .

     Electrostatic spray units range from relatively small manually oper-
ated job-shop, touchup models up to large production units with several
automatic reciprocating guns and complex powder recovery systems.  The basic
                                      46
components of all units are as follows  :
                                    4-11

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                           Figure 4-2.  SCHEMATIC OF ELECTROSTATIC  POWDER SPRAY  PROCESS
                                                                                        145
4-
H
           a.     Powder hopper
           b.     Compressed air control
           c.     Powder injector and tube
           d.     Spray gun with integral high-
                  voltage generator
e.    Deflector plate
f.    Part to be coated
g.    Ground
h.    Power supply
i.    Electrode

-------
      (a)    Basic console.   The console or cabinet contains  the
     power  supply which converts line current  to high-voltage di-
     rect current; the air supply with drier;  the powder reservoir
     with vibrator and air fluidizer to keep the powder fluidized  so
     that it will flow through the hose to the gun; and the control
     module for  regulating air volume and pressure, voltage,  amper-
     age, vibrator frequency in the powder reservoir,  and powder
     flow rate.
      (b)    Powder spray gun.   A trigger switch on the gun activates
     both powder flow and transfer of voltage. A deflector mounted
     in the nozzle of the gun controls the spray pattern.  Connected
     to the gun  are  the material hose and high-voltage cable.
            Automatic guns are similar in design construction and  op-
     eration,  but are turned on and off by a master switch on the
     control panel.   Automatic guns are often  mounted  on variable-
                                                 47
     speed/variable-stroke vertical reciprocators   .
            The  number of guns in a unit generally varies from one to
     twelve, and is  dependent on the extent and rate of travel (re-
     ciprocating guns) of the guns and the conveyor speed.  It is  bet-
     ter to use  several guns at a moderate output since excessive  out-
     put from  a  gun  will lower deposition efficiency,  increase over-
     spray, and  clog the guns
     (c)    Spray booth.   Powder spray booths are much simpler  in de-
     sign than normal paint booths.  The floors are sloped in order to
     recover oversprayed powder.  Guns are normally mounted in the
                                             t
     side walls  of the booth; openings  are kept small to minimize
     powder loss.  The interior walls are vertical and free of projec-
     tions in  order to prevent hang-up of powder  .
            The dimensions of the booth are governed by the part size,
     conveyor  speed, and the number of guns.

     Figure 4-3  shows a typical booth with recovery system and  recipro-
cating gun.   Air flow from top to bottom in the booth helps scavenge over-
sprayed powder and carry it through the bottom of the booth.
                                   4-13

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Figure 4-3.  SOPHISTICATED RECOVERY SYSTEM
                                          140
 a.   Reservoir and controls
 b.   Elevator-mounted industrial spray gun
 c.   High-voltage electrode and deflector plate
 d.   Part being coated
 e.   Grounded conveyor
 f.   Powder tube and high-voltage cable
 g.   Spray booth
 h.   Powder recovery unit
 i.   Exhaust fan
 j.   Exhaust line for powder  recovery
 k.   Clean air returned  to booth
 1.   Clean air exhausted to atmosphere
                     4-14

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     (d)     Recovery  system.    A recovery  system is also shown in
     Figure 4-  3  .  Recovery  of oversprayed powder is the key to
     economical powder coating.  Most systems comprise one or more
     cyclones with or without an added tube or bag filter.  The cy-
     clones collects  the larger particles, approximately 90 percent,
     while the  filter captures the fines.   Recovered powder can be
     screened to  remove foreign matter and agglomerates, mixed with
     virgin powder, and returned to the reservoir.  Recovery effi-
                                      49
     ciencies run 98  percent  or better  .
            Exhaust air which is not reused in the booth can be fil-
     tered and exhausted back into the building.
                                                                   49,50,51,52,53
     Hormal operating parameters for powder spray units are as follows:

            Preheat                  None
            Conveyor speed           0.91-7.62 meters/minute
                                      (3-25 feet/minute)
            Electrical output        70-90 KV DC  (maximum)
            Polarity                 Positive or negative
            Compressed air output    1416-7080 cu cm/sec at
                                     146-488 kg/sq meters  (30-
                                     100 psig)
            Powder output            0-36 KG  (0-80 Ib) /hour/gun
            Powder cure              171-227°C  (340-440°F) for
                                     10-30 minutes

     The voltage on most units is variable up to 90 KV, which permits con-
trol of film thickness  .  A low voltage will allow penetration into holes
and recesses.  Although polarity is often variable, most powders are
sprayed successfully with a negative charge.  An adjustable deflector on
the gun also controls the spray pattern.  A narrow pattern aids penetra-
                                                       54
tion while broad clouds are useful for large flat areas   .
     Powder deposition on the parts can reach 85 percent on large  flat  sur-
                                                                           48
faces, but irregularly shaped objects result in reduced transfer efficiency   .
                                   4-15

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Deposition can be as low as 30 percent on wire products such as racks and
baskets, but of course this overspray is almost always recovered
     At the present time the most  significant use of powder for auto fin-
ishing is a large pilot line being used by  the Ford Motor Company at
Metuchen, New Jersey, for applying topcoats.  This line has been success-
fully finishing Pintos in solid  colors since 1973  .  The powder coating
installation has been placed adjacent to the main assembly line.  Prior to
the powder finish, cars are pretreated and  primed in an identical manner
to cars receiving conventional finishes.  Cars to be powder coated are
moved from the main assembly line  and are painted by electrostatic spray
in one of two booths.  The bulk  of the coating is applied with automatic
powder guns.  Inaccessible areas are hand sprayed.  For good flowout, a
6.3 to 7.6 x 10~2 millimeter  (2.5  to 3.0 mil) coating is applied, which is
equivalent to approximately 2.9  kilograms  (6.5 pounds) of coating per car   .
     To fuse and cure the coating, the  cars are  baked at 177°C  (350°F) for
30 minutes.  Following  finishing and baking,  the cars are moved back into
the main assembly  line.
     The cars are  finished  in  one  of eight solid colors.  Overspray  is ap-
proximately  35 percent36, most of  which is recovered.  At the present time
recovered powder is  not segregated by color but is  used  for finishing small
auto components at another  location.
     Ford has not  successfully demonstrated the application of  "metallic"
paint  from powder.   In applying solvent-borne paint the viscosity is low
enough for  the metallic flakes to turn and orient parallel  to  the surface
as  the paint dries.   With powder,  however, the molten polymer  is  viscous
and the flake keeps  a random orientation, making the appearance less aes-
thetically  pleasing.
     On a typical auto assembly line the color of the topcoat to  be applied
 is  determined by individual orders, which come completely at random. This
 requires a color change after each  car.  The time allowed for the change
 is  dictated by the line speed, which permits approximately 13 seconds be-
 tween cars.
                                   4-16

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     Color changes cure normally difficult and time-consuming, requiring
removal of essentially all powder from the booth, lines, and guns
Color contamination cannot be tolerated or the finished coating will con-
tain particles of dissimilar color,  giving a "salt-and-pepper" look.
     Through modification of their equipment, Ford has been able to achieve
the desired 13-second color change.
4.1.5.  Higher Solids Coatings
     Higher solids coatings hold the potential of being able to apply the
same weight of paint solids with reduced emissions of volatile organic sol-
vent.  Such coatings fall in the general categories of radiation curable
systems, higher solids nonaqueous dispersion coatings, "high-solids coatings",
and powder coatings.  Powder coatings have already been discussed  (Section
4.1.4  -  page 4-10).  Radiation-cured coating involves the photocuring of
mixtures of low molecular weight polymers or oligomers dissolved in low mo-
lecular weight acrylic monomers.  These formulations contain no solvent car-
riers and can cure using either electron beam or ultraviolet light sources to
essentially 100 percent solids coatings   '    '    .  These coatings have
generated little interest in the auto industry, presumably because of the
health hazard associated with the spray application of these relatively toxic
monomer mixtures and the difficulties involved in obtaining adequate cure of
the paint when applied to irregularly shaped substrates.
     Medium-solids nonaqueous dispersion coatings are being used in the auto
industry.  Nonaqueous dispersion coating vehicles are polymer dispersions of
particles in the size range of 0.01  to 30 microns in diluents which are non-
solvents or at least very poor solvents for the resin.  The diluents are
liquids other than water and are usually limited to the more common hydrocar-
bons, alcohols, esters, etc.  At nonvolatile contents potentially as high as
40-60 volume percent, NAD products form easily pourable liquids of relatively
low viscosity, the viscosity being essentially independent of the molecular
                     122
weight of the polymer
     During the early 1970's NAD coatings began to generate  interest as
spray topcoats for automobiles, both domestic and foreign.   As a result,
                                     4-17

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several companies are now using NAD on auto and truck assembly lines for
the application of both lacquer and enamel topcoats   '
     At the present time in the auto  industry, topcoats are being applied
either from lacquers - both dispersion and solution  - or from nonaqueous
dispersion enamels.  A small percentage  of the autos produced are still be-
ing finished with solution enamel paints.
     Most of the autos and light-duty trucks produced at General Motors,
representing about half of the domestic  production, are finished with lac-
quers.  These lacquers range  from approximately  12-18 volume percent solids
applied, depending on whether  the lacquer is a nonaqueous dispersion or a
solution.
     Most of the vehicles not produced  by General Motors are manufactured by
Ford, Chrysler, and American Motors,  and are being topcoated with NAD enamel
paints.  These paints vary in their degree of dispersion; in fact,  some
come very close to being solutions.   Solid color NAD paints, which  are
relatively low in dispersion,  are  supplied at  a solids  content  generally in
the range of  39-42 volume percent.   Metallic NAD paints tend to be  higher
in dispersion than the  solid  colors and are normally supplied at  33-37  vol-
ume percent solids123'124:   these  paints are then diluted with  solvent  for
application.
      The NAD paints  in use in the industry have essentially the same  organic
solvent contents  as  their solution enamel counterparts.  Although higher sol-
ids contents  are  technically feasible,  these have not been realized in the
auto  industry due to application and appearance problems.  The  present NAD
paints, therefore,  are inherently no less polluting than solution enamels.
      Most  of the impetus behind the  switch to NAD coatings was  due to the
ability of the dispersion coating to build sufficient film rapidly without
the  sagging and solvent popping usually associated with solution enamels and
 lacquers.   Use of NAD lacquer also allowed spray application at almost
double the usual solids for solution lacquers, thereby cutting the number
 of coats required by 40-50 percent.  These improved application perform-
 ances made it possible to increase line speeds by 40-50 percent without capi-
                                      •  •   \
 tal investment in equipment or facilities
                                    4-18

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     High-solids coatings are a relatively new family of materials that is
currently being developed and investigated in the automotive, can, coil,
and applicance industries.  The attraction of such coatings seems based on
a low solvent content, the promise of application with conventional finish-
ing equipment, and the promise of energy savings through the use of more
reactive systems.  Although the traditional definition of high solids as
                                                                       125
specified in "Rule 66" indicates no less than 80 volume percent solids    ,
most of the people in industry are considering everything from 60 percent
to 100 percent.
     There will very likely be no radically new resin binders associated
with high-solids coatings; most are modifications of their low-solids
counterparts.  The coatings can be categorized as either two-component/
ambient-curing or single-component/heat-converted materials.
     The coatings that are of the most immediate interest are the two-
component/ambient-cure materials; they offer not only a reduced solvent
content but also a tremendous energy  savings since they require little or
no baking.  Resin systems being investigated include epoxy-amine, acrylic-
            *         126,127,128,132
urethane, and urethane
     The heat-converted,  high-solids  coatings being developed include
epoxy, acrylic, polyester, and alkyd   .  Most contain reactive hydroxyls
or carboxyls which allow crosslinking with amino compounds such as  hexa-
methoxy methylmelamine.   These coatings are baked at temperatures similar
to low-solids counterparts - nominally 150-175°C  (300-350°F).
     The most significant problem with high-solids coatings  is the  high
working viscosity of  the high-solids  solution  (i.e., 60-80 volume percent)
128.  The viscosity can  be controlled to  some degree by reducing  the molecu-
lar weight of the base polymer or by  using reactive diluents, but these
techniques can result in a greatly altered product with inferior proper-
ties.  A more effective  means of reducing viscosity is to heat the  coating
                      128
during the application
     Heated high solids  can be applied as airless, air, or  electrostatic-
                                           129
ally sprayed finishes from heated equipment    ,  and can be  roll-coated.
                                    4-19

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While it is generally agreed  that high-solids coatings hold a great deal of
promise, they are still  an emerging technology and must be considered to be
still in their infancy133.  Of  the  approximately  1514 million liters (400
million gallons) of industrial  finishes  consumed  in  1975, less than 1 per-
          ...   ,. , 131
cent were high solids
     Major uses  for high-solids coatings are in coil and  can coating    ;
there is no use  of high-solids  coatings  in the automotive industry at this
time.

4.1.6. Carbon Adsorption
     Carbon adsorption as a technique for solvent recovery has been in  use
commercially  for several decades.   Applications  include recovery of solvent
from dry cleaning,  metal degreasing, printing operations, and rayon manu-
facture57  - as well as industrial finishing58'59'60.  While  the  recovery
of coating solvents from industrial finishing operations using adsorption
is not  without  some technical problems,  the process is essentially no  dif-
ferent  from any other being used for solvent recovery.
     The  adsorption process is made possible through the use of  specially
 "activated" carbon, which has a fine pore structure and therefore a tre-
mendous surface area per unit weight -  as great  as  1,000,000 square meters
per kilogram61.  Through secondary bonding  and capillary action, this car-
bon can adsorb onto its surface large quantities of volatile organics.
      A typical adsorption unit is  shown in  Figure 4- 4 .  Air containing
 the organic vapors is passed through a  filter to remove  particulates and
 then through a cooler to reduce the temperature  of  the gas to no greater
 than 38°C.  A blower  forces  the vapors  through one  of  two adsorbers, packed
 with activated  carbon.   Two  units  are normally adequate  for continuous op-
 eration; one unit can be operated  while the other is being regenerated.
      During  the course  of  operation,  the carbon  becomes  saturated with or-
 ganics, and  it  is necessary  to regenerate.   The  organics are desorbed  from
 the carbon by passing either steam or hot gases  through the bed  .  The re-
 volatilized  organics  are then recovered downstream in a condenser.  The
                                    4-20

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t
to
                             Figure 4-4.  DIAGRAM OF AN ACTIVATED-CARBON ADSORBER SYSTEM138
Vapor laden
air inlet
                      Filter
                       and
                      Cooler
                                                       Adsorber No.. 2
                                              Low-pressure
                                                 steam
                                                                              Stripped air
                                                                              to atmosphere
                                                                                                   Recovered
                                                                                                      solvent
                                                                            Water
                                                         Stripped  air
                                                         to atmosphere
                     From Adsorption, by Mantel1.  Copyright 1945, 1951 by the
                     McGraw-Hill Book Company, Inc.  Used with permission of the
                     McGraw-Hill Book Company.

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regenerated gas can also be directly incinerated, which is always the case
for hot gas regeneration.
     For most industrial applications, adsorption is used to recover sol-
vents for reuse.  Coating solvents used  in industrial finishing, however,
are normally complex mixtures of  aliphatics, aromatics, esters, ketones,
alcohols, etc.  '  .   To recover such solvents with sufficient purity for
reuse would require costly fractional distillation, which is probably not
economically feasible.  The most  practical use for these solvents, since
they are all flammable, is incineration. The heat generated can be used
                                                                       68
to produce some of the steam necessary for regeneration of the adsorber
     There are several variables  which effect the performance of carbon ad-
sorbers and most are related to the  adsorptive capacity of the carbon.
This adsorptive capacity, the weight of  solvent  that can be retained on a
given weight of carbon, can be  expressed as  follows   '   :

                                           vm
            Adsorptive capacity  OC 	
                                      T  log (C0/C±)
                q  solvent
            in	
                g  carbon

     Where V  = liouid molar volume of pollutant at normal boiling point
            m
           T  = absolute  temperature
           C0 = concentration of saturated vapor
           C- =  initial  pollutant vapor concentration into  adsorber
     The liquid molar volume of a given solvent is related to both its mo-
 lecular weight  and density at the boiling point.  In general, the greater
 the Vm of the solvent the higher the molecular weight and therefore  the
 boiling point.   In other words, carbon  will generally have a greater ad-
 sorptive capacity for higher boiling solvents.
      For these compounds with relatively high Vm, adsorption will occur,
 but because of their low vapor pressures desorption becomes difficult.
 Generally solvents with a molar volume  of between 80 and 190 cm3/mole pre-
 sent no problems with adsorption and regeneration  .  Fortunately most of
                                    4-22

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the solvents used in industrial finishing fall within this range.  Table 4-2
lists some of the problem solvents for carbon adsorption.  Of the solvents
listed, only propanone (acetone) and nonane (a component of most grades of
mineral spirits) are commonly used in automotive primers and topcoats.
Acetone, when used, is normally in small quantities  (less than 10 volume
percent), and the possibility of substitution seems likely; mineral spirits
are used in substantial proportions in many of the alkyd and acrylic enamels
but should be effectively desorbed with either superheated steam or hot gas

           Table 4-2.  PROBLEM SOLVENTS FOR CARBON ADSORPTION
Solvent Vmcm /mol
Dodecane
Undecane
2-Ethylhexyl acetate
Decane
Butyl carbitol
Nonane
2 , 6-Dimethyl 4-heptanone
Diethyl cyclohexane
Butyl cyclohexane
1-Methyl pentyl acetate
Diethyl cyclopentane
Nitroe thane
Propanone
Dichlorome thane
Ethanol
Nitromethane
Methanol
274
251
238
229
213
207
207
207
207
194
192
75
74
65
61
53
42
Boiling
°C ('
216
195
199
174
231
150
174
174
152
116
56
40
78
101
66
Point
(421)
(383)
(390)
(345)
(448)
(302)
(345)
(345)
(307)
(239)
(133)
(104)
(173)
(214)
(149)
           Source:  Stern, A.C.  Air Pollution.   Academic
                    Press, New York.  Vol.  II,  2nd Edition,
                    Chapter 16  (1968)
                                    4-23

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     Temperature of the inlet gas  stream also affects adsorptive capacity;
the higher the temperature the lower  the adsorptive capacity.  At tempera-
tures in excess of approximately 38°C,  solvents which are normally adsorbed
and desorbed with no difficulty will  be poorly retained by the carbon 3' 4.
Low inlet vapor concentration also has  an adverse effect on adsorptive ca-
pacity  , and of course capacity is also affected by the surface area of
the carbon as influenced by particle  size and degree of porosity.
     Although adsorption will generally remove 90 percent or more of the
volatile organics from a gas stream,  this performance tends to deteriorate
with time as the active sites on the  carbon  surface are depleted.  This is
shown graphically in Figure 4- 5  . Although the performance begins to de-
teriorate after 500 minutes  (i.e., effluent  concentration starts to in-
crease) , the carbon is not completely exhausted until 1000 minutes have
elapsed.  The overall performance  of  an adsorber, then, is largely depend-
ent on when and how completely the unit is regenerated.  If the unit in the
example given is regenerated after every 500 minutes, the overall perform-
ance will be quite high, but the cost of treatment will also be higher than
with longer cycle times as a result of  more  frequent regeneration.  Nor-
mally there will be some trade-off between cost and performance.
     The size of a given adsorber  is  determined by the adsorptive capacity
of the carbon and the quantity of  volatile organic to be removed.  Of
course the adsorptive capacity will depend on the Vm of the solvent or sol-
vent blend.  In the case of mixed  solvents,  the bed depth necessary to
adsorb each of the vapors can be estimated from the sum of the bed depths
necessary to remove each vapor if  it  were alone in the air stream
     The cross-sectional area of each bed is determined from the volume of
air that must flow through the unit.  A face velocity  (defined as flow
rate in CFM or cubic meters per minute  divided by the  cross-sectional
area) of 9.1 to 30 meters per minute  (30 to  100 feet per minute) is nor-
                                                           77
mally used to avoid excessive pressure  drop  through the bed   and to get an
                                                            78
effective utilization of  the equilibrium capacity of the bed   .
     In the auto and light-duty  truck industry, the emissions of greatest
concern come from two general  areas:   spray  booths  for solvent-borne
                                     4-24

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                          Figure 4-5.   EFFLUENT CONCENTRATION CURVE OF BUTANE VAPOR

                                     FROM AN ACTIVATED CARBON BED AS FUNCTION OF TIME
                                                                    137
*>.


10
in
§
•H
•P
id
               q
               0)
               u
               c

               8
                   100
                    80
                    60
      40
                    20
                      tfa - 600


                       when

                      Cfa  - 0.01  C.
                                                                    J.
                                                                         _L
200      400
                                                 600
                                            800
1000
1200    1400
                                                    Time  (t),  min.

-------
primers, guide coats  (primer surfacer, used over EDP primer), and topcoats;
and their respective bake ovens.
     Automotive spray booths present  unique adsorber design considerations
because of the very high air flow rates  that are employed.  Flow rates as
high as 94 to 186 cubic meters/sec (200,000 to 400,000 CFM) are required
for operator safety in manned booths  and for prevention of cross contamina-
tion of adjacent car bodies from overspray '    .   According to Radian,
three adsorbers 6.1 meters  (20 feet)  in diameter would be sufficient to
                                                                    jnt
                                                                    ,86
                                   85
handle air flows of this magnitude  .  While no such units are presently in
use in the auto industry,  systems of this size have been  constructed
     One consequence of this high air flow is that the organic solvent va-
pors are diluted to a  very low level, normally 50 to  200  ppm, which is
equivalent to or less  than 2 percent of the lower explosive  limit  (LED .
This low concentration lowers the adsorption capacity of  the carbon and
requires a larger  adsorber unit than would be required to remove the same
quantity of  solvent from a more concentrated air stream with lower air flow.
Reduction in air flow  with increased vapor concentration  is  technically
feasible, however.  DuPont conducted a study to reduce air flow and their
                                   87
results were summarized as follows   :
          "By maximizing use of automatic painting,  reducing booth
     length, avoiding  longitudinal mixing between manual  and automatic
     painting zones, and staging of solvent-laden air exhausted  from
     manual  zones  through automatic zones, it has been demonstrated on
     a commercial  automotive production line that only close to  10 per-
     cent of the  currently discharged air needs to  be treated  to meet
     this 3,000 Ib/day limitation per source."
     Adsorption systems for spray booth emissions must also  be designed  to
handle air with a high water vapor content.  This high humidity  results  from
the use  of water curtains on both sides of the spray booths  to capture
overspray.   Although carbon preferentially adsorbs organics, water will
compete  for  available sites on the carbon surface.   Generally the relative
                                                                 88
humidity should be kept below 80 percent to minimize the problem  .
                                     4-26

-------
     The exhaust from the spray booths, particularly during periods of cool
                                                        89
ambient temperatures, can reach saturation with moisture  .  One solution to
this problem would be to preheat the moisture-laden air to lower the relative
humidity to below 80 percent; a 4-5°C heating would be sufficient
     Prior to adsorption, particulates from oversprayed paint would have to
be removed from the air streams, since this material will coat the carbon or
plug the interstices between carbon particles.  Such plugging would destroy
efficiency and increase pressure drop through the bed.  Such particulates
                                              88
can be removed by using either a fabric filter   or the combination of a cen-
                                                    87
trifugal wet separator plus prefilter and bag filter  .
     Another variable which should be considered in designing an adsorber for
this application is the potential variability of the solvent systems between
different grades or types of paint.  Although all automotive spray paints
contain the same families of solvents  (i.e., glycol ethers, esters, C8 and
C9 aliphatics, etc.), the various paints employed can differ widely with re-
gard to specific compounds and relative proportions.  Solvent systems there-
fore could differ in their adsorptive capacity and, as a result, their abil-
ity to be removed by the adsorber.  On lines where different grades of paint
are used from time to time, adsorbers will probably have to be overdesigned
in adsorptive capacity.
     Ovens are the second important source of solvent emissions; it has been
estimated that approximately 10 percent of the volatiles from an organic
                                           QQ
solvent-based paint are emitted in the oven   ; the remaining 90 percent goes
off in the spray booth and flash-off area.
     The individual solvents in a spray booth tend to evaporate at different
rates.  The 90 percent of the solvent  that is emitted in the spray booth will
comprise a large percentage of  "low boilers"  such as acetone, butanol, tolu-
ene, etc.   The 10 percent which remains  in the  film  as it enters the oven
contains primarily less volatile solvents.    Therefore, adsorbers for ovens
will have to be designed to  handle a different solvent mix than is  found with
spray booths.  High-boiling  solvents may  not  be  consistently and  completely
stripped during regeneration, in which case more frequent  replacement of  the
carbon would be likely.   In  any case,  hot gas or superheated  steam regenera-
tion would probably  be  required  .
                                        4-27

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     In the oven, high temperatures and flame contact with the volatiles
can cause polymerization of degradation products into high molecular weight
resinous materials which can deposit on and foul the carbon bed.  Various
high molecular weight volatiles in the coatings such as oligomers, curing
agents, or plasticizers could cause a similar problem.  Filtration and/or
condensation of the oven exhaust air would be necessary prior to adsorption
in order to remove these materials.
     In order to get satisfactory performance, it will also be necessary to
cool the oven exhaust to a temperature no greater than 38°C.  Without cool-
ing, many of the more volatile organics will not adsorb but will pass
                    73 74
through the adsorber  '
4.1.7.  Incineration
     Incineration is the most universally applicable technique for reducing
the emission of volatile organics from industrial processes.  In the indus-
trial finishing industry these volatile organic emissions consist mostly of
solvents made up of carbon, hydrogen, and oxygen.  Such solvents can be
burned or oxidized in specially constructed incinerators into carbon diox-
ide and water vapor.
     Industrial incinerators or afterburners are ei her noncatalytic  (com-
                                                  104
monly called thermal or direct fired) or catalytic    .  There are sufficient
differences between these two control methods to warrant a separate discus-
sion for each.
4.1.7.1.  Thermal Incinerators -
     Direct-fired units operate by heating the solvent-laden air to near
its combustion temperature and then bringing it in direct contact with a
flame.  A typical unit is shown schematically in Figure 4-6.  In general,
high temperature and organic concentration favor combustion; a temperature
of 760°C  (1400°F) is generally sufficient for near complete combustion.
     To prevent a fire hazard, industrial finishing ovens are seldom oper-
ated with a concentration of solvent vapor in the air greater than 25 per-
cent LEL, and some operations - particularly ovens in the automobile and
light-duty truck industry - can achieve concentrations of only 5-10 percent
                                       4-28

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Figure 4-6.  FORCED-DRAFT SYSTEM ELIMINATING SOLVENT VAPORS

                    FROM SURFACE COATING PROCESS139
Process
  Fumes
 Coinbustor
                     Fan
                    Hot Clean
                      Gas  '
Cooled
Clean


7l

Gas
1
I/
1
II

                                        Single-Pass

                                        Heat  Exchanger
Stack
       Preheated Process  Fumes
                             4-29

-------
LEL.  These low concentrations are the result of high air flows necessary
in order to prevent escape of oven gas at oven openings and to prevent con-
densation of high-boiling organics on the inner surfaces of the oven
     Although there is a potential for more concentrated air streams from
spray booths (see page 4-26) , most presently operate at no more than 2 per-
cent of LEL.  Because of the low concentrations from both ovens and spray
booths, auxiliary heating is necessary in order to burn the vapors; this heat
is usually supplied in the form of natural gas, but propane and oil-fired
                     97,106
units are also in use
     The quantity of heat to be supplied is dependent on the concentration
of the organic in the air stream; the higher the  concentration the lower the
auxiliary heat requirement because of the  fuel value of the organic.
     For most solvents  the  fuel value is equivalent to 4.45 gram-kilocalor-
ies per cubic meter  (0.5 Btu/scf) , which translates into a temperature rise
of approximately  15.3°C (27.5°F)  for every percentage point of LEL that  is
incinerated.  For an air  stream with an organic  solvent content of 25 per-
cent of LEL, the  contribution from the  heat of combustion of  the  solvent
would be approximately  115  gram-kilocalories per cubic meter  (13  Btu/scf)
equivalent  to a temperature rise  of 345°C (620°F) at  90 percent combustion
efficiency.
      If the desired exhaust temperature is 816°C (1500°F) ,  then the  inlet
air stream would  have  to be heated to only 471°C (880°F) .   On the other
hand,  if the process air contains only 10 percent LEL,  as is  the  case with
the exhaust from automobile bake ovens, then the solvent would contribute
only 138°C (280°F)  and the air entering the incinerator would have to be
preheated  to 678°C (1220°F) in order to attain the same final temperature,
 817°C (1500°F).
      To make thermal incineration less costly, heat transfer devices are
 often used to recover some of this heat of combustion.  Primary heat re-
 covery is often in the form of a recuperative heat exchanger, either tube
                                      4-30

-------
or plate type, which is used to preheat the incoming process ftimes as il-
                         108
lustrated in Figure 4- 6    -  Units of this type are capable of recover-
                                                          108,109
ing 50-70 percent of the heat from the original fuel input
     A more satisfactory type of heat recovery device and one that finds
wide use in fume incineration equipment is the regenerative heat exchanger,
                                      108
both refractory and rotary plate types   .  Units of this type are capable
of heat recoveries of 75-90 percent110'111'11  .  In some cases secondary
recovery is also used to convert additional exhaust heat into process
                                            108
steam or to warm "make-up" air  for the plant
     There are several  operating parameters which affect the emission re-
duction potential of thermal  incinerators; following are the most signifi-
cant ones:
           For efficient  combustion of the hydrocarbons in  the air
     stream  it is necessary to have sufficient temperature  and residence
     time  in the  incinerator.  Figure 4-7   shows  the  combined effect
     of  these two parameters.  Insufficient  residence  time  results  in
     incomplete combustion and the  generation of carbon monoxide.   A
     residence time of 0.3-1.0 second is  typical.
           If the air stream to the incinerator contains sulfur-,
     nitrogen-, or  halogen-containing organics there will be a sec-
     ondary  pollution problem.   Incineration of these  materials  will
     produce sulfur and nitrous oxides and acids such  as hydrochloric
     and hydrobromic.   Fortunately  none of the solvents used  for auto-
     motive  finishing contain these elements.
           Solvent  type can also influence incinerator performance.
     While 593-677°C (1100-1250°F)  is adequate to combust most  solvent
     vapors,  certain organics require temperatures of  760-816°C  (1400-
      1500°F)  for  nearly complete oxidation
      In the  automobile and light-duty truck industry,  the two potential
 areas  for the use of incinerators are on the spray booths and on the ovens
 used for applying and baking body primers and topcoats.
                                   4-31

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                   Figure 4-7.  COUPLED EFFECTS OF TEMPERATURE AND TIME ON RATE OF POLLUTANT OXIDATION
                                                                                                137
          100
4-

I
l.l
to
       0)
       o
       11
       •1)
       r;
       o
t)
:)
H
i>
in
ID
a
        c
        Hi

        P
       r I

        0
       0.
           80
           60
           40
           20
                     Increasing

                      Residence

                         Time
             600
                  800
1000
1200
1400
1600
1800
                                                                                                    2000
                                          Increasing Temperature,  °F

-------
     The use of incinerators on bake ovens presents no significant prob-
lem; such add-ons are in place on ovens in several assembly plants, par-
ticularly in California  '    '   .  Typical emission reduction with such
units is over 90 percent.  Since the air exiting the ovens is generally at
a temperature of 120-150°C (250-300°F), the air preheating requirements
are less than they would be for air at ambient temperature.
     Incinerators on the bake ovens are controlling approximately 10 per-
cent of the solvent emissions; the remaining 90 percent of the volatiles
are emitted in the spray booth.
     Although incineration of the air from spray booths is possible, there
has been no application in the automobile and light-duty truck industry.
Because of the large air flow in  the  spray booths, as much as 95-190 cubic
meters/second  (200,000-400,000 CFM), and the resulting low solvent of the
air, 2 percent LEL or less, large quantities of natural gas or equivalent
fuel would be required to heat the vapor-laden air from near ambient to
the 700-760°C  (1300-1400°F) necessary to  effect near complete combustion.
     Reduction of the air flow with a resulting increase in vapor concen-
tration is technically feasible,  however, as was discussed previously on
page 4-26  .
     To handle the volume of air  flow, several large incinerators would
likely be required.  This could present problems of excessive weight and
lack of available space - particularly in cases where an existing source
is  being retrofitted.
     There is a  potential legal conflict  with incineration of spray booth
exhaust air.  NFPA No. 33-1973, Section 4.2,  (also OSHA regulation  Part
1910.107 FR, which is similar) specifically prohibits open flames  in any
spraying area; and Section 1.2 defines a  spraying area as: "(b) The  interior
of  ducts exhausting  from spray processes". However, Section 4.2.1  states:
"Equipment to process air exhausted from  spray operation  for removal of
contaminants shall be approved by the authority having jurisdiction".
Section 4.2.1 would  allow the use of  incineration for spray booth  exhaust
air so long as the local authority will approve.
                                    4-33

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4.1.7.2. Catalytic Incineration -
     This add-on control method makes use of a metal catalyst to promote
or speed combustion of volatile organics.  Oxidation takes place at the
surface of the catalyst to convert organics into carbon dioxide and water;
                    104
no flame is required
     A schematic of a typical  catalytic  afterburner is shown in Figure 4-8 .
The catalysts, usually noble metals  such as platinum and palladium, are
supported in the hot gas stream in such  a way that a high surface area is
presented to the waste organics.  A  variety of designs are available for
the catalyst, but most units use  a noble metal electrodeposited on a high
                                                              104 114
area support such as ceramic rods or honeycomb alumina pellets
     As with thermal incinerators, the performance of the catalytic unit
is dependent on the temperature of the gas passing across the catalyst and
the residence time.  In  addition, the efficiency of the afterburners varies
                                        114
with the type of organic being oxidized    .   These effects of temperature
and organic type are illustrated  graphically in Figure  4-9 .  While high
temperatures are desirable for good  emission reduction,  temperatures in
excess of  593-649°C  aiOO-1200°F) can cause  serious erosion of  the catalyst
              .  J_.   104,114
through vaporization
     The use of a  catalyst permits  lower operating temperatures than are
used in direct-fired units;  temperatures are normally in the  range of  260-
316°C  (500-600°F)  for  the  incoming air stream and 399-538°C (750-1000°F)  for
the exhaust.   The  exit temperature from the catalyst  depends  on the inlet
temperature,  the  concentration of organic,  and the percent combustion.  The
increase  in temperature results from the heat of combustion of  the organics
being  oxidized.
     As with thermal incinerators,  primary and secondary heat recovery can
be used to maximize auxiliary heating requirements for the inlet air  stream
and to reduce the overall energy needs  for the plant (see page 4-30).   Al-
though catalysts are not consumed during chemical reaction, they do  tend  to
deteriorate with time, causing a gradual loss of effectiveness in burning
 the organics.   This deterioration is caused:  by poisoning with chemicals
 such as phosphorous and arsenic, which  react with the catalyst; by coating
 the catalyst with particulates or condensates; and by high operating
                                   4-34

-------
temperatures, which tend to vaporize the noble metal.  In most cases cata-
lysts are guaranteed for one year by the equipment supplier   , but with
proper filtration cleaning and attention to moderate operating temperatures
the catalyst should have a useful life of two to three years   '   '
     Although catalytic incineration has the potential for reducing vola-
tile organic emissions, there are presently no units in regular use in the
                                        134
automobile and light-duty truck industry   .  An experimental unit is pres-
ently being evaluated by Ford Motor Company at a plant near Los Angeles,
and another unit installed in a Ford truck plant in Ohio has been shut down
                                              134
for some time due to a shortage of natural gas
     While catalytic incinerators can probably be adapted to baking ovens
with relatively little difficulty, the  use of these  add-ons for controlling
spray booth emissions will present the  same design considerations that were
discussed for thermal incinerators.  These factors include high air flow,
low vapor concentration, and the need to  incorporate a highly efficient
heat recovery system in order to minimize the need for auxiliary heating
of inlet air.
                                   4-35

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                      Figure 4-8

   SCHEMATIC DIAGRAM OF CATALYTIC AFTERBURNER USING

    TORCH-TYPE PREHEAT BURNER WITH FLOW OF PREHEAT

    WASTE  STREAM THROUGH FAN TO PROMOTE  MIXING
                        Clean Hot Gases
Catalyst
Elements
                                          Oven Fumes
                                           Preheater
                         4-36

-------
               Figure  4-9.   EFFECT OF TEMPERATURE ON
              OXIDATIVE CONVERSION OF ORGANIC VAPORS
                   IN  A CATALYTIC INCINERATOR'
                                             137
  100
3
               93       204      316       427
              (200)    (400)     (600)     (800)
 538      649
(1000)    (1200)
                        Temperature,  C  ( F)
                                4-37

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4.2.  EMISSION REDUCTION PERFORMANCE OF CONTROL TECHNIQUES
     Emissions can be controlled either through the use of "new coatings" or
"add-on" control devices.  The emission reduction associated with add-ons is
related to the ability of  the technique to either capture or destroy the or-
ganic solvent emissions.
     The emission reduction  potential  for new coatings, however, is related
to the quantity of volatile  organic material in the  "paint" before applica-
tion and cure.  The  emissions of any paint can be expressed quantitatively in
terms of the amount  of  solvent or  other volatile organic emitted per unit of
dry coating resin applied to the  substrate.   These  relative solvent emissions
 (RSE) can be derived from the weight percent solids of the coating materi-
als as  follows    :
                       RSE = % Organic Solvent/% Solids
      It  can be shown that the relative organic solvent emissions are  not only
 dependent on the solids content of the paint but rise exponentially as  the
                .   ,       128
 solids content is lowered
      The RSE of any paint/application method is also related to the deposi-
 tion or  transfer efficiency; that is, the percentage of the paint used  that
 actually deposits on the substrate.  For spray application, 30-50 percent  is
 normal when using air spray, while electrostatic spray will permit deposi-
 tions of 60-90 percent.  The RSE then can be expressed as:
            RSE = % Organic  Solvent/(% Solids)  (% Deposition)

 4.2.1.  Electrodeposition of Water-Bomes
      The electrodeposition  process,  as  described on page 4-2, has three pos-
 sible sources of organic solvent emissions:   the painted substrate as it is
 baked, evaporation  from the surface  of  the EDP tank,  and evaporation of or-
 ganic solvent from  the  cascading rinse  water and the  drain.
      The paint  films  on the substrates  are approximately 95 percent  solids
 as they emerge  from the bath.   The remaining 5 percent is  primarily water
 with only  3-5 percent of  the volatiles  as organic  solvent    .
                                      4-38

-------
     Another more likely source of fugitive emissions is escape of the or-
ganic solvent into the rinse water.  During operation, a portion of the paint
from the EDP tank is pumped through an ultrafilter; the permeate is used for
rinsing purposes, while the paint concentrate is returned to the tank.  Since
                                                                     143 144
ultrafiltration will remove nothing smaller than 500 molecular weight   '   ,
a portion of the water-miscible organic solvents such as alcohols and glycol
ethers142, which have molecular weights under 150, will likely end up in the
permeate.
     The permeate is then used for spray rinsing where the high surface area
of the spray is conducive to evaporation.  Depending on the water require-
ments for the closed loop system, some of the permeate is sent to the drain.
It is possible that some of the organic solvent may be lost in this manner.
     Since the quantities of organic solvent involved with EDP are quite
small by comparison with organic solvent-borne finishes, there has been no
effort to our knowledge to quantify these fugitive emissions.
     Since we have limited our discussions in this chapter to emission con-
trol techniques rather than overall systems, we have not included the impact
of guide coat or primer surfacer on the emissions  from a typical primer op-
eration  (see Chapter 6 - Emission Control Systems).
     The RSE, regardless of the source of the emissions, can be related to
the organic solvent content of the paint.  Most EDP paints are supplied with
an organic solvent to solids ratio of 0.06 to 0.12 by weight.  Since  transfer
efficiency is essentially  100 percent, the RSE  is  also  0.06 to 0.12.  These
RSE translate into percent emission reductions  of  96.6-99.2 percent when  com-
pared  against conventional lacquers and enamels  (Table  4-3).
4.2.2.  Water-Borne Spray
      In  considering emission reduction for water-borne  spray  coatings,  it is
necessary to assess the  effect of organic  solvent content  and solids  content
of  the paint as well  as  transfer efficiency for not only the  water-borne but
also  the  organic solvent-borne paint  which it is replacing.
      Table  4-4  presents  four representative comparisons.   If  a 25 volume
percent  solids  water-borne with an 82/18 water/organic solvent ratio by vol-
ume and applied by air spray were used to  replace a 38 volume percent solids
                                     4-39

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                          Table 4-3.  THEORETICAL EMISSION REDUCTION POTENTIAL

                              ASSOCIATED WITH VARIOUS NEW COATING MATERIALS

                                    FOR USE AS AUTOMOTIVE BODY PAINTS
Coating Type and
Percent Solids
By Volume
Solvent-borne
enamel, 28 v/oa
Solvent-borne
lacquer, 16 v/o
Powder coating,
97 to 98 v/o
Water-borne
Water-borne , 25 v/o
Water-borne , 25 v/o
High solids, 60 v/o
High-solids, 70 v/o
High solids, 80 v/o
Application
Method
Air spray
Air spray
Electrostatic
spray
Electro-
deposition
Air spray
Electrostatic
spray
Air spray
Air spray
Air spray
Transfer
Efficiency,
Percent
50
50
98
100
50
80
50
50
50
RSE, Organic
Solvent/Dry
Solids
(Liters)
5.14
10.50
0.021-0.032
0.06-0.12
1.44
0.96
1.33
0.86
0.50
Percent Emission Reduction
When Compared Against:
Lacquer,
16 v/o
solids
51.0
-
99.7-99.8
98.9-99.4
86.3
90.6
87.3
91.8
95.2
Enamel ,
28 v/o
solids
-
-
99.4-99.6
97.7-98.8
72.0
81.3
74.1
83.3
90.3
£*
O
           v/o = volume percent
Assumed 82/18 water/organic solvent ratio by volume

Assumed 88/12 water/organic solvent ratio by volume

-------
organic solvent-borne enamel also applied by air spray, then there would be
a potential emission reduction of only 72 percent.  On the other hand, if a
25 volume percent solids water-borne with an 88/12 water/solvent ratio by vol-
ume and applied by electrostatic spray were used to replace a 16 volume per-
cent organic solvent-borne lacquer applied by air spray, then there would be
an emission reduction of over 90 percent.
     General Motors estimates that when using an acrylic lacquer topcoat, its
two plants at Van Nuys and South Gate were emitting a total of 5.31 million
                                                           25
Kg  (11.70 million pounds) of organic solvent per model year   from topcoat
alone.  When these plants converted to water-borne topcoats, the emissions
for the topcoating operations were reduced to 1.30 million Kg  (2.86 million
pounds)25.  This represents an emission reduction of approximately 75 percent.
     One paint supplier estimates that an emission reduction in the range of
72-84 percent will result from substituting water-bornes  for organic  solvent-
borne enamels in spray applications.  See Table 4-4.
              Table 4-4.   REDUCTION OF ORGANIC SOLVENT EMISSIONS
                92,400 Square Meters  (1,000,000 Square Feet)
                      Sprayed at 65 Percent Efficiency
                   Approximately 30 Percent Volume Solids
Coating Type
Conventional enamel
Water-borne, 33 percent
organic solvent
Water-borne, 18 percent
organic solvent
Liters (Gallons) of
Organic Solvent
Emitted
10,931 (2,888)
2,861 ( 756)
1,560 ( 412)
a
Percent
Reduction
72
84
     Source:  SME Technical Paper FC74-639, 1974.  Page 3.

     a Further reductions of emissions are possible through the use of
       incineration.  Refer to Chapter 6, pages 6-2, 6-3, footnotes.
                                      4-41

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4.2.3. Powder Coating - Electrostatic Spray
     There is a tremendous emission reduction potential associated with the
use of powder coating materials which are nearly 100 percent solids.
     Although powders contain a small amount of volatile material, the quan-
tity does not usually exceed one-half of one percent  , which is equivalent
to an RSE of approximately 0.005.  The volatile emissions can be as high as
2-3 percent from baked polyvinyl chloride and epoxy coatings due to the par-
tial evaporation of plasticizers and coreactants, respectively  .  These per-
centage losses translate into RSE of from 0.020 to 0.031.
     With electrostatic spray of powder coatings, the powder which does not
deposit on the part to be painted is mostly contained in the spray booth.
With properly designed equipment, the oversprayed powder can be recovered,
providing overall transfer efficiencies as great as 98 percent.  The RSE
when adjusted for transfer efficiency becomes 0.021 to 0.032; and when com-
pared against conventional solvent-borne lacquers and enamels, there is a po-
tential emission reduction of greater than 99 percent  (Table 4- 3  ).
4.2.4. Higher Solids  Coatings
      To determine the emission  reduction potential associated with higher
solids coatings, the  RSE  of  various  solids content paints  in the  range of  30
to 80 volume percent  were compared against the  RSE of  both lacquer and solu-
tion  enamel  topcoat materials  (figures  4-10   and 4-11   ).   In preparing  these
estimates, the  deposition or transfer efficiency was also  taken into  consid-
eration.   Application by  air spray (50  percent  deposition) and  electrostatic
spray (80 percent  deposition)  was compared against  application  of conventional
solvent-borne paints with air spray.
      Figure  4-10 indicates that if a 16 volume  percent solvent-borne  lacquer
were replaced by a 35 volume percent solids NAD or solution enamel that was
 applied by electrostatic spray, there would be a potential emission reduction
 of nearly 70 percent.
      At the present time most high-solids coatings are being developed to
 achieve 70 volume percent solids or greater.  If the above solvent-borne lac-
 quer were replaced by a 50-60 volume percent high-solids paint applied by air
 spray, then a potential emission reduction of over 80 percent could be realized.
                                    4-42

-------
     Figure 4-11 shows that if 28 volume percent NAD coatings were replaced
by higher solids coatings of 60 volume percent solids, then an emission re-
duction of 74-84 percent would be possible.
     With the relatively high level of solvent dilution that would be associ-
ated with a 50 to 60 volume percent "high-solids" coating, it is concievable
that such paints could be sprayed without heated equipment and with rela-
tively little modification of existing equipment.
                                                         *
     Further comparisons have been presented in Table 4-3 .   If an 80 volume
percent high-solids coating were used to replace a 16 volume percent solvent-
borne lacquer, then an emission reduction as great as 95 percent would be
possible.
4.2.5. Carbon Adsorption
                                                              79,80,81
     Carbon adsorption is being used successfully in  the paper         ,
      82
fabric   , and can coating industries for controlling  solvent emissions.  Al-
though pilot studies have been conducted   , no  full-scale carbon adsorption
units are in place in the auto industry at this time.   It is generally ac-
knowledged, however, that an emission reduction of  85 percent or better  is
possible in the auto industry for the control of solvent vapors from spray
^  ^           62,62,64
booths and ovens

4.2.6. Incineration
      Incineration is currently being used  to control  solvent emissions  in  such
                             91       .  92       93,94      95,96           97,98
finishing  industries as paper   , fabric   , wire     , can      , and coil
                                               99,100
coating  as well as the auto finishing industry       .  Field investigations
indicate that  incineration, both thermal and catalytic,  is  capable of  remov-
                                                                   93,94,100,
ing at   least   90 percent of the solvents  from exhaust  air  streams
110,102,103,135

      Although  no catalytic  incinerators are  in regular use  in  the auto indus-
try at this  time134,  several bake  ovens in Ford Motor Company  plants  in
California are equipped  with thermal  incinerators   '    '    .   Typical units
operating at 760°C to 815°C (1400-1500°F)  have operating efficiencies of at
                 136
 least 90 percent
 *
   Page 4-40
                                   4-43

-------
               Figure  4-10.  EMISSION REDUCTION POTENTIAL  (PERCENT) WITH USE OF


                HIGHER SOLIDS COATINGS  IN PLACE OF 16 VOLUME PERCENT LACQUERS


                               (50 PERCENT DEPOSITION EFFICIENCY)
    100
n
o
-H
4>
O
s
§
 Ul

 (0
 4'
 t:
 a)
 0
 M
 a)
40
                   Volume Percent Solids Content  of Paints

-------
                      Figure 4-11.   EMISSION REDUCTION POTENTIAL (PERCENT)  WITH USE OF



                       HIGHER SOLIDS COATINGS IN PLACE OF  28 VOLUME PERCENT LACQUERS



                                     (50 PERCENT DEPOSITION EFFICIENCY)
            100
I

in
c
o
.1
*>
u
3
T1

I


§
-.1
Ifl
(II
         0)

         f)

         Vl
         OJ

         n.
    40-
                          H(
                    % Deposit:
                                                        50% De
position Efficiecy
                           30         40          50         60          70




                               Volume Percent Solids Content  of  Paints

-------
4.3.  REFERENCES
      1.    Schrantz, J.  Pollution Compliance with Water-Reducible
            Coatings.  Industrial Finishing.  49_(7):13, July 1973.
      2.    Henning, C.C. and M.J. Krupp.  Compelling Reasons for the
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      3.    Schrantz, J.  Off-Line Cleaning and Electrocoating of Truck
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      4.    Bardin, P.C.  Chevrolet Primes Truck Parts in Two 60,000-
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      6.    Levinson, S.B.  Electrocoat.  Journal of Paint Technology.
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      7.    Jones, F.N.  What Properties Can You expect from Aqueous
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      9.    Paolini, A. and M.A. Glazer.  Water Borne Coatings, A
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      10.   Steinhebel, F.W.  Water-Soluble Primer with Electrocoating.
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      11.   Pitcher, E.R.  Electrocoating Electrical Raceways.  Industrial
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                                    4-46

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14.   Schrantz, J.  How Ultrafiltration Benefits Equipto.
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15.   Schrantz, J.  UF Benefits Conveyorized, Batch-Type EDP
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                               4-47

-------
26.   Schrantz, J.  Water-Reducible Electrostatic  Spray Brings
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                                4-48

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39.   Cehanowicz, L.  The Switch is on for Powder Coating.
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                               4-49

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53.   Interrad/Gema 730 Automatic.  Data Sheet 128.  Interrad
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       letter dated March 12, 1976.
                               4-50

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65.   Danielson, J.A.  Air Pollution Engineering Manual.  Cincinnati,
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      McGraw-Hill,  1971  5-20.
                              4-51

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76.   Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold.  Evaluation
      of a Carbon Adsorption/Incineration Control System for Auto
      Assembly Plants.  Radian Corporation; Austin, Texas.  EPA
      Contract 68-02-1319, Task 46.  May 1976. 28-29.
77.   Package Sorption Device Systems Study.  MSA Research Corpora-
      tion; Evans City, Pennsylvania.  EPA-R2-73-202.  April 1973.
78.   Lund, H.F.  Industrial Pollution Control Handbook.  New York.
      McGraw-Hill, 1971.  5-21.
79.   Oge, M.T.  Trip Report - Fasson Company, Painesville, Ohio.
      DeBell & Richardson, Inc., Enfield, Connecticut.  Trip Report
      141.  July 21,  1976.
80.   Oge, M.T.  Trip Report - Brown-Bridge Mills,  Troy, Ohio.
      DeBell & Richardson, Inc., Enfield, Connecticut.  Trip Report
      140.  July 20,  1976.
81.   Solvent Recovery  Installations.   Supplier  Bulletin.  Vulcan-
      Cincinnati,  Incorporated;  Cincinnati, Ohio.
82.   McCarthy, R.A.  Trip Report  - Raybestos-Manhattan,  Incorporated,
      Mannheim, Pennsylvania.   DeBell & Richardson, Inc.,  Enfield,
      Connecticut.   Trip Report 77.  February 26,  1976.
83.   Gabris, T.   Trip  Report  - American Can  Company, Lemoyne,
      Pennsylvania.   DeBell  &  Richardson,  Inc.,  Enfield,  Connecticut.
      Trip Report  89.  March 11, 1976.
84.   Reinke,  J.M.   Ford Motor Company, Dearborn,  Michigan.   Letter
      to James  McCarthy, EPA-CTO,  dated November 1, 1976.
85.   Cavanaugh,  E.G.,  G.M.  Clancy, and R.G.  Wetherold.  Evaluation
      of a Carbon Adsorption/Incineration Control System for Auto
      Assembly Plants.   Radian Corporation; Austin, Texas.  EPA
       Contract 68-02-1319, Task 46.  May 1976.  54-58.
 86.    Lee, D.  Vic Manufacturing Company; Minneapolis, Minnesota.
       Letter to Bob Wetherold, Radian Corporation, dated March 17,
       1976.
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87.   Roberts, R. E. and J.B. Roberts.  An Engineering Approach
      to Emission Reduction in Automotive Spray Painting.   Pro-
      ceedings of the 57th APCA Annual Meeting.  _26_(4) :353,
      June 1974.
88.   Cavanaugh, E.G., G.M. Clancy, and R. G. Wetherold.   Evaluation
      of a Carbon Adsorption/Incineration Control  System  for Auto
      Assembly Plants.  Radian Corporation;  Austin,  Texas.   EPA
      Contract 68-02-1319, Task 46.  May 1976.  32.
89.   Sussman, Victor H.  Ford Motor Company; Dearborn, Michigan.
      Letter to R. G. Wetherold, Radian Corporation,  dated March 15,
      1976.
90.   Handbook of Chemistry and Physics.  Weast,  R.C. (ed.)
      Cleveland.  The Chemical Rubber  Company.  1964.  E-26.
91.   Oge, M.T.  Trip Report  - Hazen Paper  Company;  Holyoke,
      Massachusetts.  DeBell  & Richardson,  Inc.,  Enfield, Conn.
      Trip Report 134.    May  19,  1976 .
92.   McCarthy,  R.A.  Trip  Report - DuPont  Corporation,  Fabric and
      Finishes Department;  Fairfield,  Connecticut.  DeBell &
      Richardson, Inc., Enfield,  Connecticut.   Trip Report 130.
      April  30,  1976.
93.   Kloppenburg, W.B.   Trip Report - Phelps  Dodge Magnet Wire;
      Fort Wayne, Indiana.   DeBell & Richardson,  Inc.,  Enfield,
      Connecticut.   Trip  Report  113.   April 7,  1976.
94.   Kloppenburg, W.B.   Trip Report - General Electric Company;
      Schenectady, New  York.   DeBell  S Richardson, Inc.,  Enfield,
      Connecticut.   Trip  Report  106.   April 6,  1976.
95.   Gabris, T.  Trip  Report -  National Can Corporation; Danbury,
      Connecticut.   DeBell  & Richardson,  Inc., Enfield, Connecticut.
      Trip  Report 128.  April 27, 1976.
 96.   Gabris, T. Trip Report -  Continental Can Company, Inc.;
      Portage,  Indiana.  DeBell  & Richardson,  Inc.,  Enfield,
      Connecticut.   Trip Report 80.  March  3,  1976.
                              4-53

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97.     Gabris, T.  Trip Report - Roll Coater, Inc., Kingsbury,
        Indiana.  DeBell & Richardson, Inc., Enfield, Connecticut.
        Trip Report 76.  February 26, 1976.
98.     Gabris, T.  Trip Report - Litho-Strip Company, South Kilburn,
        Illinois.  DeBell & Richardson, Inc., Enfield, Connecticut.
        Trip Report 35.  January 22, 1976.
99.     Gabris, T.  Trip Report - Ford Motor Company, Truck Plant,
        Milpitas, California.  DeBell & Richardson, Enfield,
        Connecticut.  Trip Report 120.  April 8, 1976.
100.    Gabris, T.  Trip Report - Ford Motor Company, Auto Plant,
        Milpitas, California.  DeBell & Richardson, Inc., Enfield,
        Connecticut.  Trip Report 112.  April 7, 1976.
101.    Kloppenburg, W.B.  Trip Report - Rea Magnet Wire, Fort Wayne,
        Indiana.  DeBell & Richardson, Inc., Enfield, Connecticut.
        Trip Report 96.  March 17, 1976.
102.    Fisher, J.R.  Trip Report - Supracote, Inc., Cucamonga,
        California.  DeBell & Richardson,  Inc., Enfield, Connecticut.
        Trip Report 31.  January 16, 1976.
103.    Gabris, T.  Trip Report - American Can Company, Plant 025,
        Edison, New Jersey.  DeBell & Richardson,  Inc., Enfield,
        Connecticut.  Trip Report 6.  December 29, 1975.
104.    Lund, H.F.  Industrial Pollution Control Handbook.  New
        York.  McGraw-Hill, 1971.  5-27 to 5-32.
105.    Conversation between Fred Porter,  Ford Motor Company,
        Dearborn, Michigan, and EPA-CTO, Research  Triangle Park,
        North Carolina.
106.    Hydrocarbon Pollutant Systems Study.  MSA  Research Corporation;
        Evans City, Pennsylvania.  MSAR 72-233, October 20, 1972.   VI-4.
107.    Stern, A. C.  Air Pollution; Vol.  Ill, Sources of Air
        Pollution and Their Control.  New  York.  Academic Press,
        1968.
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108.    Lund, H.F.  Industrial Pollution Control Handbook.  New York.
        McGraw-Hill, 1971.  7-8 to 7-11.
109.    Heat Recovery Combined with Oven Exhaust Incineration.
        Industrial Finishing. 52(6);26-27.
110     Re-Therm Thermal Oxidation Equipment.  Product Bulletin
        REE-1051-975-15M.  Reeco Regenerative Environmental Equipment
        Company, Inc., Morris Plains, New Jersey.
111.    Young, R.A.  Heat Recovery:  Pays for Air  Incineration and
        Process Drying.  Pollution Engineering.  _7_(9) :60-61,
        September 1975.
112.    Can  Ceramic Heat Wheels  Do  Industry a  Turn?  Process
        Engineering.  42-43,  August  1975.
113.    Atherton, R.B.   Trip Report  -  Automobile Manufacturers in
        Detroit,  Michigan;  Dearborn  and Wayne,  Michigan.   EPA,
        Industry  Survey  Section, Research Triangle Park,  North
        Carolina.   April 16,  1973.
114.    Danielson,  J.A.   Air Pollution Engineering Manual.  Cincinnati,
        Ohio.   Public Health Service Publication 999-AP-40,  1967.
        178-184.
115.    Kent,  R.W.  Thermal Versus  Catalytic Incineration.  Products
        Finishing.  4£(2):83-85, November 1975.
116.    Fuel Requirements,  Capital  Cost and Operating Expense for
        Catalytic and Thermal Afterburners.  Combustion Engineering,
        Air  Preheater Division,  Wellsville, New York.  EPA Contract
        68-02-1473, Task 13.
117.    Mazia, J.   Technical Developments in 1976.  Metal Finishing.
        7J5(2) :75,  February 1977.
118.    Powdered  Automobile Paints Make a Strong Inroad.  Chemical
        Engineering.   a3_(14) :33, July 5, 1976.
119.    Levinson,  S.B.   Radiate.  Journal of Paint Technology.   44_(571)
         32-36, August 1972.
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120.    North, A.G.  Progress in Radiation Cured Coatings.  Pigment
        and Resin Technology.  3_(2):3-ll, February 1974.
121.    Nickerson, R.S.  The State of the Art in UV Coating.
        Industrial Finishing.  5jO(2) :10-14, February 1974.
122.    Dowbenko, R. and D.P. Hart.  Nonaqueous Dispersions as
        Vehicles for Polymer Coatings.   Industrial Engineering
        Chemistry Product Research and Development.  12(1);14-28,
        1973.
123.    Conversation with Mr. Noone, Product Manager, Automotive
        Finishes Department, DuPont  Company, Southfield,  Michigan.
        February 23, 1977.
124.    Conversation with A. Little, Ditzler, Automotive  Finishing
        Division,  PPG  Industries,  Inc.,  Detroit, Michigan.  February
        23,  1977.
125.    Rule 66, Organic Solvents.  Los Angeles,  California.   Air
        Pollution  Control District,  County of Los  Angeles.  July  28,
        1966.   Amendments of November  2, 1972,  and August 31, 1974.
126.    Young,  R.G.  and W.  R.  Howell.  Epoxies  Offer Fulfillment  of
        High Performance Needs.   Modern  Paint  and  Coatings.   j>5_(3) :
        43-47,  March 1975.
127.    Lunde,  D.I.   Acrylic Resins Defy Conventional Relationships
        in New Technology  Coatings.  Modern Paint and Coatings.
        66_(3) :51-53,  March 1976.
128.    Mercuric,  A.  and S. N. Lewis.   High Solids Coatings for Low
        Emission Industrial Finishing.  Journal of Paint Technology.
        47J607) :37-44, August 1975.
129.     Scharfenberger, J.A.  New High  Solids Coating Equipment
         Offers Ecology/Energy Advantages.  Modern Plastics.  53_(2) :
         52-53, February 1976.
 130.     Larson, J.M. and D. E. Tweet.   Alkyds and Polyesters Readied
         for Market Entry.  Modern Paint and Coatings.  65_(3) :31-34,
         March  1975.
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131.    Mazia, J.  Technical Developments in 1976.  Metal
        Finishing.  75_(2) :74-75, February 1977.
132.    Baker, R.D. and J.J. Bracco.  Two-Component Urethanes:  Higher
        Solids Systems at Lower Cure Temperatures.  Modern Paint and
        Coatings.  66_(3) :43-48, March 1976.
133.    Price, M.B.  High Solids Coatings - Where Can They Be Used.
        Preprints, NPCA Chemical Coatings Conference, High Solids
        Session.   37, April 22, 1976.
134.    Conversation with D.' Twilley, Ford Motor Company, Detroit,
        Michigan.   February 17, 1977.
135.    Kloppenburg, W.B.  Trip Report - Chicago Magnet Wire, Elks
        Grove Village,  Illinois.   DeBell & Richardson,  Inc.,  Enfield,
        Connecticut.  Trip Report  124.  April  9,  1976.
136.    Sussman,  Victor H.  Ford Motor Company.   Dearborn, Michigan.
        Letter to James McCarthy,  EPA-CTO, dated  March  16, 1976.
137.    Stern, A.C.  Air Pollution.   New York. Academic Press.
        Volume II, Second Edition, Chapter 16.  1968.
138.    Mantell,  C.L.   Adsorption.  New York.   McGraw-Hill.   1951.
        232.
139.    Benforado, D.M. Air  Pollution  Control by Direct Flame
        Incineration in The Paint  Industry.   Journal of Paint
        Technology.   3_9_(508) :265,  May 1967.
140.    Levinson, S.B.  Powder Coat.  Journal of Paint Technology.
        44_(570):44,  July 1972.
141.    Loop, F.M.  Automotive Electrocoat.   Preprints, NPCA Chemical
        Coatings Conference,  Electrocoat Session.  81,  April 22, 1976.
 142.    Koch, R.R.  Electrocoating Materials Today and Tomorrow.  SME
         Technical Paper.  FC75-563:4, 1975.
 143.     Blatt, W.F.  Hollow Fibers:  A Transition Point in Membrane
         Technology.  American Laboratory.  78, October 1972.
                                 4-57

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144.    Mahon, H.I. and B.J. Lipps.  Hollow Fiber Membranes.
        In:  Encyclopedia of Polymer Science and Technology.
        New York.  John Wiley and Sons, 1971, 269.
145.    Why Powder Coat?  Technical Bulletin Number 1.  Interrad
        Corporation; Stamford, Connecticut.
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                     5.   MODIFICATION AND RECONSTRUCTION

     Proposed standards  apply to all affected facilities constructed or modi-
fied after the date of proposal of the proposed standards.  Provisions apply-
ing to modification and  reconstruction were originally published in the
Federal Register on December 23, 1971.  Clarifying amendments were proposed
in the Federal Register  on October 15, 1974 (39 FR 36946) , and final regula-
tions were promulgated in the Federal Register on December 16, 1975  (40 FR
58416).
     Modification is defined as "any physical change in, or change in the
method of operation of,  an existing facility which increases the amount of
any air pollutant  (to which a standard applies) emitted into the atmosphere
by that facility or which results in the emission of any air pollutant  (to
which a standard applies) into the atmosphere not previously emitted".  Re-
construction occurs when components of an existing facility are replaced to
such an extent that:
      (1)   The fixed capital cost of the new components exceeds
           50 percent of the fixed capital cost that would be re-
           quired to construct a comparable entirely new facility,
           and
      (2)   It is technologically and economically feasible to meet
           the applicable standards.
     There are certain circumstances under which an increase in emissions
does not result in a modification.  If a capital expenditure that is less
than the most recent annual asset guideline repair allowance published  by
the Internal Revenue Service  (Publication 534) is made to increase capacity
at an existing facility and also results in an increase  in emissions to the
atmosphere of a regulated pollutant, a modification is not considered to have
occurred.
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     An increase in working hours - i.e., from one- to two-shift operation -
or an extension from 8 hours to 10 hours per shift would also increase solvent
emissions per day.  This situation, however, is also not considered a modifica-
tion under the definitions set forth in 40 FR 58416, December 16, 1975.
     The purpose of this chapter is to identify potential modifications and
reconstructions of affected facilities, and any exemptions or special allow-
ances covering changes in existing facilities that should be considered.  Ex-
emptions from the regulations may be based on availability of technology and
economic considerations.
     The following potential modifications and reconstructions would apply to
both passenger car and light-duty truck body painting operations, as both op-
erations axe similar.  The only real difference is that generally automobile
body lines run faster than light-duty truck lines.  Some light-duty truck lines,
however, run at speeds comparable to those of automobile lines.  Therefore, for
purposes of this chapter, the two operations can be considered similar.
     As will be seen, many of the possible changes do not qualify as modifica-
tions by strict definition.  They are, however, potential causes of increased
solvent emission and as such should be discussed.
5.1.  POTENTIAL MODIFICATIONS
     The following changes in materials or formulations could cause increased
solvent emissions but would qualify primarily as alternate raw materials, not
as modifications, under the above definition unless capital expenditures are
required to effect the change so as to qualify as a reconstruction.
      (1)  Lower Solids Coatings
          If a change is made from a higher solids to a lower solids
          coating - e.g., from an enamel  to a lacquer - more material,
          hence more solvent, will be used to maintain the same  dry
          coating thickness.  While a change in the direction of lower
          solids is unlikely, it could occur in any one plant as a re-
          sult of changing paint systems, colors, models; or increased
          use of metallics.  It is unlikely, however, that any major
          capital expenditures to equipment would be required.
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     (2)  Use of Higher Density Solvent
         Regulations normally restrict the number of pounds of  solvent
         which can be emitted.  A change in the density of the  solvents
         used, even if the volumetric amounts used were the same, would
         result in more pounds or kilograms being emitted.  Again,  this
         could be construed as a raw-material substitution and  hence  not
         a modification, as no major capital expenditures would be  in-
         volved.  Such substitutions might come about  as a result of  sol-
         vent shortages, attempts to cut paint costs,  or efforts to in-
         corporate  less photoreactive solvents.
     (3)   Increased  Thinning of Coatings
         A change to  a higher viscosity coating could  result  in an  in-
          creased use  of  solvents  for thinning  the  coating  to  proper
          application  consistency.
     While  the above three cases can be considered as raw material  substitu-
tions, they are not of themselves considered to be modifications.   The  phrase
"bubble concept" has been used in Title 40,  FR 58416, to refer to a trade-off
of emission increases from one facility undergoing a physical  or operational
change with emission reductions from another facility in order to achieve no
net increase in the amount of any air pollutant (to which a standard applies)
emitted into the atmosphere by the stationary source as a whole.
     Title  40, FR 58416,  states:   "In those cases where utilization of the ex-
emptions under Paragraph 60.14 (e)  (2),  .(3),  or (4)  as promulgated herein
would effectively negate  the compliance measures originally adopted, use of
those exemptions will not be permitted.
     Other changes that could be made that could result in increased solvent
emission include:
      (4)  Change to Larger Parts
          If body size were increased and the same production rates
          were maintained, more coating materials would be used.
          While the overall trend is toward smaller sized automobiles,
          any one facility could switch from a small sized automobile
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    to a larger model.   It  is  felt, however, that  such a change
    would not qualify as a  modification per se, as automobile
    or light-duty  truck assembly lines normally can  accept more
    than one size  vehicle.
    If extensive capital expenditures were involved,  such a
    change  could be classified as a reconstruction.
(5)  Change  to Thicker Coatings
    A change to a  thicker coating, other  factors  remaining con-
    stant,  could result in increased solvent  emission.   There
    is  an effort under way in the automotive  industry to in-
    crease corrosion resistance, which could  call for increased
    coverage or thicker coatings in corrosion-prone areas.

(6)   Reduced Deposition Efficiency
     Increased overspray because of a process modification such
     as a switch from electrostatic spray to conventional spray
     would result in increased emissions.   For economic reasons
     if for nothing else, however, a  switch in such a direction
     is unlikely except possibly as a temporary measure.
(7)  Additional Coating  Stations
     If for any reason  additional  coating stations were added,
     emissions would be  increased.  It was found by  General
     Motors, for example, that water-borne coatings  achieved a
     better finish if applied  in two  coats with a  bake after
     each application.   The repair station also had  to be in-
     creased, as any touch-up  required repainting  entire pan-
     els  instead of just small areas, as  with  conventional
      lacquers.  It is possible that new paint  systems could  re-
      sult in similar requirements.  Such  a change would likely
      involve a  reconstruction or a new facility and, as such,
      would be  subject to regulation.
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5.2.   RECONSTRUCTION
     Automotive spray booths and bake ovens last 20-25 years and are normally
not replaced before that time unless process changes dictate it.  Chrysler
has two plants which are twenty years old in which booths and ovens have not
been replaced.  In the last eighteen years Chrysler has replaced only one
complete paint line .  In some cases the line is moved to another location
within the plant, and booths or ovens may fall apart, necessitating some
rebuilding.
     Model changes are normally handled with existing equipment and do not
require any major changes .  A model changeover may be coupled with an in-
crease in production line speed over previous design speed, however, which
would necessitate increasing the length of both spray booths and ovens.
     If replacement of booths is required, more advanced designs would nor-
mally be incorporated.  Such things as electrostatic spray and more automated
                                                 2
spraying would be added if not already being used  .
     If emission controls were not imposed, it is not likely that paint line
replacements  would include changing to low emitting  systems such as water-
borne topcoats or powder coating systems which are still not perfected.  One
important exception  is the adoption of electrodeposition of water-borne elec-
trophoretic primer coatings.  Both Ford and General  Motors use  this system
quite extensively, and Chrysler is now considering this system  .  Inter-
national Harvester uses the system for priming light-duty truck bodies.  In-
creased corrosion resistance is a prime advantage of the EDP coating  system
and a principal reason for its use; considerably lower solvent  emission
 (even with a  guide coat) is an important secondary effect.
     It is quite possible that if a primer paint line were to be replaced,  an
EDP system would be  installed even without emission  regulations.  The fact
that 50 percent of U. S. passenger car bodies are  already prime-coated by thi
method would  attest  to this.
     Installation of an EDP  system is a major reconstruction project, as  the
 tank and a new oven  have to  be  installed.   The  existing  spray booth and oven
 can be  salvaged  in part for  applying the  guide  coat or primer  surfacer usu-
 ally associated  with an EDP  primer.   Other major reconstructions would be
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required to convert to water-borne topcoats or powder coating because of the
need for longer ovens, humidity controls, corrosion protection, and larger
repair areas for the former; and because of new technologies involved in the
latter system such as overspray recovery.
5.3.   CONSTRAINTS
     Probably the greatest physical constraint in switching to new painting
systems with lower solvent emissions is in additional space requirements.
More space is needed for EDP prime coating because of the added tank and oven.
This assumes that part of the existing system  -  i.e., spray booth and
oven  -  would be needed for the guide coat.  Switching to water-borne top-
coats requires longer ovens and also longer repair areas.  As previously men-
tioned, increasing line speed over original design rates would require longer
booths and ovens.
     Automotive assembly lines are highly integrated, and the space for body
painting in the middle of a line just might not be expandable without tearing
down half the plant.  In many plants bake ovens are already on the roof, so
this space is already taken.  Lack of space was cited as a reason why Ford
Motor Company did not consider switching to water-borne topcoats in their
Milpitas, California, assembly plant.  In this plant the painting line is
located in the middle of the building, so any expansion would have to be
vertical  .
     Such add-on controls  for controlling bake oven emissions as incinerators
and carbon adsorbers  can be mounted  on the  top of the ovens because  they are
relatively small.   Units  for  spray booth control, however, would be  very
large because of the  high  air flows  involved.  The size of carbon adsorption
units  for spray booth control, both  in area and  height, would  almost always
                                                      A
preclude  their being  mounted  on  the  roof of the  plant .   A typical  system  for
controlling  emissions for  a complete automotive  paint line  is  figured to be
approximately  16,000  square feet in  area .
     Another constraint on the  use of certain emission control techniques  is
high energy  usage,  which is considered very sensitive in this  era  of energy
 shortages.   This is particularly true in the case of incinerators  for control-
 ling emissions from spray booths.   Fuel  usage is high,  even with heat
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recovery, because of the high air flows which must be incinerated.  Water-
borne topcoat application increases electrical and gas consumption by an
average of 67 percent and 28 percent, respectively ' , over a typical
solvent-borne system.

5.4.   OTHER CONSIDERATIONS
     One further possible change in operating procedure which could result in
a modification, reconstruction, or new facility, depending on individual cir-
cumstances, is the painting in-house of parts which are manufactured and
prime-coated or finish-coated in other plants or by custom suppliers.  Parts
such as wheels, frames, front ends, etc., as well as many small parts, are
commonly supplied from external sources.  In some cases entire bodies or cabs
are supplied" at least prime-coated  (International Harvester truck cabs, as an
example).  For economic reasons, an automotive company may wish to consoli-
date these operations under one roof.  Depending on the facilities available,
this could require a new painting line or the modification or reconstruction
of an  existing line.  In either case new standards of performance would apply.
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5.5.  REFERENCES
     1.    Gabris, T.  DeBell S Richardson, Inc., Enfield, Connecticut.
           Telephone conversation with R.Flaherty, Chrysler Corporation.
     2.    Gabris, T.  DeBell & Richardson, Inc., Enfield, Connecticut.
           Telephone conversation with T.B. King, International
           Harvester Corporation.  March  2, 1977.
     3.    Gabris, T.  DeBell & Richardson Trip  Report 112.   Ford Motor
           Company, Milpitas, California.  April 7,  1976.
     4.    Cavanaugh,  E.G.,  G.M. Clancy,  R.G.  Wetherold.   Evaluation of
           a Carbon Adsorption/Incineration Control  System for Auto
           Assembly Plants.   Radian  Corporation, Austin,  Texas.   EPA
           Contract 68-02-1319,  Task No.  46.   May 25,  1976.   p.  94.
     5.    Reference  4,  above,   p.  61.
     6.    Gabris, T.   DeBell & Richardson Trip Report 102.   General
           Motors Plant at South Gate,  California.   April 5,  1976.
     7.    Gabris, T.   DeBell & Richardson Trip Report 110.  General
           Motors Plant at Van Nuys, California.  April 6, 1976.
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                      6.   EMISSION CONTROL SYSTEMS
     In Chapter 4 the performance of available emission control technology
for coating operations in the automotive industry was discussed and evaluated.
The purpose of this chapter is to identify alternative emission control sys-
tems and finishing processes for typical automotive finishing lines.
     Primer and topcoat operations are considered here as two separate emis-
sion sources.  Approximately 40 alternatives for controlling or reducing
prime coat application and 30 alternatives for topcoat application for both
automobile and light-duty truck body coating operations have been identified
and are listed in tables 6-3 through 6-6 at the end of this chapter.  These
can yield as many as 1,200 combinations each for automobiles and light-duty
truck coating operations, any one of which results in reduced emissions from
uncontrolled organic solvent-borne spray operations which constitute the base
cases against which the various alternative systems are measured.
     It was assumed for all  cases that the coating line for automobile bodies
was operating at a rate of 55 bodies per hour for 3,840 hours per year  (240
days, 2 shifts), and that the line for light-duty truck bodies was operating
at 38 bodies per hour for 3,840 hours per year.  This gives an annual output
of 211,200 automobiles and 145,920 light-duty trucks.
     It is the task of this  chapter to select a realistic number of alterna-
tive emission control systems in order to analyze the range of environmental
 (Chapter 7) and economic  (Chapter 8) impacts associated with various alterna-
tive controls.  For this reason, several of the most viable of the various
alternatives have been selected  for further consideration.  These  are presen-
ted - in order of decreasing emission  reduction - in Table 6-1 for automo-
biles and Table 6-2  for  light-duty trucks.
     A  relatively  simple code was devised  for differentiating  the  selected
 alternatives used here and  in Chapter  7.   A somewhat different code was used
 for tables  6-3  through 6-6  in this  chapter and  also  in Chapter 8,  Section 2,
 because of  the  very large number of options and combinations.

                                    6-1

-------
                         Table 6-1.  AUTOMOBILE COATING LINES  -  EMISSION CONTROL SYSTEMS
Process
Primer Coat
Water-borne electrodeposition with no guide coat
Water-borne electrodeposition with water-borne guide coat
Water-borne electrodeposition with solvent-borne guide coat
Solvent-borne (spray) primer, incinerator on cure oven,
10 percent LEL
Topcoat -
Powder coat
Solvent-borne coating, carbon adsorber on spray booth,
1 percent LEL, and incinerator on cure oven, 10 percent LEL
c
Water-borne coating (spray)
Solvent-borne coating, (catalytic) incinerator on spray
booth, primary heat exchanger, 1 percent LEL
Solvent-borne coating, incinerator on cure oven, 10 per-
cent LEL
Code
Number

II-P
III-P
II-P
IV-P

IV-T
II-T/III-T
I-T
III-T
II-T
Alter-
nate
Codeb

II
IV
III
l-b' to
I-f

C
A-le
B
A- 3
A-e
Solvent
Emitted ,
Metric
Tons/Year

37
78
286
910

0
149
295
310
1,328
Percent
Reduction

96.0
92.0
72.0
10.8

100.0
90.0
80.0
79.2
10.8
CTi
to
       a Incinerator interchangeable with carbon adsorber  at  same  efficiency.

         From tables 6-3 through  6-6.
       ° Further reduction  of  emissions  is  possible  using  an  incinerator on  the oven,  Code B-e.

-------
                        Table  6-2.   LIGHT-DUTY TRUCK COATING  LINES   -   EMISSION CONTROL SYSTEMS
a
Process
Primer Coat -
Water-borne electrodeposition with water-borne guide coat
Water-borne electrodeposition with solvent-borne guide
coat
Topcoat -
Powder coat
Solvent-borne coating, carbon adsorber on spray booth,
1 percent LEL, and incinerator on cure oven, 10 per-
cent LEL
c
Water-borne coating (spray)
Solvent-borne coating, (catalytic) incinerator on spray
booth, primary heat exchanger, 1 percent LEL
Solvent-borne coating (catalytic) incinerator on cure
oven, primary and secondary heat exchangers, 10 per-
cent LEL
Code
Number

III-P
II-P

IV-T
II-T/III-T
I-T
III-T
II-T
Alter-
nate
Code

IV
III

C
A-le
B
A- 3
A-e
Solvent
Emitted,
Metric
Tons/Year

49
193

0
108
229
229
963
Percent
Reduction

92.0
70.0

100.0
90.0
79.0
79.0
11.0
U)
       a Incinerator interchangeable with carbon adsorber at same efficiency.




         From tables 6-3 through 6-6.



       C Further  reduction of emissions  is possible using an incinerator on  the oven, Code B-e,

-------
     The decreased emissions and percent reduction are from the base cases,
which - as previously mentioned - are uncontrolled organic solvent-borne
spray coating systems.
6.1.  ALTERNATIVE I-P
     The application of a water-borne primer by electrodeposition  (EDP) is
in widespread use in the automotive industry today, primarily because of the
increased corrosion protection it affords.  Such systems have been described
in detail1'2'3'4'5'6'7.  At the present time, however, automotive coating
lines usually apply an extra coat by spraying  (either organic solvent-borne
or water-borne).  This guide coat or primer surfacer gives a smoother finish
for the topcoat application.
     If means can be  found to eliminate the guide coat and still obtain a
satisfactory finish,  changing from an uncontrolled organic solvent-borne
prime coat  to this EDP system for the automobile model line would reduce
solvent emissions from 1,020 metric tons per year to 37 metric tons - a re-
duction of  96 percent.   For the  light-duty truck line, emissions would be
reduced from 649 metric  tons per year to 21 metric tons.
     Figure 6-1 presents a flow  diagram of this system.
6.2.  ALTERNATIVE II-P
     Figure 6-2 shows a  flow diagram of a typical EDP  line in  conjunction
with an organic solvent-borne  guide coat.  This is normal practice in  the
automotive  industry  where organic  solvent-borne topcoats are applied.   The
use of an organic solvent-borne  guide  coat increases  solvent emission  sig-
nificantly  over just the use of  EDP alone.   For the automobile model line,
however,  emissions  using this  combination are  reduced to  286 metric tons
compared  to 1,020 tons  for  the organic solvent-borne  prime coat base case  -
a reduction of 72 percent.   On the light-duty  truck model  line,  emissions
are reduced to 193  metric tons per year.
                                    6-4

-------
6.3.  ALTERNATIVE III-P
     Where water-borne topcoats are used, the guide coat used over the EDP
primer is normally also water-borne coating.  In the automobile model line,
emissions are 78 metric tons, a reduction of 92 percent over the organic sol-
vent-borne base case.  Similar reductions are achieved in the light-duty truck
model line.
     Figure 6-3 illustrates this combination.
6.4.  ALTERNATIVE IV-P
     In this alternative the organic solvent-borne prime coat  (base case) oven
emissions are controlled by an incinerator unit.  Many of the state and local
regulations limit oven emissions quite severely.  In many cases oven emissions
are limited to 15 pounds per day unless  total oven emissions are reduced by at
least 85 percent  (example:  Rule 66, Los Angeles County Air Pollution Control
District).
     This control measure  reduces  total  prime coating  line emissions by 11 per-
cent.  Total emissions  from  the automobile  model  line  become 910 metric tons
per year; and  from  the  light-duty  truck  line, 579 metric  tons per  year.
     The  same  reduction can  be achieved  by  the  use of  a carbon  adsorption  unit
on the bake oven.
     Figure 6-4  is  a flow  diagram  of this alternative.
6.5.  ALTERNATIVE I-T
     In this alternative system a  water-borne topcoat  material  replaces  the
solvent-borne  topcoat.   This technology  is  used today  by  ,two automobile
plants4'5.  The  essential  steps of this  process and  points  of  emission source
are shown in Figure 6-5.
     Converting  to  water-borne topcoat materials reduces  the  emission from
 the automobile topcoat operations  of the model  line  to 295  metric tons per
 year;  that of  the light-duty truck line  is reduced to  229 metric tons, or a
 reduction of 80  percent from the organic solvent-borne topcoat base case.
                                       6-5

-------
6.6.  ALTERNATIVE II-T
     In this alternative an incinerator is put on the topcoat oven.  This
                                                                 6,8
technology is used by some automobile and light-duty truck plants   .  A re-
duction of 11 percent in emissions is observed.  This is the same as would be
in the case of a carbon adsorber installation.  The system is illustrated by
Figure 6-6.
     The incineration of the topcoat oven emissions reduces the emission of
the topcoat operation of the automobile line  from 1,489 metric tons  (uncon-
trolled solvent-borne topcoat)  to  1,328 metric tons; the emission  reduction
of the light-duty truck topcoat operation is  120 metric tons - reductions of
about 11 percent.
6.7.  ALTERNATIVE III-T
      In this  system,  emissions from the paint spray booth of the model  line
are  fed to  an incinerator  (or  to  a carbon adsorption unit) .  A flow diagram
is  shown  in Figure  6-7.
      This control  system reduces  topcoat emissions of  the  automobile model
line to  309 metric  tons  per year  and emissions from  the light-duty truck
model line to 229  metric tons per year - reductions  of 79  percent.
6.8.   ALTERNATIVE II-T Plus III-T
      This system combines a carbon adsorption unit on the organic solvent-
borne spray booth(s)  and an incinerator on the bake oven(s).   This reduces
 total emissions from the automobile model line from 1489 metric tons per
 year to 149 metric tons, and emissions from  the light-duty truck model line
 to 109 metric tons per year -  reductions of  90 percent.
 6.9.  ALTERNATIVE IV-T
      In this alternative the  solvent-borne topcoat materials are  replaced on
 the model line by powder coating.  The reduction is practically 100 percent
 with an emission of zero  (minute  emissions can be caused by plasticizers from
 vinyl materials, and by some  of the curing agents used in conjunction  with
 thermosetting resins).
      A flow  diagram of this process is  shown in Figure 6-8.
                                       6-6

-------
                                  Figure 6-1.  FLOW DIAGRAM  -  ALTERNATIVE I-P

                                APPLICATION OF ELECTRODEPOSITION  (EDP) PRIME COAT
                        Stack
                            Stack
 Stack
•a
         Body
     EDP Coating
                             Transfer Loss
                               (Solvent)
EDP Prime Coat
   Dip Tank
                                 [Solvent Loss
                                                   Rinse
      Evaporation Loss
      (Solvent, Water)
Prime Cure
  Oven
Painted Body
Goes to Topcoat
Application

-------
                                   Figure  6-2.   FLOW DIAGRAM  -  ALTERNATIVE II-P

                                  APPLICATION OF ELECTRODEPOSITION  (EDP) PRIME COAT

                                     WITH  SOLVENT-BORNE GUIDE COAT (SURFACER)
                            Stack
                                                      Stack
                                               Stack
00
             Body
                                 Transfer Loss
                                   (Solvent)
EDP Prime Coat
   Dip  Tank
                                  Solvent Loss
                                                       Rinse
               Evaporation Loss
               (Solvent,  Water)
         Prime Cure
           Oven
          EDP Coating
                                            Stack
                                                                      Stack
                                              1
                       Evaporation Loss
                           (Solvent)
         1
Transfer Loss
  (Solvent)
       Painted Body Goes to
       Topcoat Application
               Guide Coat
                (Surfacer)
               Cure Oven
Spray Solvent-Borne
     Guide Coat
     (Surfacer)

-------
                                    Figure 6-3.  FLOW DIAGRAM  -  ALTERNATIVE III-P

                                  APPLICATION OF ELECTRQDEPOSITION  (EDP),  PRIME COAT

                                       WITH WATER-BORNE GUIDE COAT  (SURFACER)
                           Stack
                            Stack
                                                                        Stack
                               Transfer Loss
                                  (Solvent)
I
10
           Body
EDP Prime Coat
   Dip  Tank
         EDP Coating
                                  Solvent Loss
Rinse
                        Evaporation Loss
                        (Solvent, Water)
Prime Cure
   Oven
                                            Stack
                                             Stack
                                             t
                       Evaporation  Loss
                            (Solvent)
                  t
   Transfer Loss
      (Solvent)
      Painted  Body  Goes  to
      Topcoat  Application
              Guide  Coat
               (Surfacer)
              Cure Oven
          Spray Water-Borne
              Guide Coat
               (Surfacer)

-------
                            Figure 6-4.  FLOW DIAGRAM  -  ALTERNATIVE IV-P
                               APPLICATION OF SOLVENT-BORNE PRIMER COAT

                              BASE CASE WITH INCINERATOR ON PRIMER OVEN
                             Stack   Stack
                   Overspray
                   (Solvent)
   Body
Paint,  Thinner
               11
                                                               1
                                                                   Stack
                                                           Incinerator,
                                                            90 Percent
                                                            Efficient
         Solvent
         Emission
     Prime Coat
     Spray Booth
-T      I
        Flashoff
          of
        Solvents
  i
Evaporation  Loss
   (Solvent)
Prime Coat
Cure Oven
                                                                                 Painted Body Goes to
                                                                                 Topcoat Application
Overspray Loss
   (Solids)

-------
                                      Figure 6-5.   FLOW DIAGRAM  -  ALTERNATIVE I-T

                                          APPLICATION OF WATER-BORNE TOPCOAT
I
H
                                     Stack
                                      1
   Overspray
(Solvent,  Water)
                                 Stack
1
Evaporation Loss
(Solvent, Water)
Primed
Body
PsHnt-. Tlrlnnpr .
Water-Borne Topcoat
Spray Booth
_J 1

Overspray
Topcoat
Cure Oven

Painted
^ Body
                                                 (Solids, Water, and Solvents)

-------
                                   Figure 6-6.   FLOW DIAGRAM  -  ALTERNATIVE II-T
                                        APPLICATION OF SOLVENT-BORNE TOPCOAT

                                  BASE CASE WITH CARBON ADSORBER3 ON TOPCOAT OVEN
                                                                                     Stack
                                                                               Carbon Adsorber
                                                                                  90 Percent
                                                                                  Efficient
                 Stack
                                            Stack
H
K)
    Primed
     Body
                       Overspray
                       (Solvent)
            Topcoat
          Spray Booth
                                              \
       Solvent Emission
Flashoff
   of
Solvents
                                                                                          Evaporation
                                                                                            (Solvent)
                                                                                   Topcoat
                                                                                  Cure Oven
Painted
 Body
 Paint,
Thinner"
                          Overspray
                           (Solids)
           Incinerator can be used in place of carbon adsorber
           with same efficiency.

-------
o\
I
H
W
                                     Figure  6-7.   FLOW DIAGRAM  -   ALTERNATIVE III-T


                                          APPLICATION  OF SOLVENT-BORNE TOPCOAT


                                        BASE CASE WITH INCINERATOR ON SPRAY BOOTH
                            Stack
                    Incinerator,

                     90  Percent

                     Efficient
                                                                                         Stack
Primed
Body
Paint,

1

4
1 Solvent Emission
Flashoff
Topcoat
Spray
f
Thinner
Booth —
Solvents


Evaporation
(Solvent)
Painted
Topcoat
Cure Oven Body
1
                                (Solids)

-------
                                 Figure 6-8.   FLOW DIAGRAM  -  ALTERNATIVE IV-T

                               APPLICATION OF ELECTROSTATIC SPRAY POWDER COATING
              Primed
               Body
a\
Apply
Electrostatic
Powder
Spray


Cure
Oven
Painted
 Body
                         Powder
                                  _J
                                                 30 Percent
                                                 Overspray
                                                  (Solids)

-------
     Following is a listing of the codes used in the ensuing tables 6-3
through 6-6:

Code    identification of Process or Control Device  	.	

   Prime Coating
I       Solvent-borne prime coat  -  spray
II      Prime coat/electrodeposition/water-borne dip/no guide coat
III     Prime coat/electrodeposition/water-borne dip/solvent guide coat
IV      Prime coat/electrodeposition/water-borne dip/water-borne guide coat

   Top Coating
A       Solvent-borne topcoat
B       Water-borne topcoat
C       Powder  topcoat
   Spray Booth  Controls  for Either  Prime  Coat or Topcoat
1       Spray booth/carbon adsorption/1 percent LEL
2       Spray booth/incinerator/I percent LEL/thermal/primary  heat exchange
 3       Spray booth/incinerator/I percent LEL/catalytic/primary heat exchange

 .   Oven Controls for Either  Prime Coat or Topcoat
 a       Oven/carbon adsorption/10 percent LEL
 b       Oven/incinerator/10  percent LEL/thermal/primary heat exchange
 c       Oven/incinerator/10  percent LEL/thermal/primary and secondary
             heat exchange
 d        Oven/incinerator/10 percent LEL/catalytic/primary heat exchange
 e        Oven/incinerator/10 percent LEL/catalytic/primary and secondary
             heat exchange
 f       Oven/incinerator/5 percent LEL/catalytic/primary and secondary
             heat exchange

 EXAMPLE:
 Case    Code    Control System	.	_	
 Ill-la  III     Prime coat/electrodeposition/water-borne dip/no guide coat
         1       Spray booth/carbon adsorption/1 percent LEL
         a       Oven adsorption/10 percent LEL

                                      6-15

-------
  Table 6-3 .  ALTERNATIVE  CASES



AUTOMOBILE BODIES, PRIME COATING

Case
II
Ill-la
Ill-le
III-3a
III-3e
IV
III-l
III-3
I-la
1-13
I-ld
I-lc
I-lf
I-lb
I-3a
I-3e
I-3d
I-3c
I-3f
I-3b
I-2a
I-2e
I-2d
I-2c
I-2f

I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
l-a
I-e
I-d
I-c
I-f
I-b
I (Base)
Emission
Reduction ,
Percent
96
94
I
92
91
91
90
































T:

79
I
75
75
72
11




'





0
Decreased
Emission,
Metric Tons
Per Year
983
957
1
942
931
931
917



































807
i
761
761
734
110




1




P
-
Solvent Emitted
Metric
Tons
Per Year
37
63
I
78
89
89
103




































213
i
250
250
286
910




•





1,020
Pounds
Per Day
339
577
1
715
816
816
944


































f

1,952
i
2,374
2,374
2,622
8,342









'
9,350
             6-16

-------
          Table 6-4.  ALTERNATIVE CASES

          AUTOMOBILE BODIES, TOPCOATING

Case
C
A-le
A-la
A-lc
A-ld
A-lf
A-lb
A-3e
A-3a
A-3c
A-3d
A-3f
A-3b
A-2e
A-2a
A-2c
A-2d
A-2f
A-2b
B a
A-l
A- 3
A-2
A-e
A-a
A-c
A-d
A-f
A-b
A (Base)
Emission
Reduction ,
Percent
100
90
















i

















80
79
1
11




i





0
Decreased
Emission,
Metric Tons
Per Year
1,489
1,340


































1,194
1,179
1
161




i





0
Solvent Emitted
Metric
Tons
Per Year
0
149

































r
295
310
I
1,328




i




t
1,489
Pounds
Per Day
0
1,366

































i
2,704
2,842
i
12,173




i




r
13,649
Further reduction of emissions is possible with use of
an incinerator on the oven.
                         6-17

-------
     Table  6-5.  ALTERNATIVE CASES



LIGHT-DUTY TRUCK BODIES, PRIME COATING

Case

II
Ill-la
Ill-le
IV
III-1
III-3
I-la
I-le
I-ld
I-lf
I-lc
I-lb
I-3a
I-3e
I- 3d
I-3f
I-3c
I-3b
I-2a
I-2e
I-2d
I-2f
I-2c
I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
I-a
I-e
I-d
I-f
I-c
I-b
I (Base)

Emission
Reduction,
Percent

97
94


92
91
91
90


































79
1
73
73
70
11




1




t
0
|
Decreased
Emission,
Metric Tons
Per Year

628
610
1

600
592
592
584


































514
1
475
475
456
70




1




r
0
Solvent Emitted
Metric
Tons
Per Year
21
39


49
57
57
65


































135
I
174
174
193
579




1





649
Pounds
Per Day

192
357
i

449
522
522
596











-






















1,237
I
1,595
1,595
1,769
5,307




•





5,949
                       6-18

-------
            Table 6-6.   ALTERNATIVE CASES

         LIGHT-DUTY TRUCK BODIES, TOPCOATING

Case

C
A-la
A-le
A-ld
A-lc
A-lf
A-lb
A-3a
A-3e
A-3d
A-3c
A-3f
A-3b
A-2a
A-2e
A-2d
A-2c
A-2f
A-2b
A-l
A- 3
B a
A-2
A-a
A-e
A-d
A-c
A-f
A-b
A (Base)
Emission
Reduction,
Percent

100
90















^
















f

79
1
11




i




f
0
Decreased
Emission,
Metric Tons
Per Year
1,080
972
















i

















855
855
851
855
117




1




>
0
Solvent Emitted
Metric
Tons
Per Year
0
108
















i

















225
225
229
225
963




*




r
1,080
Pounds
Per Day
0
990
















1

















2,062
2,062
2,099
2,062
8,827




1





9,900
Further reduction of emissions is possible with the use
of an incinerator on the oven.
                           6-19

-------
6.10. REFERENCES

1.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 9.  December 30, 1975.
2.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut,  Trip
     Report 13.  January 2, 1976.
3.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 73.  February 24, 1976.
4.   Gabris. T,  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 102.  April 5, 1976.
5.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 110.  April 6, 1976.
6.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 112.  April 7, 1976.
7.   Bardin, P.C.  Chevrolet Primes Truck Parts in Two 60,000-Gallon EDP
     Tanks.  Industrial Finishing 49  (2) pp58-65.
8.   Gabris, T.  DeBell & Richardson, Enfield, Connecticut.  Trip
     Report 120.  April 8, 1976.
                                     6-20

-------
                         7.  ENVIRONMENTAL IMPACT

7.1.  AIR POLLUTION IMPACT
      Automobile and light-duty truck assembly lines are major point sources
of solvent emissions.  Most of these emissions result from painting (coating)
the automobile and/or light-duty truck body at the assembly line(s) within the
plant.  For example, an automobile assembly line producing 55 cars per hour
and working with two (8-hour) shifts causes an uncontrolled emission from
primer coating of approximately 1,000 metric tons (2,200,000 pounds) per year.
Emissions from topcoat operations of this line are approximately an additional
1,500 metric tons per year.  This equals approximately 10.4 metric tons
(23,000 pounds) of solvent emissions per work day.
      In 1973  (a very high production year), U. S. consumption of solvents in
paints and coatings was 1,902,273 metric tons or 4,185,000,000 pounds .  From
this,, approximately 680,000 metric tons  (1,500,000,000 pounds) were aliphatic
and 400,000 metric tons (882,(
at the following use pattern:
and 400,000 metric tons (882,000,000 pounds) were aromatic .   Thus we arrive
                                              Million      Per-
                                               Pounds       cent
                 Oxygenated solvents           1,766        42
                 Aliphatic hydrocarbons        1,500        36
                 Aromatic hydrocarbons           882        21
                 Other                            37       	1^
                                Total          4,185       100
      In 1973, excluding maintenance coatings and exports, 1,247 million liters
(330 million gallons) of industrial finishes were made and applied on a vari-
ety of products.  From this  1,247 million liters of coating materials, 170 mil-
lion liters  (45 million gallons) have been used on automobiles and approximately
                                     7-1

-------
75 million liters (20 million gallons) on other transportation units.  It is
estimated that light-duty trucks have used some 15 million liters (4 million
gallons) of these 75 million liters.  Organic solvent consumption in these
1,247 million liters  (330 million gallons) of industrial product finishes is
estimated at about 756 million liters or 200 million gallons.
     The objectives of New Source Performance Standards are to limit the emis-
sion of pollutants by imposing standards which reflect the degree of emission
reduction achievable through the application of the best adequately demonstra-
ted system(s) of emission reduction, taking into account the cost of achiev-
ing such reduction.  Several alternative solvent emission control systems
 (hereinafter referred to as "Alternative") have been identified as candidates
for the best system of emission reduction.
     In assessing the environmental  impact and the degree of emission control
achieved by each alternative which could serve as the basis for standards,
these alternatives need to be compared.  Also, other facets of environmental
impact  - such as potential water pollution and solid waste generation -  need  .
to be assessed.  Similarly, state regulations and controlled emissions should
be considered.  These are  discussed  in the  following  sections.
 7.1.1.  State Regulations and Controlled Emissions
     In August of 1971, Los Angeles  County in California adopted  Rule 66,
 Section C,  specifying that effective August  31,  1974,  the maximum allowable
 organic nonphotochemical emissions  per paint facility was to be  3,000 pounds
 per  day.  The rule  allows only  40 pounds per day from sources  using photochemi-
 cally  reactive  solvents and  15  pounds per day from ovens.  Emissions beyond
 this limit  would require  control.
     Very few coating users  other than automobile and/or light-duty truck as-
 sembly plants (and some truck plants) could consume enough coating product to
 aggregate 3,000 pounds of total organic solvent emission in a day.
      The regulations also provided an exemption for waterborne coatings where
 the volatile content consists of 80 percent water and the solvent was a non-
 photochemically reactive solvent.
                                      7-2

-------
     Today only thirteen states have statewide regulations covering hydro-
carbon emissions.  Approximately half of these states have regulations that
are the same as or similar to Rule 66 of Los Angeles.  Such standards care-
fully limit the amount of photochemically reactive  (PCR) solvent volatiles
which may be emitted within a given time period from both baking ovens and
curing operations and from coating applications in any automotive plant.
     There are difficulties in understanding and interpreting Rule 66.  While
many states have Rule 66 regulations, many have variations such as no maximum
limit per day.  Even those states that have the same regulation seem to in-
terpret it differently.  The interpretation of the definition of the affec-
ted facility has a great impact on the stringency of the standard.  The situ-
ation is complicated even more by the current activity  in rewriting state
regulations.
     California  counties have required assembly plants  to lower organic emis-
sions from spray booths.  In California  the ovens are controlled, while in
Ohio Ford  has  been allowed to shut  down  their afterburners.  The Connecticut
regulation is  one of  the most stringent  in terms of total daily  solvent emis-
sion restrictions, but Connecticut  has no assembly  plants.   The  oven  dischar-
ges of  organic materials are  limited to  15 pounds per day,  unless the dis-
charge  of  the  oven has been' reduced by at least 85  percent.  On  the other
hand, Michigan,  the  state with  the  most  automobile  assembly plants  (approxi-
mately  one  third of the U.S.  car production),  has  no volatile organic con-
 trol regulations at  all.
      For better understanding of existing and future regulations and their im-
 pact on automobile assembly lines,  the relationship between daily emissions of
 coating systems vs.  daily production of automobiles is shown in Figure 7-1 on
 page 7-9,  and Figure 7-2 on page 7-22.
 7.1.2.   Uncontrolled and Controlled Emissions (Alternatives)
      The objective of this chapter is to discuss and determine what control
 methods coupled with which processes will allow substantial reductions in sol -
 vent emissions over the baseline situation without an  extreme adverse effect
 on secondary pollution such as water and  solid waste.  This chapter  should
 help to identify those control methods/processes which can result in  signifi-
 cant emission reduction and should  guide  the selecting of candidates  for  NSPS.
                                      7-3

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7.1.2.1.  Automobiles -
     For our base case, we have assumed that the automobile assembly line is
producing 55 automobiles per hour and is on two  (8-hour) shifts.  This would
mean that the line is producing 880 automobiles per day or 211,200 automo-
biles per year  (240 work days).  The base case is representative of what
might be found  in the industry.  This model line is using traditional or-
ganic solvent-borne finishes.
     Our base case indicates that the uncontrolled organic solvent-borne pri-
mer coat operation results in  an emission of 1,020 metric tons per year
 (2,244,000 pounds).  The organic solvent-borne topcoat operations are re-
sponsible for an additional emission of  1,489 tons per year  (3,275,800 pounds).
These amounts converted into daily  emissions add up  as follows:
     Emissions  (Volatile Organic Solvents)	       Lb/Day
     From organic  solvent-borne primer operation           9,350
     From organic  solvent-borne topcoat  operation         13,649
                                    Total                ' 22,999
     The following alternatives represent control  technologies that could be
 used to reduce  the emission of volatile  organic solvents.   Typical emissions
 from such alternative  lines have  been discussed and have been compared against
 the base case above.
      (1)   Water-Borne Primer Coating
            Alternative I-P (Table 7-1)
            By switching to water-borne primer (electrodeposition) on the model
 line,  the primer coat emission has been reduced to 37 metric tons or 81,400
 pounds per year.  Thus the daily emission from this operation would amount to
 154 kilograms or 339 pounds (81,400 divided by 240).  Note that this technol-
 ogy requires the use of a guide coat* (organic solvent-borne or water-borne).
 *  Guide coat includes  any  spray coating applied after
    electrodeposition but before the  topcoat.   It is
    sometimes called "surfacer" or  "primer-surfacer".
                                    7-4

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   Table 7-1.  AUTOMOBILE BODY PAINTING OPERATION - PRIMER COAT
        HYDROCARBON EMISSION FACTORS AND CONTROL EFFICIENCY
             CONTROLLED AND  UNCONTROLLED  MODEL PLANTS
Model Plant
Uncontrolled
Controlled
Water-borne coating
- Excluding guide coat
- With organic solvent-borne
guide coat
- With water-borne guide coat
Incinerator on primer oven,
10 percent T.KT.
Alternative
-

I-P
II-P
III-P
IV-P
Tons/Year
1,020 (1,124)

37 ( 41)
286 ( 314)
87 ( 96)
910 (1001)
Percent
Reduction
-

96
72
92
11
Units are metric tons; U.S. tons shown in parentheses
                                  7-5

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     (2)    Water-Borne Primer Coating with Organic Solvent-Borne Guide Coat
            Alternative II-P  (Table 7-1)
            The use of the organic solvent-borne guide coat on the model line,
in combination with the water-borne primer, increases the primer coat emission
to 285 metric tons or 627,000 pounds per year.  Thus the daily emissions of this
operation amount to 1,187 kilograms or 2,612 pounds  (627,000 divided by 240).
     (3)    Water-Borne Primer Coating with Water-Borne Guide Coat
            Alternative III-P  (Table 7-1)
            The use of a water-borne guide coat, in combination with the water-
borne primer, on the model line yields a primer coat emission of 78 metric tons
or 171,600 pounds per year.   Thus the daily emissions of this operation amount
to 325 kilograms or 715 pounds.
     (4)    Incinerator on Primer Oven
            Alternative IV-P  (Table  7-1)
            In this case an incinerator  is treating  the emissions  from the pri-
mer coat oven of the model line, which can reduce  the yearly emission  (1,020
metric  tons) by 11 percent, yielding a yearly emission of  910 tons or  2,002,000
pounds.  Converting this into daily  emissions, the result  is 3,792 kilograms  or
8,341 pounds per day.
      (5)    Water-Borne Topcoat
            Alternative I-T  (Table 7-2)
            The converting to water-borne topcoat materials reduces  the emis-
sion from  topcoat  operations  of  the  model line to 295 metric tons (649,000
pounds)  per year.   Thus the daily topcoat emission from the line becomes
1,229  kilograms or 2,704  pounds.
      (6)     Incinerator  on Topcoat Oven
             Alternative II-T (Table 7-2)
             In this Alternative an incinerator is put on the topcoat oven.  A
 reduction of 11 percent in emission is observed, bringing the 1,489 metric
 tons of emission down to 1,328 tons (2,921,600 pounds), amount to 5,533 kilo-
 grams or 12,173 pounds per day.
   Carbon adsorber can be used in place of
   incinerator with same efficiency.
                                       7-6

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       Table 7-2.  AUTOMOBILE BODY PAINTING OPERATION - TOPCOAT



         HYDROCARBON EMISSION  FACTORS AND  CONTROL EFFICIENCY



               CONTROLLED AND UNCONTROLLED MODEL PLANTS
Model Plant
Uncontrolled
Controlled
Water-borne coating
Catalytic incinerator on oven
(primary and secondary heat
exchanger) , 10 percent LEL
Catalytic incinerator on spray
booth (primary heat exchanger
Powder coating
Carbon adsorber on spray booth,
1 percent LEL
Alternative
-

I-T
II-T
III-T
IV-T
V-T
Tons/Year
1,489 (1,641)

495 ( 546)
1,328 (1,464)
309 ( 341)
0
309 ( 341)
Percent
Reduction
-

80
11
79
100 •
79
Units are metric tons; U.S. tons shown in parentheses
                                 7-7

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     (7)   Incinerator* on Topcoat Booth
          Alternative III-T  (Table 7-2)
          In this operation the paint booth exhaust of the model line is fed
to an incinerator.  This Alternative reduces the topcoat emission from 1,489
metric tons to 309 tons  (679,800 pounds), amounting to 1,287 kilograms or
2,832 pounds per day.
     (8)  Powder Topcoat
          Alternative IV-T  (Table 7-2)
          In this Alternative the solvent-borne topcoat materials are replaced
on the model line by powder coats.  The reduction  is practically 100% with an
emission of zero**.
      (9)  Water-Borne Primer Coat with Incinerator on  Topcoat  Booth
          Alternative II-P with Alternative  III-T
          In this example,  a water-borne primer  (with  solvent-borne  guide
coat) and a solvent-borne topcoat are used on the  model  line.   The topcoat
booths are equipped  with incinerator (s).  As can be  gathered from the pre-
ceding pages,  Alternative II-P generates a daily emission of 2,612 pounds,
while Alternative III-T yields a daily emission of 2,832 pounds.  Thus  the
total emission from the combined operation (Alternative II-P and III-T),  at
a production  rate of 880 cars per day, should amount to 2,474 kilograms or
 5,444 pounds  per day.
      Summarizing the Alternatives:   comparative impacts of the control tech-
 nologies and alternative systems are shown graphically in the following
 Figure 7-1.   The graph shows daily emissions from coating systems relative
 to daily production of automobiles.
 * Carbon adsorber can be used in place of  incinerator with
   the same efficiency.
 **For practical purposes,  emission can be  considered as  zero;
   however, minute emissions  can be caused  (0.5-3%) by plasti-
   cizers from vinyl materials, and by curing  agents used in
   conjunction with thennosetting type resins.
 * The term "solvent-borne" is interchangeable with the term
   "organic solvent-borne".
                                     7-8

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      10,000.
   id  8,000
   Q
   gg
   •M
-1  in
'„  G
10  o
   • rH
   M
   10
      6,000
   i!
   W
   >,   4,000.
       3,000
       2,00(>
               Primer and Top Coats
               Uncontrolled Emissions
                                                I            I           I
                                                FIGURE  7-1
                                      Daily Emissions of Coating Systems
                                                     Vs.
                                        Daily Production of Automobiles
                                                                           Alternative I-P
                                                                                plus
                                                                           Alternative I-T
                Alternative II-P
        Primer  - Emissions Controlled
         Top Coat  -  Uncontrolled
                                                  Alternative I-P
                                                       plus
                                                  Alternative III-T
                       200
400         600        800        1,000       1,200

     Daily Production - Number of Automobiles
1,400
1,600

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7.1.2.2.  Light-Duty Trucks -
     As can be seen from the previous tables and from Figure 7-2 (page
the most effective control systems  (alternatives) are:

          Water-borne primer coat
          Powder topcoat
          Water-borne primer coat with water-borne topcoat
          Water-borne primer coat with powder topcoat
     These alternatives are here discussed  for light-duty trucks.
     For our base case we have  assumed that the  light-duty truck assembly
line is producing 38 truck per  hour and  is  on two  (8-hour) shifts.  This
would mean that the line is producing 145,920 bodies per year  (240 workdays).
Similarly to the automobile base case, the  base  case being discussed here does
not represent  a specific line, nor is it intended to indicate that all light-
duty truck finishing lines have these parameters.  The  base  case, however,
is typical or  representative  of what might  be  found  in  the industry.   This
model  line uses traditional  solvent-borne finishes.
     Our base  case  indicates  that  the uncontrolled primer coat operation  re-
sults  in an  emission of 649  metric tons  per year (1,427,800  pounds).   Top-
coat operations produce an additional emission of 1,080 metric tons per year
 (2,376,000 pounds).   These amounts add up to a total emission of 1,729 met-
ric tons per year and a daily emission as follows:
                   Emissions	  Lb/DaY
                   From primer operation        5,949
                   From topcoat operation       9,900
                                Total          15,849
      (1)   Water-Borne Primer Coatings with  Solvent-Borne Guide Coat
           Alternative II-P (Table 7-3)
           The use of the solvent-borne guide coat, in  combination with the
 water-borne (electrodeposition) primer, yields  a primer coat  emission of 193
 metric tons or 424,600 pounds per year.  Thus the daily emissions of this op-
 eration amount to 804 kilograms or  1,769 pounds (424,600 divided by 240).
                                     7-10

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      Table 7-3.   LIGHT-DUTY TRUCK PAINTING OPERATION - PRIMER COAT
           HYDROCARBON EMISSION FACTORS AND CONTROL EFFICIENCY
                Controlled and Uncontrolled Model Plants
Model Plant
Uncontrolled
Controlled
Water-borne coating
- With no guide coat
- With organic solvent-borne
guide coat
With waterborne guide coat
Incinerator on primer oven,
10 percent LEL
Alternative
-


I-P
II-P
III-P
IV-P
Tons/Year
649 (715)


21 ( 23)
193 (212)
49 ( 54)
579 (637)
Percent
Reduction
-


96
70
92
11
a Units are metric tons; U.S. tons shown in parentheses
                                   7-11

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      Table 7-4-  LIGHT-DUTY TRUCK PAINTING OPERATION - TOPCOAT
        HYCROCARBON EMISSION FACTORS AND CONTROL EFFICIENCY
              Controlled and Uncontrolled Model Plants
Model Plant
Uncontrolled
Controlled
Water-borne coating
Catalytic incinerator on oven
(primary and secondary heat exch.)
Catalytic incinerator on booth
(primary heat exchange)
Powder coating
Alternative
-

I-T
II-T
III-T
IV-T
Tons/Year
1,080(1,190)

229 (252)
963 Cl, 059)
855 (940)
Q
Reduction ,
Percent
-

79
11
79
100
Units are metric tons; U.S. tons shown in parentheses.
                                 7-12

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     (2)    Water-Borne Primer Coating with Water-Borne Guide Coat
            Alternative III-P  (Table 7-3)
            The use of a water-borne guide coat in combination with the water
borne primer reduces the primer coat emissions to 49'metric tons or 107,800
pounds per year.  Thus the daily emissions of this operation amount to 204
kilograms or 449 pounds.
     (3)    Water-Borne Topcoat
            Alternative I-T  (Table 7-4)
            Converting to water-borne topcoat materials reduces the emission
from topcoat operations to 229 metric tons or 503,800 pounds per year.  Thus
the daily emissions of this operation amount to 954 kilograms or 2,099 pounds.
7.1.3.  Estimated Hydrocarbon Kmi ssion Reduction in Future Years
     After a record production of 9,667,118 automobiles in 1973, sales de-
clined in 1974 and 1975.  However, it appeared early in 1976 that the auto
industry would stage a comeback, and 1976 production should return to
                                                                           21
8,000,000 automobiles, with  further gains in 1977 and 1978.  A recent study
estimates sales of U.S. made cars in 1976 at 8.6 million, 1977 at 10.0 mil-
lion, 1978 at 10.4 million, and 1979 at 10.2 million units, respectively.
For 1985, production should be up to 11 million units.
     These figures and the yearly emissions  (and emission reductions) that
could occur in the coming years as a result of any standards set  (based on
the alternatives discussed in this section), are here discussed.
     The truck industry manufactures a wide range of vehicles designed for
personal and commercial application.  Different models of vehicles are clas-
sified by gross vehicle weight and body types.  Under light-duty trucks,
trucks with weights up to and including 8,500 pounds are categorized.  Ap-
proximately 75 percent of the total production accounts for trucks of less
than 8,500 pounds gross vehicle weight
     As with the automobile  industry, the truck industry has been affected by
recession in the past few years.  After the record production of 3,007,495
units in 1973, production slackened in 1974 and 1975.  However, truck
                                      7-13

-------
production in 1976 increased 37 percent over 1975 production, and almost re-
                                                          22
turned to the record high  (3,015,000 units) levels of 1973  .  Industry esti-
mates for the 1977 calendar year call for sales of almost 3.3 million total
units22.  Short-range  (to  1980) expansion rates are projected at approxi-
                           O *5
mately 4 percent per annum .  More modest growth  (1 percent average annual
                                   22
rate) is projected for 1980 to 1985  .
Based on these figures,  light-duty truck production is estimated in 1976 at
2,261,250; in 1977 at  2,475,000; in 1978 at 2,574,000; in 1979 at 2,578,000;
and in 1985 at 3,750,000 units, respectively.

7.1.3.1   Automobiles
     Our automobile base case is a line which  produces 211,200 cars per year.
This line results in an  uncontrolled emission  of 1,020 metric tons per year
from the primer operation  and 1,489 tons  from  the  topcoat operations.  This
would mean the following yearly U.S. emissions:

      Table  7-5.  HYPOTHETICAL  EMISSIONS FROM UNCONTROLLED  AUTOMOBILE
                     BODY  PAINTING OPERATIONS, 1976  -  1985
Coating Process
Primer
Uncontrolled topcoat
Total Emission

1976
41,534
60,631
102,165
Emission
1977
48,295
70,501
118,796
- Metric Tons/Year
1978
50,227
73,322
123,549
1979
49,261
71,912
121,173
1985
53,125
77,552
130,677
      The above-listed emissions have been calculated as follows:
           Exaimple, 1976 uncontrolled primer emission  -
           211,200 automobiles yield a yearly emission of 1,020 metric
           tons; thus, 8.6 million units in a year yield:
                1,020 x 8,600,000
                     211,200
41,534 tons/year
   a Our field work  indicates  that  approximately  50 percent of the automo-
     bile plants  (and  light-duty  truck lines)  in  1976  used water-borne
     primer coats.
                                     7-14

-------
The technological merits of water-borne (electrocoat) primers have been dis-
cussed elsewhere in this report.  Indications are that the automobile industry
will continue to explore these advantages.  The expected result would be an
annual rate of 4-5 percent in favor of this technology.
     In view of the above, it can be assumed that by 1979 60 percent of the
automotive primers will be of the water-borne type; and by 1985 a 90 percent
conversion will take place.  The 1985 automobile production is projected at
11 million units.  This increased production will bring us back to the emis-
sion levels of 1976  (84,579 metric tons vs. 82,151).  The wider use of water-
borne primers, alone, will not be sufficient to offset the emissions caused
by the uncontrolled topcoats  (see Table 7-4, page 7-13).
     The adoption by the automobile industry of programs for the reduction of
emissions is a long-range consideration.  Discussed herein in detail is a plan
for adoption by the industry at the rate of 5 percent compounded per year;
see Tables 7-6 through 7-11.  This plan shows the effects of control technol-
ogy over a growth period  from year 1976 to year 1985.
     Industry is using water-borne primer coating in some 50 percent of its
assembly plants, as has been previously stated.     In Figures 7-2  (page 7-25) ,
7-3  (page 7-33), and 7-4  (page  7-34) are charted the emission impacts over the
years 1976-1985 produced by the alternative pollution control technologies.
     For better understanding, one of the calculations  (1979 emissions) of
Table 7-6 is discussed here:
     It is assumed that 60 percent of the car bodies produced in 1979 will be
made with water-borne primer coats.  This means that 6.12 million cars  (60 per-
cent of 10.2 million) will be so produced.  Our base case involves 211,200 cars.
These 211,200 cars, if made with water-borne primer and solvent-borne guide
coat, result in a yearly emission of 285 tons; therefore, 6.12 million cars
yield a primer emission of:
          285 x 6,120,000  = 8,278 metric tons
              211,200
     The remaining 40 percent of the 10.2 million cars are assumed to be madr
with uncontrolled primer; therefore, these cars yield an emission of 19,704
tons, which is 40 percent of  49,261  (see Table 7-5  preceding).  The
                                     7-15

-------
ncontrolled topcoats of 10.2 million cars  (Table 7-5) yield an emission of
71,912 tons.  The total emission, then, is composed of:
          60% of production - water-born primer
          40% of production - uncontrolled primer
 Tons
 8,278
18,704
          100% of production - uncontrolled topcoat   71,912
               Total emission
99,894
    Alternative IV-P covers the use of an  incinerator on the primer oven.
                           18
Cost calculations indicate  that the best case for incineration is the cata-
lytic incinerator.  The  same calculations  indicate that this Alternative rep-
resents a high added annual cost which yields an emission reduction of only
10.8 percent.  This section is restricted  to the best alternative, so that no
further consideration will be given Alternative IV-P herein.
    Water-borne topcoats (Alternative I-T)  are demonstrated technology.  Two
                 2 3
automobile plants  '  are currently using this technology.

              Table 7-6.  AUTOMOBILE BODY  PAINTING OPERATION
         ESTIMATED EMISSIONS FROM WATER-BORNE PRIMER3 - 1976-1985
               Effect of 1976 Results on Future Projections
                                Code:   III/Ab


Uncontrolled primer
a
Water-borne primer
(Alternative II-P)
Uncontrolled topcoat
Total emissions

1976
20,767

5,816

60,631
87,214
Emission
1977
21,732

7,439

70,501
99,672
- Metric
1978
22,602

8,440

73,322
104,364
Tons/Year
1979
19,704

8,278

71,912
99,894

1985
5,312

13,390

77,551
96,253
      Includes solvent-borne guide coat
      For code, see Chapter 6, page 6-2.
                                      7-16

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             Table 7-7.  AUTOMOBILE BODY PAINTING OPERATION

           ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER

      (WITH WATER-BORNE GUIDE COAT)/SOLVENT-BORNE TOPCOAT,  1976-1985

                  (ANNUAL PENETRATION:  5 PERCENT EACH)

                             Code:  IV/A
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrolled
Total Emission
Emissions - Metric Tons/Year
1976

20,767
5,816
(b)

60,631
87,214
1977

21,733
6,771
206

70,501
99,211
1978

20,091
7,041
428

73,322
100,882
1979

17,241
6,906
630

71,912
96,689
1985

2,656
7,448
2,039

77,551
89,694
a At a constant penetration of 50 percent.

  Taken as zero penetration for water-borne primer
  with water-borne guide coat.
                                     7-17

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             Table 7-8.  AUTOMOBILE BODY PAINTING OPERATION

   ESTIMATED EMISSION FROM TOPCOAT WITH INCINERATOR ON OVEN, 1976-1985

       (TOPCOAT OVEN INCINERATOR:  ANNUAL PENETRATION, 5 PERCENT)

                             Code:  III/A-e
Coating Process

Primer -
Uncontrolled
Water-borne (Alternative
II-P)
Topcoat -
Uncontrolled
Incinerator on Oven
(Alternative II-T) , 10% LEL
(Total Topcoat)
Total Emission
Emissions - Metric Tons/Year
1976

20,767
5,816

57,599
2,703a
(60,302)
86,885
1977

21,732
7,439

63,451
6,288
(69,739)
98,910
1978

22,602
8,440

62,323
9,810
(72,133)
103,175
1979

19,704
8,278

57,529
12,827
(70,356)
98,338
1985

5,312
13,390

38,775
34,583
(73,358)
92,060
DeBell & Richardson's field work indicates that approximately
5 percent of the 1976 automobile production used this technology.
                                   7-18

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             Table  7-9.   AUTOMOBILE BODY PAINTING OPERATION

 ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER  (WITH WATER-BORNE

          GUIDE COAT)/ORGANIC SOLVENT-BORNE TOPCOAT,  1976-1985

         WITH INCINERATOR ON TOPCOAT SPRAY BOOTH(S) AND OVEN(S)

                 (ANNUAL PENETRATION:  5 PERCENT EACH)

                            Code:   IV/A-3e
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)d
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat
Uncontrolled
Incinerator on spray booth
and oven (Alternatives
II-T and III-T), LEL !%/
10%
Total Emission
Emissions - Metric Tons/Year
1976

20,767
5,816
(b)

57,599
303

84,485
1977

21,733
6,771
206

63,451
705

92,866
1978

20,091
7,041
428

62,323
1,100

90,983
1979

17,241
6,906
630

57,529
1,439

83,745
1985

2,656
7,448
2,039

38,775
3,880

54,798
a At a constant penetration of 50 percent.

b Taken as zero penetration for water-borne primer with
  water-borne guide coat.
                                      7-19

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           Table 7-10.  AUTOMOBILE BODY PAINTING OPERATION

         ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER

    (WITH WATER-BORNE GUIDE COAT)/WATER-BORNE TOPCOAT, 1976-1985

                (ANNUAL PENETRATION:  5 PERCENT EACH)

                            Code:  IV/B
Coating Process
Primer -
Uncontrolled
Water-borne with Solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrolled
Water-borne (Alternative
I-T)
Total Emission
Emissions - Metric Tons/Year
1976

20,767
5,816
(b)

57,599
600
84,782
1977

21,733
6,771
206

63,451
1,397
93,558
1978

20,091
7,041
428

62,323
2,179
92,062
1979

17,241
6,906
630

57,529
2,850
85,156
1985

2,656
7,448
2,039

38,775
7,682
58,600
At a constant penetration of 50 percent.

Taken as zero penetration for water-borne primer
with water-borne guide coat.
                                     7-20

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             Table 7-11.   AUTOMOBILE BODY PAINTING OPERATION

           ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER

         (WITH WATER-BORNE GUIDE COAT)/POWDER TOPCOAT, 1976-1985

                  (ANNUAL PENETRATION:  5 PERCENT EACH)

                              Code:  IV/C
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrolled
Powder Coat (Alternative
IV-T)
Total Emission
Emissions - Metric Tons/Year
1976

20,767

5,816
(b)

57,599
0
84,182
1977

21,733

6,771
206

63,451
0
92,161
1978

20,091

7,041
428

62,323
0
89,883
1979

17,241

6,906
630

57,529
0
82,306
1985

2,656

7,448
2,039

38,775
0
50,918
a At a constant penetration of 50 percent.

  Taken as zero penetration for water-borne primer
  with water-borne guide coat.
                                     7-21

-------
     100,000.
KJ
KJ
      90,000..
o  ~
•H  10
w  c
(A  O
•H  EH
ll
         U
         •H
       70,OOQ
                                                                                 Figure  7-2

                                                                                Automobiles
                                                                      Emission  Control  Alternatives
                  With solvent-borne guide coat


                  With water-borne guide coat
     1976     1977      1978     1979
                                                 Production Year
                                                                                     1985

-------
7.1.3.2   Light-Duty Trucks
     Our light-duty truck base case is a line which produces 145,920 trucks
per year (3,840 hours per year).  This line results in an uncontrolled emis-
sion of 649 metric tons per year from the primer operation and 1,080 metric
tons from the topcoat operations.  The total estimated emissions from the
uncontrolled U.S. body painting operations are tabulated in Table 7-12.
Other meaningful data will be found in tables 7-13 through 7-18; see also
figure 7-3  (page 7-30).
                 Table 7-12.  HYPOTHETICAL EMISSIONS FROM
             UNCONTROLLED LIGHT-DUTY TRUCK PAINTING OPERATIONS
                                 1976-1985
Coating Process
Primer
Topcoat
Total Emission
Emission - Metric Tons/Year
1976
10,057
16,736
26,793
1977
11 , 008
18,318
29,326
1978
11,448
19,051
30,499
1979
11,466
19,080
30,546
1985
16,678
27,755
44,433
                                    7-23

-------
           Table 7-13.  LIGHT-DUTY TRUCK BODY PAINTING OPERATION
            ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER
      (WITH SOLVENT-BORNE GUIDE COAT)/UNCONTROLLED TOPCOAT, 1976-1985
  Water-Borne Primer Penetration:  50% in 1976, 60% in 1979, 90% in 1985
                                Code:  III/'A
Coating Process
Primer -
Uncontrolled
Water-bornea (Alternative
II-P)
(Total Primer)
Topcoat -
Total Emission
Emissions - Metric Tons/Year
1976

5,028
1,495
(6,523)
16,736
23,259
1977

5,141
1,745
(6,886)
18,318
25,204
1978

4,968
1,927
(6,895)
19,051
25,946
1979

4,586
2,046
(6,632)
19,080
25,712
1985

1,668
4,464
(6,132)
27,755
33,887
Includes solvent-borne guide coat
                                     7-24

-------
         Table 7-14.  LIGHT-DUTY TRUCK PAINTING OPERATION

     ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER (WITH

     WATER-BORNE GUIDE COAT)/SOLVENT-BORNE TOPCOAT, 1976-1985

               (ANNUAL PENETRATION:  5 PERCENT EACH)

                           Code:  IV/A
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alter-
native II-P)a
Water-borne with water-
borne guide coat (Alter-
native UI-P)
Topcoat - Uncontrolled
Total Emission
Emissions - Metric Tons/Year
1976

5,028

1,495

(b)
16,736
23,259
1977

4,953

1,637

41
18 , 318
24,949
1978

4,579

1,702

86
19,051
25,418
1979

4,013

1,705

130
19,080
24,928
1985

834

2,480

566
27,755
31,635
At a constant penetration of 50 percent.

Taken as zero penetration for water-borne primer
with water-borne guide coat.
                                  7-25

-------
           Table 7-15,  LIGHT-DUTY TRUCK PAINTING OPERATION



 ESTIMATED EMISSION  FROM TOPCOAT WITH INCINERATOR ON OVEN, 1976-1985



      (TOPCOAT OVEN INCINERATOR, ANNUAL PENETRATION:  5 PERCENT)



                            Code:  III/A-e
Coating Process
Primer -
Uncontrolled
Water-borne (Alternative
Topcoat -
Uncontrolled
Incinerator on oven
(Alternative II-T)
Total Emission
Emissions - Metric Tons/Year
1976

5,028
1,495

16,402
280
23,205
1977

5,141
1,745

17,402
816
25,104
1978

4,968
1,927

17,146
1,699
25,740
1979

4,586
2,046

16,218
2,552
25,402
1985

1,668
4,464

15,265
10,136
31,533
Includes solvent-borne guide coat
                                    7-26

-------
           Table 7-16.  LIGHT-DUTY TRUCK PAINTING OPERATION
      ESTIMATED EMISSION  FROM COMBINED WATER-BORNE  PRIMER (WITH
        WATER-BORNE GUIDE COAT)/WATER-BORNE TOPCOAT, 1976-1985
                (ANNUAL PENETRATION:  5 PERCENT EACH)
                             Code:  IV/B
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrol led
Water-borne (Alternative
I-T)
Total Emission
Emissions - Metric Tons/Year
1976

5,028

1,495

(b)

16,736
-
23,259
1977

4,953

1,637

41

17,402
194
24,227
1978

4,579

1,702

86

17,146
404
23,917
1979

4,013

1,705

130

16,218
607
22,673
1985

834

2,480

566

15,265
2,648
21,793
At a constant penetration of 50 percent.
Taken as zero penetration for water-borne
primer with water-borne guide coat.
                                 7-27

-------
           Table 7-17.  LIGHT-DUTY TRUCK PAINTING OPERATION

      ESTIMATED EMISSION FROM COMBINED WATER-BORNE  PRIMER  (WITH

          WATER-BORNE GUIDE COAT)/POWDER TOPCOAT, 1976-1985

                 (ANNUAL PENETRATION:  5 PERCENT EACH)

                             Code:  IV/C
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrolled
Powder coat (Alternative
IV-T)
Total Emission
Emissions - Metric Tons/Year
1976

5,028
1,495
(b)

16,736
0
23,259
1977

4,953
1,637
41

17,402
0
24,033
1978

4,579
1,702
86

17,146
0
23,513
1979

4,013
1,705
130

16,218
0
22,066
1985

834
2,480
566

15,265
0
19,145
At a constant penetration of 50 percent.

Taken as zero penetration for water-borne
primer with water-borne guide coat.
                                  7-28

-------
           Table 7-18.   LIGHT-DUTY TRUCK PAINTING OPERATION

      ESTIMATED EMISSION FROM COMBINED WATER-BORNE PRIMER  (WITH

       WATER-BORNE GUIDE COAT)/ORGANIC SOLVENT-BORNE TOPCOAT WITH

           INCINERATOR ON TOPCOAT SPRAY BOOTH(S) AND OVEN(S)

                (ANNUAL PENETRATION:  5 PERCENT EACH)

                         Code:   IV/A-3e
Coating Process
Primer -
Uncontrolled
Water-borne with solvent-
borne guide coat (Alterna-
tive II-P)a
Water-borne with water-
borne guide coat (Alterna-
tive III-P)
Topcoat -
Uncontrolled
Incinerator on spray booth
(Alternative III-T) and in-
cinerator on oven (Alterna-
tive II-T)
Total Emission
Emissions - Metric Tons/Year
1976

5,028
1,495
(b)
16,736
-
23,259
1977

4,953
1,637
41
17,402
91
24,124
1978

4,579
1,702
86
17,146
190
23,703
1979

4,013
1,705
130
16,218
286
22,352
1985

834
2,480
566
15,265
1,249
20,394
At a constant penetration of 50 percent.

Taken as zero penetration for water-borne
primer with water-borne guide coat.
                                  7-29

-------
LA)

O
   30,000  -
     «
       a
fi, >H
  J-l
     0)
                                           Figure 7-3


                                      Light-Duty Trucks


                               Long-Range  Emission  Prediction
                                               WB Primer /WB Topcoat
                                                                                                Booth and Oven
                       Solvent-borne  guide coat




                       Water-borne guide coat
    10,000-
—4—

 1978
                                    4-
         1976
             1977
                                   1979
Production Year
                                                                                        1985

-------
7.2.  WATER POLLUTION IMPACTS
     Water-borne electrodeposition primer coats are prepared by neutralizing
highly acidic polymers with an alkali (like amines) so that these polymers
can be dissolved or suspended in water.   Small amounts of solvents are also
added to increase the water dispersibility.
     In the coating process the paint solids coat the automobile or light-
duty truck body, leaving alkali coalescing solvents behind in the tank.
These products must be removed.  In modern installations, ultrafiltration is
used to automatically remove the water-solubles and chemical agents which are
left behind during the process  (see details in section on Solid Waste Dis-
posal Impact  -  7.3).
     If the effluent water originates from properly operating ultrafiltration
only and  is treated properly,  it can be adequately handled in municipal or
in-house  sewage  treatment facilities.  On the other hand, if the electro-
coating system allows rinse  water  and/or paint to drip or be spilled on the
floor and the rinsing and clean-up water is not automatically placed in a
reservoir for treatment, this  painting operation could cause pollution.
     Especially  important in this  instance is the matter of "dragout".  At
the end of the coating operation the  dipped body becomes coated with an addi-
tional film of adhering paint  called  dragout.  This  film is more porous than
the plated coating;  therefore, it  is  usually rinsed  off.  Also, a  dragout
 (0.50-0.75 pound wet/body) takes place as  the body leaves the tank for the
next location.   This dragout is reclaimed  through an ultrafiltration system.
     With the exception of the primer coats, which are applied by  electro-
coating,  both primer coats and topcoats are applied  by spraying.   The  spray-
ing operations are carried out in  the spray booths.   With the increased at-
tention to air pollution, the  efficiency of particulate  removal  from the
spray booths  is  of great importance to the automotive assembly  lines.  As  a
result, water-wash spray booths of advanced design are coming more and more
into  use.  These booths have a grid  in the floor through which  the overspra\
 is drawn  before  being  exhausted.
      Regarding  the amount of overspray  formed in a given automotive finish-
 ing operation,  the expert opinions and  estimates vary over a very wide rang'..
                                      7-31

-------
The reason for this is the high dependency of this operation on personal ef-
ficiency; a given operator may work with a high or low overspray percentage
                                                                          9
from one occasion to another.  Estimates for overspray run from 20 percent ,
                         13               *
through 35 and 40 percent  , to 50 percent .  As an average, we took the fig-
ure of 35 percent as a realistic one for overspray, with the understanding
that the water-borne topcoat materials tend to yield a higher amount of over-
spray than do their organic solvent-borne counterparts
     Water-wash booths remove overspray paint particles by means of a flow
of water passing down the face of a sheet of steel located at the rear faces
and/or sides - the so-called "water curtain".  These water curtains move some
25-50 gallons per minute per foot   .  Thus a 20-foot section would have a
                                                  14
water flow of approximately 600 gallons per minute   .  This figure is for one
side only; if there are water curtains on both sides of the booth, the water
needs will be doubled.  In actual practice this means that, for example, a
spray booth 180 feet long will need 10,800 to 14,500 gallons of water per
minute, respectively; and a line with four spray booths will need some
40,000 gallons of water per minute  .
     Solvent-based topcoat materials and their overspray contain almost en-
tirely solvents  which separate easily  from the water wash.  Water-borne top-
coat materials, however, are made with  water-miscible solvents to assure good
suspension of the resin binder in the water phase of the coating material.
These various water-miscible  solvents  (glycols, and  certain esters and alco-
hols) found in the water-borne coating  materials are extremely miscible with
water wash and actually act as coupling agents between  the  suspended particles
and the water.
     The  problem with  organic solvent in effluent water is  the chemical oxy-
gen demand  (COD).   COD is  not a pollutant in  itself; it is  a problem only  if
it is discharged to a  stream in  sufficient concentration and quantity to de-
plete the oxygen in the  stream and thereby affect  fish  life and other water
life.  Almost all  assembly plants  emit water  wash  from the  bonderizing pro-
cess to  municipal  sewers  - some  of which have restrictions  on  COD.  The
 * Chrysler,  realizing the contradictory nature of
   these figures, puts it at 50% "as a rule of thumb".
                                      7-32

-------
effluent from the two General Motors (California) plants using water-borne
topcoat is acceptable to sewer authorities.  If necessary, treatment can be
used to lower the COD.
     There are no water pollution impacts associated with the other alterna-
tive emission control systems; however, incineration or adsorption of spray
booth exhaust - although technically feasible - have not been used at any
plant.  As far as carbon adsorption is concerned, it is to be noted that
some solvents used in assembly plants are sufficiently water-miscible to
pose a water pollution problem if regeneration steam is condensed and dis-
charged without being treated.
7.3.  SOLID WASTE DISPOSAL IMPACT
     Water-borne electroprimer operations can have an impact on solid waste
disposal.  In older installations the dragout and rinse were discarded, re-
sulting in a waste disposal problem.  This also causes a paint loss.  Im-
provements have been made, however, to reduce paint cost through the inclu-
sion of some means of reusing this paint by returning it to the tank.
     In modern operations, ultrafiltration is used to automatically remove the
amine(s), solvents, and water-solubles which are left behind during the elec-
trocoating.  Consequently, it is possible to set up a completely closed sys-
tem with practically no waste problem.
     Once a year there is a regular cleaning of the filter system.  Otherwise
cleaning is not needed except on occasions such as, for example, when a paper
cup or other foreign object is accidently dropped into the tank.  Such a
minor cleaning job, however, does not involve more paint than a few gallons.
     There are no serious solid waste disposal problems associated with elec-
trocoating.  Sludge may develop in the tank, leading to a minor solid waste
disposal problem; however, sludge is generally a result of improperly con-
trolled chemistry of the electrocoating tank or poor housekeeping  (such as
allowing parts to accumulate in the tank).  In any case, the amount of such
solid waste is not excessive.
     While water-borne primer coats no longer present any serious sludge  ana
solid waste disposal problems, water-borne topcoats are more prone to do  so
Water-borne topcoat materials, because they are partial or full suspension
                                      7-33

-------
systems just as are dispersions and/or emulsions, display considerably less
mechanical and storage stability than do organic solvent-borne topcoat materi-
als, which are often actually  true  solutions.   In a dispersion, fine parti-
cles  (of the binder) are  suspended  in a continuous liquid phase, like water.
In an emulsion the solids are  liquefied with the help of solvent (s), and
droplets of this are suspended in a continuous liquid phase like water.
     The stability of  these suspension  (also referred to as colloidal) sys-
tems is much dependent on the  water-to-solvent ratio  used.  This is especi-
ally true when the water-to-sol vent ratio  of the water-borne  topcoat material
is disturbed, as it  is when the overspray  of the water-borne  topcoat material
hits the water wash.   In the water wash the major  portion  of  the water-borne
topcoat overspray  is thrown out of suspension, forming lumps  consisting of
agglomerated solids  with locked-in water.   This seriously  increases the
                                               2,3
amount of  sludge formed  in an  automotive plant
      Sludge is  formed  in a conventional solvent-based topcoat operation  - as
for example a combined light-duty truck/automobile production of 50 units per
hour  each, working with two shifts - amounts to a daily 15,000 to 20,000
pounds15.  As an average, approximately four times more sludge is formed in
the water-borne topcoat operations than is observed in conjunction with top-
coats based on  solvent.   For example, one of the automotive plants reported
that  the sludge tank had to be cleaned only once a year when using solvent-
based topcoats, and as the plant switched to water-borne topcoats the sludge
                                          16
 tank  had to be  cleaned every  three months   .
      As a result of the  above  situations -  the water  being filtered at and
 recirculated from the sludge  tanks  to the  spray booths of assembly lines -
 the water must contain significant  amounts  of water-miscible solvents as well
 as colloidal particles of the coagulated binder and  pigment.  Particles which
 are of ultrafine size are impossible to filter out by conventional filtering
 methods.
      As to the exact  amounts  and compositions of  the sludge, estimates of the
 various automotive  industry spokesmen  vary over a wide  spectrum.  This is es-
 pecially true for water-borne topcoats.
      There are some basic differences  between the treatment  of  sludge from
 solvent-based  coatings  and that of water-borne topcoat materials.  Sludge
                                       7-34

-------
from water-based topcoat materials, in order to break the suspension system
and to remove the particles, is treated with slightly acidic compounds like
calcium acetate at an actual pH of 3-4  .  Ultrafiltration could be used
eventually to remove the colloidal particles; but this method is labeled as
an expensive approach to the problem  .  Actually, the solid waste problem
associated with the use of water-borne coatings is minor compared with the
solid waste consideration relating to the total plant.
     There is little solid waste impact associated with alternatives other
than water-borne coatings.  In the case of carbon adsorption (because of the
high cost of the carbon), the carbon is returned to the supplier for regen-
eration.  In the case of powder coats (because of the high cost of the pow-
der) , the oversprayed powder is recovered by means of cyclone(s) - with the
possible additional help of tube or bag filters.  Virtually no solid by-
product is produced by incineration.
7.4.  ENERGY IMPACT
     Automobile and light-duty truck painting operations consume a signifi-
cant amount of energy.  With the exception of a catalytic incinerator - with
primary and secondary heat exchangers used on the curing oven - all alterna-
tive emission control systems require some additional energy.  On the other
hand, the opportunity for more than primary energy recovery from incineration
of spray booth exhaust is limited because of inadequate outlet for the large
amount of energy involved.  The chief adverse effect of incinerating spray
booth exhaust is the high energy consumption.
     In contrast to the necessary exhausting method used for solvent-borne
paint systems, the exhaust from a powder coating application booth usually
can be filtered and returned to the room.  This makes possible a consider-
able energy reduction - attributable to less makeup air, less oven exhaust,
no flashoff zone, and the elimination of heat-up zones in the oven   .
     The energy impact associated with each of the alternative emission con-
trol systems outlined in Chapter 6 and discussed in this chapter is  summar-
ized in Tables 7-19 through 7-26; these tables are a compact representation
and summary of energy balances prepared  for the purpose of comparing the en-
ergy required for a base-case finishing model with the energy required when
pollution reduction coatings or add-on emission controls are utilized.
                                    7-35

-------
                       Table 7-19. ENERGY BALANCE - BASE CASE MODEL AND PROCESS MODIFICATION

                                           Automotive Passenger Car Body
                                              Prime Coat Application
i
u>

Model Description

Base Case -
Solvent-borne prime
coat spray
Option to base case -
Electrodeposition; prime
coat with solvent-borne
guide coat
Option to base case -
Electrodeposition; prime
coat with water-borne
guide coat
Energy Requirements/211,200 cars3
Prime Application
Electricity, kw-hr
1,516,759
7,339,035
8,052,420
Prime Cure Oven
Electricity,
kw-hr
383,827
756,045
997,660
Fuel,
106 Btu
72,349
142,350
162,600
Total Energy
Requirements ,
106 Btu
78, 836 b
169,978
193,481
               211,200 cars  -  the yearly output of a model finishing line.

               Sample calculation:(1,516,759  kw-hr x 3413 Btu/kw-hr) +  (383,827 kw-hr x 3413 Btu/
               kw-hr)  + 72,349 x 106 Btu = 5,177  x 106  Btu + 1310 x 106 Btu +  72,349 x 106 Btu =
               78,836 x 10&  Btu.

-------
                             Table  7-20.  ENERGY BALANCE -  ADD-ON EMISSION CONTROL SYSTEMS
                                              Automotive Passenger Car Body
                                                 Prime Coat Application
Model Description
Incinerator on oven only, 10% LEL
Thermal - primary heat exchanger
Thermal - primary and secondary
heat exchanger
Catalytic - primary heat ex-
changer
Catalytic - primary and secon-
dary heat exchanger
Incinerator on spray booths only
Thermal - primary heat recovery
Catalytic - primary heat
recovery
Carbon adsorption on ovens only,
10% LEL
Carbon adsorption on spray booths
only
Energy Requirements/211,200 Carsa
Emission Control Equipment
Prime Application
Electricity,
kw-hr

-
-
-
_

2,977,920
3,146,880
-
1,776,080
Fuel,
106 Btu

-
-
-
-

1,267,200
464,640
-
13,988
Prime Cure Oven
Electricity,
kw-hr

69,120
80,640
72,960
84,480

-
-
57,290
-
Fuel,
106 Btu

9,600
3,070b
1,536
(2,304)C

-
-
1,700
-
Total Energy, In-
cluding Base Case
and Emission Con-
trol Equipment,
106 Btu

88,672
82,181
80,621
77,106

1,356,196
554,216
80,732
98,878
u
      a 211,200 cars  -  the yearly output of a model finishing line,

      b Energy credit from secondary heat recovery is included.
      c The parentheses indicate that the shown amount of energy is credit and is subtracted
        from the base case to result in the energy requirements of 77,106 x 106 Btu.

-------
                        Table  7-21. ENERGY BALANCE  -  BASE  CASE MODEL AND PROCESS MODIFICATION

                                            Automotive  Passenger Car Body

                                                 Topcoat Application
i
OJ
00

Model Description
Base Case -
Solvent-borne spray
topcoat
Option to base case
Water-borne spray
topcoat
Option to base case -
Powder topcoat, elec-
trostatic application
Energy Requirements/211,200 Cars3
Topcoat Application
Electricity, kw-hr
3,901,555
6,506,737
3,668,000
Topcoat Cure Oven
Electricity,
kw-hr
990,624
1,662,798
-
Fuel,
106 Btu
186,041
238,130
223,250
Total Energy
Requirements,
106 Btu
202,730
265,980
235,769
               211,200 cars  -   the yearly output  of a model  finishing  line.

-------
                              Table 7-22. ENERGY BALANCE - ADD-ON EMISSION CONTROL SYSTEMS


                                              Automotive Passenger Car Body

                                                   Topcoat Application
— — , 	 	 	 — — 	

Model Description

Incinerator on oven only, 10% LEL
Thermal - primary heat exchanger
Thermal - primary and secondary
heat exchanger
Catalytic - primary heat ex-
changer
Catalytic - primary and secon-
dary heat exchanger
Incinerator on spray booths only
Thermal - primary heat recovery
Catalytic - primary heat
recovery
Carbon adsorption on ovens only,
10% LEL
Carbon adsorption on spray booths
only
Energy Requirements/211,200 Carsa
Emission Control Equipment
Topcoat Application
Electricity,
kw-hr
-
4,060,800
4,273,920
-
2,578,180
Fuel,
106 Btu
-
1,728,000
633,600
-
17,979
Topcoat Cure Oven
Electricity,
kw-hr
99,840
115,200
103,680
122,880
-
85,940
-
Fuel,
106 Btu
13,440
3,840
2,380
(3,380)b
-
2,465
-
Total Energy, In-
cluding Base Case
and Emission Con-
trol Equipment,
106 Btu
216,510
206,962
205,460
199,767
1,944,587
850,914
205,488
229,507
I
w
       a 211,200 cars - the yearly output of a model finishing line.





         Energy credit from secondary heat recovery is included.


       c The parentheses indicate that the shown amount of energy is credit and&is subtracted

         from the base case to result in the energy requirements of 77,106 x 10  Btu.

-------
                                          Table 7-23.  ENERGY BALANCE

                            BASE CASE MODEL AND OPTIONAL POLLUTION REDUCTION COATINGS

                             Automotive, Light-Duty Truck  -  Prime Coat Application
£>
O
Model Description
Base case -
Solvent-borne prime
coat spray
Option to base case -
Electrodeposition; prime
coat with solvent-borne
guide coat
Option to base case -
Electrodeposition; prime
coat with water-borne
guide coat
Energy Requirements/145,920 Vehicles a
Prime Application
Electricity,
kw-hr
1,240,258
5,153,750
5,812,760
Prime Cure Oven
Electricity,
kw-hr
349,253
678,250
818,240 .
Fuel,
106 Btu
36,325
82,000
92,100
Total Energy
Requirements ,
106 Btu
41,750
101,900
114,728
               145,920 vehicles - the yearly output of a model finishing line.

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                     Table 7-24.   ENERGY BALANCE - ADD-ON EMISSION CONTROL SYSTEMS

                                    Automotive, Light-Duty Truck Body
                                         Prime Coat Application
Model Description
Incinerator on oven only, 10% LEL
Thermal - primary heat exchanger
Thermal - primary and secondary
heat exchanger
Catalytic - primary heat ex-
changer
Catalytic - primary and secon-
dary heat exchanger
Incinerator on spray booths only
Thermal - primary heat recovery
Catalytic - primary heat
recovery
Carbon adsorption on ovens only,
10% LEL
Carbon adsorption on spray booths
only
Energy Requirements/145,920 Vehicles
Emission Control Equipment
Prime Application
Electricity,
kw-hr

-
-
-
-

1,739,904
1,825,152
-
1,145,860
Fuel,
106 Btu

-
-
-
-

748,800
278,784
-
8,911
Prime Cure Oven
Electricity,
kw-hr

46,080
53,760
53,760
61,440

-
-
42,970
-
Fuel,
106 Btu

6,720
2,120a
1,152
(960)b

-
-
1,078
-
Total Energy, In-
cluding Base Case
and Emission Con-
trol Equipment,
106 Btu

48,627
44,053
43,085
40,999

796,488
326,763
42,828
45,661
145,920 vehicles - the yearly output of a model finishing line.


Energy credit from secondary heat recovery is included.

The parentheses indicate that the shown amount of energy is credit and is subtracted
from the base case to result in the energy requirements of 77,106 x 10» Btu.

-------
                                             Table 7-25.   ENERGY BALANCE
                               BASE CASE MODEL AND OPTIONAL POLLUTION REDUCTION COATINGS
                                 Automotive,  Light-Duty Truck  -  Topcoat Application
i
*>
to
Model Description
Base case -
Solvent-borne topcoat
spray
Option to base case -
Water-borne topcoat
spray
Option to base case -
Electrostatic powder
coat
Energy Requirements/145,920 Vehicles*1
Prime Application
Electricity,
kw-hr
3,179,607
5,314,920
3,060,000
Prime Cure Oven
Electricity,
kw-hr
898,329
1,499,080
-
Fuel,
106 Btu
93,405
-
112,100
Total Energy
Requirements ,
106 Btu
107,324
119,560
122,544
                 145,920 vehicles - the yearly output of a model finishing line.

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                             Table 7-26.   ENERGY BALANCE - ADD-ON EMISSION CONTROL SYSTEMS

                                             Automotive, Light-Duty Truck Body
                                                   Topcoat Application
__ _

Model Description

Incinerator on oven only, 10% LEL
Thermal - primary heat exchanger
Thermal - primary and secondary
heat exchanger
Catalytic - primary heat ex-
changer
Catalytic - primary and secon-
dary heat exchanger
Incinerator on spray booths only
Thermal - primary heat recovery
Catalytic - primary heat
recovery
Carbon adsorption on ovens only,
10% LEL
Carbon adsorption on spray booths
only.
Energy Requirements/145,920 Vehicles*
Emission Control Equipment
Topcoat Application
Electricity,
kw-hr
-
2,977,920
3,134,208
-
1,890,660
Fuel,
106 Btu
""
1,267,200
464,640
-
14,823
Topcoat Cure Oven
Electricity,
kw-hr
69,120
80,640
72,960
84,480
-
57,290
-
Fuel,
106 Btu
9,600
3,070
1,536
(2,304)b
_
1,813
-
Total Energy, In-
cluding Base Case
and Emission Con-
trol Equipment,
106 Btu
117,150
110,669
109,109
105,300
1,384,687
582,660
109,332
128,597
•-J
W
        145,920 vehicles - the yearly  output  of a model finishing line.
       Energy credit  from secondary heat recovery is included.

       ~,,...;,  ,-,,v~rthc-se3  ir^.c'te  that the shown amount of energy is credit and is subtracted
       fronTthe base  case to result in the energy requirements of 77,106 x 106 Btu.

-------
7.5.   OTHER ENVIRONMENTAL IMPACTS
     Electrophoretic dip coatings contain amines that are driven off during
the curing step.  Some plants have found it necessary to incinerate the oven
exhaust gas to eliminate the visible emission and malodors associated with
these amines ; some other plants have  installed scrubbers for the same pur-
    22
pose
     No environmental impacts other than those discussed above are likely to
arise from standards of performance for automobile or light-duty truck paint-
ing  (coating) operations, regardless of which alternative emission control
system is selected as the basis  for standards.
7.6.  OTHER ENVIRONMENTAL CONCERNS
7.6.1.  Irreversible and Irretrievable Commitment of Resources
     The alternative control  systems will  require the installation of addi-
tional equipment, regardless  of  which  alternative emission  control system is
selected.  This will require  the additional use of  steel  and other resources.
This commitment of resources  is  small  compared to the national  usage of each
resource.  A good quantity  of these  resources will  ultimately be  salvaged and
recycled.  With the exception of carbon adsorption,  there are not expected  to
be significant  amounts  of  space  (or land)  required  for  the  installation of  con-
trol equipment  and/or new  coating technology because all  control  systems can
be located with little  additional space required.   Therefore, the commitment
of land  on which  to  locate additional  control  devices and/or  application
equipment is  expected  to be minor.
      The increase in the use of activated carbon is also expected to be  in-
significant.   In  many cases the carbon can be regenerated and reused after
approximately fifteen years of use.
      As  can  be noted,  the use of primary and secondary heat recovery would
 enhance  the  value of incineration; here it is reasoned that without heat re-
 covery,  significant energy would be lost.
 7.6.2.  Environmental Impact of Delayed Standards
      Delay of proposal of  standards for the automobile and/or light-duty truck
 industry will have major negative environmental effects on emission of hydro-
 carbon to the atmosphere (see Figure  7-3, page 7-30) and minor or no positive

                                       7-44

-------
impacts on water and solid waste.  Furthermore, there does not appear to be
any emerging emission control technology on the horizon that could achieve
greater emission reductions or result in lower costs than that represented b\
the emission control alternatives under consideration here.  Consequently, de-
laying standards to allow further technical developments appears to present
no "trade-off" of higher solvent emissions in the near future against lower
emissions in the distant future.
7.6.3.  Environmental Impact of No Standards
     Growth projections have been presented in earlier sections.  It is obvi-
ous that the increased production of automobiles and light-duty trucks will
add to the national solvent emissions.
     There are essentially no adverse water and solid waste disposal impacts
associated with either of the alternative emission control systems proposed
in this chapter.   Therefore, as in the case of delayed standards, there is
no trade-off of potentially adverse impacts in these areas against the nega-
tive result on air quality which would be inherent with not setting standards.
                                     7-45

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7.7.   REFERENCES
     1.    Tess, Roy W.   Chemistry and Technology of Solvents;
           Chapter 44 in Applied Polymer Science.  American Chemical
           Society, Organic Coatings  and Plastics Division.  1975.
     2.    DeBell & Richardson Trip Report  102.
     3.    DeBell S Richardson Trip Report  110.
     4.    DeBell & Richardson Trip Report  9.
     5.    DeBell & Richardson Trip Report  112.
     6.    Strand, R. C.  Waterborne  Coatings  in Metal  Packaging.
           Paper presented at NPCA Chemical Coatings Conference,
           Cincinnati,  Ohio  (April 23,  1976).
     7.    Prane, J. W.  Water-Borne  Coating Usage  - Current and  Future.
           Paper presented at NPCA Chemical Coatings Conference,
           Cincinnati,  Ohio  (April 23,  1976).
     8.    Brown, R. A.  Water  as a  Compliance Coating - EPA/OSHA/
           Waste Disposal.   Paper presented  at NPCA Chemical  Coatings
           Conference,  Cincinnati, Ohio (April 23,  1976).
     9.    DeBell  &  Richardson  Trip  Report 56.
     10.   DeBell  &  Richardson  Trip  Report 5  (Overprint Varnishing).
     11.   EPA Trip  Report by V.  N.  Gallagher (call made with T.  Gabris,
           September 26, 1975).
     12.   DeBell  &  Richardson Trip Report 3.
     13.   One of  the estimated figures given to T. Gabris by Ford
           Motor Company representative.
     14.   Gabris,  T.   Telephone interview with George Koch Sons, Inc.,
           Evansville, Indiana (October 29, 1976).
      15.   DeBell & Richardson Trip Report 120.
      16.    Gabris, T.  Telephone conversation with  one of the California
            General Motors plants  (October  29, 1976).
                                     7-46

-------
17.   Gerwert, Phil.  General Motors Water Pollution Section,
      November 2, 1976.
18.   DeBell & Richardson, Enfield, Connecticut.  Second  Interim
      Report to EPA on Contract 68-02-2062.  Air Pollution  Control
      Engineering and Cost Study of the Transportation Surface Coat-
      ing Industry.
19.   Auto News.  1975 Almanac Issue  (April  23, 1975).  Page 55.
20.   Auto News  (June 28, 1976).
21.   DeBell & Richardson, Enfield, Connecticut.  Plastics  in the
      Automotive Industry, 1975-1985.
22.   DeBell & Richardson Trip Report 13.
23.   Product Finishing.  June 1976.   Page  166.
                                7-47

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                          8.  ECONOMIC IMPACT

8.1.  INDUSTRY ECONOMIC PROFILE

8.1.1.  Industry Size
     The automobile industry stands at the center of the American economy.
One employed person out of  six works  for  an auto maker or a company whose
primary business is related to the automobile.  Motor vehicles and allied
industries account for one-sixth  of the gross national product of the
United States.  In 1973,  the auto industry consumed the following percen-
tages of these resources:
                                            Percent
                    Rubber                    65
                    Lead                      63
                    Malleable  iron             47
                    Zinc                      33
                    Steel                     21
                    Aluminum                  12
                    Copper                     9

      Any significant  change in the automobile industry affects the entire
 United States economy.  According to the U.S. Department of Commerce, for
 every ten workers producing cars, trucks, and parts, another fifteen are em-
 ployed in industries that provide raw materials such as those listed above
 and manufactured components.
      in 1975 the four major auto makers  -  General Motors Corporation, Ford
 Motor Company, Chrysler Corporation, and American Motors Corporation  -  had
 combined sales of $73.7 billion, 8.5 percent of the total sales of the five
 hundred largest United States corporations1.  The four companies were ranked
 number 2, 4, 10, and 87,  respectively, in terms of sales, by Fortune.
                                      8-1

-------
     Basic data on industry employment and production follows in a series
of tables.  Statistics on indirect employment are included.  The magnitude
of indirect employment is substantial.  According to the Motor Vehicle
Manufacturers Association, 3 million jobs existed in automotive sales and
servicing in 1967.
     Direct employment in the production of automobiles is presented in
Table 8.1-1.  In Table 8.1-2 automotive-related employment in other indus-
tries in 1975 is listed.  Employment in all motor vehicle and equipment
manufacturing, which includes not only passenger cars and light-duty trucks
but also medium- and heavy-duty trucks, is recorded from 1967 to 1974 in
Table 8.1-3.
     Table 8.1-4 gives employment data for motor vehicle and car bodies,
SIC 3711, which includes establishments that manufacture or assemble com-
plete passenger cars and trucks, including light-duty trucks.  Table 8.1-5
lists U.S. truck and bus factory sales by body types and gross vehicle
weight.  Table 8.1-6 presents data on-value added by manufacture by the
motor vehicles and car bodies industry.
                                    8-2

-------
               Table 8.1-1.  DIRECT EMPLOYMENT IN

                 THE PRODUCTION OF AUTOMOBILES
Year
1967
1971
1972
1973
1974
1975
1976 (estimated)
Number
Employed
341,000
382,000
412,000
450,000
350,000
380,000
390,000
 Source:  Automobiles:  Trends and Projections.  U.S. Industrial
          Outlook 1976.  U.S. Department of Commerce, Washington,
          D.C.  January 1976.  p. 133.
Table 8.1-2.  AUTOMOTIVE-RELATED EMPLOYMENT IN SUPPORT INDUSTRIES
                                                     Estimated
                                                    Automotive
 Industry                        _ Employment

 Chemical, plastic, rubber, and allied
                                                         , OOO
  products

 Fabricated metal products                             56,000

 Machinery and electrical equipment                   149,000

 Textile, paper, glass,  and other products             69,000


 TOTAL                          _ 400,000


 Source:  Motor Vehicle  Manufacturers Association  (MVMA) .  1975
          Automobile Facts and Figures.   Detroit,  Michigan, 1976.
          p.  56.
                              8-3

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    Table 8.1-3.  MOTOR VEHICLE AND EQUIPMENT
            MANUFACTURING EMPLOYMENT
Year
1967
1971
1972
1973
1974
All Employees
815,800
842,100
860,900
941,400
858,100
Production
Employees
626,900
650,900
666,300
731,000
655,600
Figures are for the Motor Vehicles and Equipment
Manufacturing Industry (SIC 371), which includes
manufacturers of motor vehicles, car bodies,
truck and bus bodies, parts and accessories, and
truck trailers.
Source:  MVMA.  1975 Automobile Facts and Figures.
         Detroit, Michigan, 1976.  p. 56.
                        8-4

-------
         Table 8.1-4.  EMPLOYMENT DATA FOR MOTOR VEHICLES AND
                    CAR BODIES INDUSTRY  (SIC 3711)
Year
1972
1971
1970
1969
1968
1967
Total Employees
Number
340,400
340,800
305,200
351,000
332,800
321,200
Value
Added Per
Employee
$
34,737
34,160
24,077
26,619
28,703
22,894
Payrolls as
Percent of
Value Added
36
33
41
36
35
37
Production Workers
Number
285,000
283,000
245,300
293,400
272,400
262,300
Average
Hourly
Earnings ,
$
5.79
5.36
4.82
4.67
4.29
4.00
Value Added
Per Man-Hour
of Production
Worker, $
20.04
20.33
15.42
15.89
15.59
14.02
The motor vehicles and car bodies  industry  includes establishments pri-
marily engaged in manufacturing or assembling complete passenger auto-
mobiles, trucks, commercial cars,  and buses.
Source:  1972 Census of  Manufactures
                                  8-5

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                               Table 8.1-5.  1975 U.S. TRUCK AND BUS FACTORY SALES
                                          BY BODY TYPES AND GVW POUNDS
Body Type
Pickup
General utility
Panel
Van
Multi-stop
Station wagon (on
truck chassis)
Busus (including
school bus chassis)
Other body types
TOTAL
6 , 000 and
Less
680,646
101,701
1,143
191,645
23
2,731
-
4,612
982,511
6,001-
10,000
510,189
94,925
-
191,168
23,161
80,501
-
63,043
962,987
10,001-
14,000
—
-
-
-
12,188
-
-
2,154
14,342
14,001-
16,000
-
-
-
-
391
-
-
738
1,129
16,000-
19,500
-
-
-
-
1,256
-
307
9,019
10,582
19,501-
26,000
-
-
-
-
-
-
35,070
139,148
174,218
26,001-
33,000
-
-
-
-
-
-
989
26,321
27,310
Over
33,000
-
-
-
-
-
-
4,164
94,917
99,081
Total
1,190,835
196,626
1,143
382,813
37,019
83,242
40,530
339,952
2,272,160
00
        Source:   Ward's  1976 Automotive  Yearbook

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 Table 8.1-6.  GENERAL STATISTICS ON MOTOR VEHICLES
               AND CAR BODIES INDUSTRY (SIC 3711)
Year
1972
1971
1970
1969
1968
1967
Million Dollars
Value Added
by
Manufacture
12,026
11,680
7,348
9,343
9,552
7,354
Cost of
Materials,
Fuels, Etc.
30,992
28,526
20,531
24,793
24,130
19,965
Value of
Industry
Shipments
42,970
40,306
27,751
34,335
33,665
27,296
See note to Table 8-4 regarding establishments covered
by SIC 3711.

Source:  1972 Census of Manufactures
                        8-7

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8.1.2.  Industry Structure
     The passenger car and light-duty truck industry is dominated by four
firms which produce more than 99 percent of all units manufactured or assem-
bled in the United States.  In addition to General Motors, Ford, Chrysler,
and American Motors, Checker Motors Corporation in Kalamazoo, Michigan;
Sebring-Vanguard in Sebring, Florida; and International Harvester are domes-
tic corporations also participating in the industry.  Plans for U.S. assem-
bly plants by Volvo and Volkswagen Werk are definite; and Fiat, Toyota, and
Datsun  (Nissan) are all considering United States assembly lines.
      General Motors is the dominant firm - whether measured by sales, capi-
talization, profits, breadth of product line,  or number of distribution out-
lets.   Over the last decade. General  Motors'  share of domestic auto produc-
tion has been  about twice as large as Ford's,  its nearest competitor; about
three times as large as Chrysler's; and ten  times that of American Motors.
The share of domestic  production for  each  company has held relatively con-
 stant during  the last  ten years,  as  Figure 8.1-1 shows.
      While its share  of production has held steady,  General  Motors'  share of
 new car registrations has been falling due to increasing competition from
 imports.  In the past decade,  imports have become a major factor in the
 American automotive market, climbing from a 7 percent market share in 1966
 to a high of 19 percent in 1975.  Through 1974 imports have  been taking their
 market share from General Motors.  See Figure 8.1-2.
      One of the most  important features of the structure of the auto indus-
 try is General Motors' dominance of the large-car market,  which is documen-
 ted in Table 8.1-7.  From 1970 to 1974, General Motors sold 79 percent of
 the high-priced class of cars registered in the United States, and 72 per-
 cent of the medium-priced class.  Table 8.1-8 presents factory shipments of
 trucks with a gross vehicle weight of less than 6,000 pounds for the 1972
 to 1974 period.  As can be seen by comparing Table 8.1-8 and Figure 8.1-1,
 market share in light-duty trucks and passenger cars is about equal for all
 four of the largest auto makers.
                                     8-8

-------
  100^.


    90


    80^


    70



    60-

H

|   50i~

W
*   40 _


    30--


    20 _


    10 -
  ~T
  66
              Figure 8.1-1.   SHARE OF  DOMESTIC AUTO
                      PRODUCTION BY COMPANY
                                                         General Motors
                                                          AMC
              67  68
 I
69
70
"T
 71
  ~T
  72

YEAR
~i	i	1	1	T
 73   74   75   76    77
Source:  U.S. Car Production by Quarters.   Ward's  1975  Automotive
         Yearbook, Ward's Communications,  Inc.  (Detroit,  Michigan)
         1975.  p. 93.

Note:    Checker's share of production was less  than  one-tenth
         of 1 percent of the industry total during this period.
                                 8-9

-------
         Figure 8.1-2.  SHARE OF NEW CAR REGISTRATIONS
                      IN THE UNITED STATES
   100


    90


    80


    70


    60
S   50
Oi
W
CU
    40
    30


    20


    10
                                           General  Motors

                                           Ford
                                      .-    Imports
                                      —.    Chrysler
                                                          AMC
            I
           66
67
 I
68
69
T
70

YEAR
 1
71
72  73
 I
74
 I
75
    Source:  U.S. New Car Registrations by Maker.  Ward's
             1975 Automotive Yearbook,  p. 132.
                               8-10

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      Table 8.1-7.   MARKET SHAKE OF U.S. AUTOMOBILE REGISTRATIONS
           FOR MEDIUM- AND HIGH-PRICED LINES VS. TOTAL MARKET
                               (Percent)a
Class
High-Priced Class:
General Motors
Ford
Chrysler
American Motors
Medium-Priced Class:
General Motors
Ford
Chrysler
American Motors
Total U.S. Automobile
Registrations :
General Motors
Ford
Chrysler
American Motors
Imports
1974

79
16
5
-

70
10
20
—


42
25
14
4
15
1973

79
17
4
-

71
10
19
—


44
23
13
4
15
1972

79
16
5
-

73
10
17
—


44
24
14
3
15
1971

81
14
5
-

72
10
18
—


45
24
14
3
14
1970

77
18
6
-

75
13
22
—


40
26
16
3
15
Avg.

79
16
5
-

72
11
19
—


43
25
14
3
15
aTotals may not add to 100 because of rounding errors.
Source:  Ward's 1975 Automotive Yearbook.  U.S. Car Registrations
         by General Market Classes 1970-1974 Calendar Years.
         p. 135.
1975.
                                 8-11

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             Table 8.1-8. U.S.  TRUCK PRODUCTION TRENDS
Make
Brockway
Chevrolet
Diamond Reo
Dodge
Ford
CMC
International
Kaiser-Jeep
Mack
White
Plymouth
American Motors
Miscellaneous
6-Month Total
12-Month Total
New Truck Registration by
Make in U.S.
1967
1,248
551,923
3,913
101,058
494,921
113,982
150,946
39,757
13,434
17,458
—
29,386
-
1,518,426
1972 (Percent)
2,061 ( 00.1)
802,755 ( 31.9)
4,332 ( 00.2)
269,333 ( 10.7)
856,630 ( 34.1)
174,794 ( 06.9)
189,210 ( 07.5)
50,926 ( 02.0)
20,005 ( 00.7)
20,556 ( 00.8)
— "~
121,350 ( 04.8)
-
2,513,952 (100.0)
6-Month U.S. Truck
Production
"£f <— >
-
498,391 ( 32.8)
-
212,711 ( 14.2)
494,050 ( 32.9)
144,519 ( 09.5)
58,776 ( 03.9)
60,279 ( 04.0)
10,167 ( 00.7)
7,637 ( 00.5)
6,200 ( 00.4)
3,739 ( 00.2)
14,646 ( 00.9)
1,506,115 (100.0)
3,015,000
From:  Auto News.  1975 Almanac Issue.  April 23,  1975; and
       Auto News.  June 28, 1976.  Chart, p. 39.
                                  8-12

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8.1.3.  Marketing
     General Motors has not, of course,  always dominated the American auto-
mobile market.  The industry became  a major  factor in the United States econ-
omy as a result of the successful manufacturing strategy of Henry Ford.  His
approach was simple:  obtain economies of  scale by mass-producing identical
cars, thus putting them within the financial reach of more and more Americans.
With that head start in providing  "basic transportation", Ford dominated the
automobile market until the late 1920's, when General Motors took over the
lead position it has never relinquished.
     Ford's manufacturing practices  limited  consumer choice.  Alfred Sloan,
the architect of General  Motors' strategy, sensed correctly that Americans
were no longer willing to accept Henry Ford's dictum that "any customer can
have a car painted any color  that  he wants so long as it is black"  .  As
Sloan put it in his autobiography:   "...the  used cars at much lower prices
dropped down to fill the  demand  at various levels for basic transportation.
When  first-car buyers returned to  the market for the second round,  with the
old car as a first payment on the  new car, they were selling basic  transpor-
tation and demanding  something more  than that in the new car.  Middle-income
buyers, assisted by the  trade-in and installment financing, created the de-
mand, not  for basic transportation but  for progress in new cars,  for  comfort,
convenience, power, and style"
      General  Motors'  strategy was to upgrade a line of products  with  styling
changes and  extras such as heaters,  and eventually automatic  transmissions,
radios, air  conditioning, and other luxuries.  One of the most significant
extras was coatings of different colors and improved durability.
      The  results of Ford's inflexibility  regarding color and styling were
 severe.   In the course of bringing  out  a  new model in the late 1920's, Ford
 lost $200 million, replaced 15,000  machine  tools, rebuilt 25,000 more, and
 laid off 60,000 workers  in Detroit  alone.   Ford  made the automobile a con-
 sumer item by lowering the price annually until  19264. General Motors then
 turned competition from  price to styling, which  has remained a key element
 in marketing ever since  and shows no  sign of weakening.
                                      8-13

-------
      In the marketing strategy of  the domestic auto producers, the impor-
tance placed on  styling is due, in large part, to the fact that the market
for new automobiles is primarily a replacement market.  From the industry's
point of view, the more often consumers buy cars, the higher total volume
becomes.  Styling has played a major role in the industry's attempts to in-
crease the rate  of replacement.  In a 1973 study, Bradford C. Snell, gen-
eral  counsel to  the Senate Judiciary Committee's Subcommittee on Antitrust
and Monopoly, estimated that consumers paid $1.6 billion or $170 per car to
                        56                          7
cover model change costs  .  Lawrence J. White  and Robert F. Lanzillotti
reached similar  conclusions about  the cost of model changes.
      There are other reasons for the importance of styling.  As White puts
it:   "The high visibility of automobiles, their importance as symbols in our
society, their intermediate durability, and their multifaceted nature all
point toward the attractiveness of product behavior that stresses design
change.  Design change and efforts toward design distinctiveness also main-
tain  and enlarge brand loyalty, reducing the price elasticity for each com-
                    Q
pany's own product."   In other words, the more committed a consumer is to a
particular auto maker, the less likely he or she is to change brands despite
price advantages of other models.
      The role of styling in automobile marketing has exerted substantial in-
fluence on capital spending in the industry/ an influence difficult to quan-
tify with precision.  In the last decade, just under half of the industry's
$35 billion in capital expenditures have gone for special tools,  which are
required in part due to styling changes.  How much of the $17 billion is di-
rectly related to styling changes cannot be determined,  because the tools
wear out,  styling changes or no.   But for low-volume models,  the tools are
often changed before the end of their useful life.
     Relative to the cost of other items and the rate of inflation, the price
of new automobiles has been relatively stable.   From 1960 to 1972,  the period
covered by Table 8.1-9,  the average annual compound growth rate for automo-
bile prices was 0.5 percent,  compared to 1.7 percent for all consumer-
durable commodities and 2.9 percent for the gross national product implicit
price deflator.
                                   8-14

-------
     The single most important source of price stability for autos is diffi-
cult to pinpoint.  Several influences come into play.  Of first consideration
are market forces.  While the market for new cars is more sensitive to styl-
ing and brand loyalty than to price, the market for used cars is more price
sensitive.  Since the new car market is based in large part on the used car
market, a downward influence on new car prices is exerted indirectly.
     Second, as the nation's most visible industry, the auto makers are under
the constant eye of federal agencies responsible for the enforcement of the
antitrust laws.  This visibility, which cannot be overstated  -  market-share
statistics for the industry, difficult to obtain for many industries, are
common knowledge  -  enforces caution in the decision making of the auto mak-
ers.  Visibility is a restriction on the ability to raise automobile prices.
     Productivity gains have also been very important to price stability.
These have resulted from automation, as at Lordstown; improved product de-
sign; and experience gains, in general.  Automobile price stability has also
benefitted from price declines in plastics, which are being used increasingly
by the industry.  Census of Manufactures data presented earlier in Table 8.1-4
shows that the value added per man-hour of production worker increased at al-
most exactly the same rate as the average hourly earnings of production work-
ers from 1967 to 1972.
     The data in Table 8.1-9 should be treated carefully, for the Bureau of
Labor Statistics estimates include an adjustment for technological improve-
ments, which makes  interpretation difficult.  In addition, the cost of a new
car is the largest  component cost in operating a car, but is by no means the
only important one.  In the fiscal year July  1972  -  June 1973, gasoline ex-
penditures equaled  an average of almost 5 percent  of family  income, according
to data in Table  8.1-10, gathered by the U.S. Bureau of Labor Statistics and
analyzed by the Motor Vehicle Manufacturers Association.
     When gasoline  prices began  to  increase in the early 1970's,  small cars
became more attractive to consumers, as  shown by the share of automobile sales
by  size of  domestic cars in Figure  8.1-3,  High- and medium-priced cars and
regular and intermediate sizes of cars have been losing market  share, while
compacts  and  subcompacts have  increased  their share  dramatically.   The mar-
ket share of  imports jumped to 19 percent in  1975  after several  level years,
                                   8-15

-------
largely as a result of the meteoric climb in the price of gasoline - which
increased in cost by 34 percent from 1973 to 1974 - and the resulting in-
crease in consumer interest in fuel economy.  From 1950 to 1960 the average
passenger car's fuel economy dropped from 14.95 miles per gallon to 14.28
miles per gallon.  By 1970 it had dropped further to 13.58 miles per gallon.
The low price of gasoline and a low rate of inflation for fuel from 1960 to
1972 - the price of gasoline increased at an average annual compound growth
rate of only 1.3 percent - made gas mileage a low priority item for con-
sumers during that period.
     From 1960 to 1970 the share of the total cost of operating an automobile
accounted for by gasoline alone held steady, dropping insignificantly from
14.9 percent to 14.6 percent.  By 1974, however, gasoline accounted for 19.0
percent of the total cost of operating an automobile.  The increasing portion
                                                                          9
of total costs due to fuel costs has made consumers more mileage conscious  .
     It is inevitable that small cars will continue to increase their market
share.  Demand for better fuel economy is coming not only from the market,
but also from federal law.   In late 1975 the United States Congress passed
the Energy Policy and Conservation Act, which was signed by the President
on December 22, 1975.  Title 3, Part A, of that law requires the average
fuel economy for each auto maker's fleet to reach the following levels:

                                               Miles Per
                             Year                 Gallon
                             1978                 18.0
                             1979                 19.0
                             1980                 20.0
                             1985                 27.5
     For the model years of  1981 through 1984, the United States Secretary
of Transportation will set the reguired average fuel economy.
     The improvement in fuel economy needed for compliance  is  substantial.
In 1974 Ford's fleet averaged 14.2 miles per gallon, and General Motors'
averaged 12 miles per gallon.  Ford must improve its 1974 average  by  41 per-
cent by 1980 and 94 percent  by 1985.   General Motors'  improvement  must be
67 percent by  1980 and 129 percent by  1985  from 1974's  level.   A reduction
                                    8-16

-------
in the size of the average car is absolutely necessary in order for the two
companies to meet the requirements of the  federal government.
     General Motors has already begun its  move to smaller cars, as has
Chrysler; American Motors Corporation, of  course, is already positioned in
the. small car end of the market.  Ford is  not redesigning and retooling as
quickly as General Motors to produce smaller cars, but the change is inevi-
table.  Fortune summed up its analysis of  the impact of  the impending change
in the market on Chrysler and American Motors this way:  "Chrysler, in peri-
odic financial trouble, will probably have to ultimately abandon full-size
cars in order to concentrate its  slender resources on compact models.
American Motors will have the least  trouble meeting the  government's new
mileage standards, but is in danger  of being  crowded out of its niche in the
market as bigger companies  begin  pushing smaller cars in earnest."
     The move to smaller cars will have  a  major impact on  the marketing
strategy of the automobile  industry.   The  key company, of  course, is General
Motors.  By 1980 cars weighing  less  than 3,500 pounds will account  for more
that 70 percent of General  Motors sales, compared to  20  percent now.  The
company that long stood  not only at the top of the automobile  industry but
also at the top of the Fortune  500 list will have to  depend more on volume
for profitability and less on the sale of larger, higher margin cars.  Even
though General Motors is already the undisputed volume  leader,  its  competi-
tive  stance is likely to become even tougher.   According to the Wall  Street
Journal, a market-share  figure discussed with General Motors as a  goal was
60 percent.  While  General Motors1  Chairman Thomas A.  Murphy did  not confirm
the  60 percent figure,  he did tell the Journal:  "We want all the  business
we can get."
      In  its early years, the economics of mass production dominated the  in-
dustry's marketing strategy, as price cuts were an annual event.   General
Motors was first to recognize the marketing advantages  of styling and prod-
uct  amplification with extras.   It parlayed that head start into a dominant
market share by 1930 and has never relinquished its lead.
      New cars experienced price  stability during the 1950's and 1960's,  and
 styling and image dominated marketing.  During  the 1960's imports -
                                     8-17

-------
Volkswagen at first and then Toyota and Nissan  (Datsun) - worked to make
price and fuel economy more important in the marketplace.  As a result of
rising gasoline prices and the energy crisis of 1973 and 1974, small cars
as a whole as well as imports have improved their market share.  The trend
toward smaller cars that offer better fuel economy is guaranteed to continue
by minimum fleet averages for gasoline mileage set in federal law.
              Table 8.1-9. PRICE INDEXES FOR CONSUMER GOODS
                               1960 AND 1974
                                (1967 = 100)
Item
Automobiles , new
Gasoline
Housing
All consumer durable
commodities
1960
105.5
92.5
90.2
96.7
1974
112.8
158.7
144.9
124.3
Percent
Increase ,
1960-1974
7.7
71.6
60.6
28.5
       Source:  U.S. Bureau of the Census.  Washington, D. C.
                Statistical Abstract of the United States; 1974.
                95th edition.  1974.  p. 405, 412.
                                    8-18

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          Table 8.1-10. USER-OPERATED TRANSPORTATION COSTS,  1973
Item
New cars and net purchases of
used cars
Tires, tubes, accessories,
parts
Automobile repair, maintenance,
parking, and rental
Gasoline and oil
Tolls
Insurance premiums, less claims
paid
Total user-operated transpor-
tation
Total personal consumption
expenditures

Billions
of
Dollars
50.0
7.5
11.4
28.3
0.7
4.7
102.6
805.2
Percent of
User-
Operated
Transpor-
tion
Costs
49.0
7.0
11.0
28.0
1.0
4.0
100.0
-
Total
Personal
Consumption
Expenditures
6.2
0.9
1.4
3.5
0.1
0.6
12.7
100.0
Source:  MUMA.  1975 Automobile Facts,  p. 63.
                                 8-19

-------
                 Figure  8.1-3.   SHARE  OF AUTO SALES

                     BY  SIZE  OF  DOMESTIC CARS
W
04
50


40


30


20


10
            70
               71
 72

YEAR
73
                                        Regular and Intermediate

                                        Compacts and Subcompacts
                 Imports
                 Specialty Sports
                 High and Medium Price
74
       Source:   Ward's  1975 Automotive  Yearbook,  p.  135.
                                   8-20

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8.1.4.  Financial Performance
     General Motors' preeminence in profitability is due primarily to its
large market share in the high-price end of the market.  In Figure 8.1-4,
each company's share of total profits of the four auto makers is plotted
against its share of new-car registration.  General Motors1 profit share is
higher than its share of sales; Ford's share of profits is about the same
as its share of sales; and Chrysler and American Motors both earn a lower
share of profits than the market share they command.
     While the profit figures are not limited solely to automobiles and
light-duty trucks, those form such a high percentage of sales of the four
auto makers that the comparison is valid.
     For Ford, from 1971 to 1975 automotive sales accounted for about 90
percent of revenues.  From 1971 to 1973, automotive sales provided about
90 percent of pretax earnings but dropped to 82 percent and 74 percent, re-
spectively, in 1974 and 1975 as the recession hit autos.  At General Motors
automotive production in the United States accounted for 89 percent of total
net income in 1971 but dropped to 77 percent by 1975.   For AMC, general
automotive performance determines total corporate profitability.  Because
Checker's situation is different, the breakdown of its revenues and earn-
ings before taxes is presented in detail in Table 8.1-11.  From 1971 to 1975
sales of automotive products accounted for 40 percent of sales and resulted
in a loss before taxes equaled to one-fifth of its total earnings before
taxes.  Meaningful  data on a breakdown for International Harvester is not
available.
     General Motors, Ford, and Chrysler are known as the Big Three of the
automobile industry; American Motors  is-the last survivor  of a group of  car
manufacturers once  known as  "the  independents".  From  1966 to 1975, American
Motors  lost money in  four different years, and over the entire period lost
a net total of  $2 million.  While Chrysler reported losses three  times,  in
total,  the company  made  just over $1  billion.  Table 8.1-12 presents annual
profits by company  during the  last decade.
      General Motors leads not  just in total dollar profits but  also  in  ten-
year average return on  equity,  assets,  and  sales.   Table  8.1-13  summarizes
each company's  performance  during the last  decade.
                                    8-21

-------
     Checker Motors'  performance from 1972 to 1975 was poor, since the com-
pany as a whole earned an average of only about 3 percent on shareholders'
equity.  From Table 8.1-11 it is clear that automotive products actually
earned a negative return on investment.  International Harvester is a large
and consistently profitable company.  On sales of $5.2 billion and $4.9 bil-
lion in 1975 and 1974, the company earned $79 million and $124 million, re-
spectively.  Return on equity equaled 6 percent in 1975 and 10 percent in
1974.
     Table 8.1-14 presents 1975 and 1974 income statements for manufacturers
of passenger cars and light-duty trucks.  International Harvester is excluded
because sales of its relevant product line are such a small percentage of
total  sales that its financial statements do not reflect the economics of
the  industry at issue here.
                                    8-22

-------
  100*
   90-
•o
s   8o-<-
    70
§   60 +
 -
 c
 50-
§   40
 _
 —
    30
    20
 £  10
 0
 E-


 "•"   n
 o   o
-10




-20



-30
            Figure 8.1-4.   COMPANY PROFITS AS A PERCENT OF EARNINGS


               VERSUS SHARE OF NEW CAR REGISTRATIONS,  1966-1974
                                                           A
                                                          AA
                                                    A
                                    Note:  The number of points graphed appear

                                           different for each company because

                                           some points  occurred more than once.
                  10          20         30          40



                       Percent of  New Car Registrations
                                                             50
                                                                            60
   Source:  Wards'  Annual Reports.  1975 Automotive Yearbook,  p. 132.
                                     8-23

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        Table 8.1-11.   REVENUE AND EARNINGS BEFORE TAXES BY LINE OF



            BUSINESS FOR CHECKER MOTORS CORPORATION, 1971-1975



                          (Thousands of Dollars)
Year:
Sales Revenue and Other
Income -
Revenue from vehicle
operations
Interest and other income
Total
Earnings Before Income Taxes
and Extraordinary Credit -
Sales of automotive prod-
ucts (loss)
Revenue from vehicle opera-
tions (loss)
Interest and other income
Total
Net Earnings After Taxes and
Extraordinary Items
1971


32,610
44,876
78,654

(563)
(260)
1,168
345
313
1972


39,177
44,350
84,609

(1,238)
674
1,082
518
451
1973


30,697
40,481
72,422

1,432
515
1,244
3,191
2,084
1974


22,658
38,764
62,634

(284)
504
1,212
1,432
1,304
1975


18,716
39,014
58,883

(751)
1,627
1,153
2,029
1,900
Source:  1975 Annual Report
                                    8-24

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Table 8.1-12.  ANNUAL PROFITS AFTER TAXES  (LOSS) BY COMPANY




                    (Millions of Dollars)
Year
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
10-Year
Total
GM
1,793
1,627
1,732
1,711
609
1,936
2,168
2,398
950
1,253
16,177
Ford
621
84
627
547
516
657
870
907
361
323
5,513
Chrysler
194
203
303
99
(8)
84
220
255
(52)
(260)
1,038
AMC
(13)
(76)
12
5
(56)
10
30
86
28
(28)
(2)
    From:  Annual Reports
                           8-25

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              Table 8.1-13.  PROFIT AFTER TAXES AS  A PERCENT OF EQUITY,  ASSETS,  AND SALES BY COMPANY

Year

1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
10-Year
Average
Return on Equity

GM Ford Chrysler AMC
20,6 13,0 11.2 ( 4.9)
17.6 1.8 10.9 (42.4)
17.8 12.7 14.4 6.2
16.7 10.5 4.6 2.4
6.2 9.4 ( 0.4) (27.6)
17.9 11.8 3.7 4.8
18.5 14.6 8.8 12.4
19.1 14.1 9.3 25.0
7.6 5.8 ( 2.0) 7.2
9.5 5.1 (10.8) ( 7.7)
15.1 9.9 5.0 ( 2.5)

Return on Assets

GM Ford Chrysler AMC
13.9 7.7 6.1 ( 2.7)
12.3 1.1 5.1 (20.1)
12.4 7.0 6.8 3.4
11.5 5.9 2.1 1-3
4.3 5.2 (0.2) (12.3)
3.5 6.2 1.7 2.0
11.8 7.5 4.0 5.3
11.8 7.0 4.2 12.1
4.8 2.5 (0.8) 3.2
5.8 2.3 (4.1) ( 2.7)
9.2 5.2 2.5 ( 1.0)

Return on Sales

GM Ford Chrysler AMC
8.9 5.1 3.5 ( 1.4)
8.1 0.8 3.3 (11.5)
7.6 4.4 4.1 1.5
7.0 3.7 1.4 0.7
3.2 . 3.4 (0.1) ( 5.1)
6.8 4.0 1.1 0.8
7.1 4.3 2.3 2.2
6.7 3.9 2.2 4.9
3.0 1.5 (0.5) 1.4
3.5 1.3 (2.2) ( 1.2)
6.2 3.1 1.5 ( 0.8)

00
NJ
     From:  Annual  Reports

-------
                Table 8.1-14.  INCOME STATEMENTS FOR MOTOR VEHICLE  MANUFACTURERS  - 1974 AND 1975

                                              (Millions of  Dollars)

Item

Revenues -
Net sales
g^
Income adjustments
Total Income
Expenses -
Cost of sales
General and administrative0
Depreciation of real es-
tate, plants and equip-
ment
Amortization of special
tools
Interest expense
Total Expenses
Income Before Taxes
Income Taxes (Credit)
Net Income
General Motors

1975 1974

35,725 31,550
(11) 121
35,714 31,671

31,256b 28,288b
NA NA

906 847

1,180 858
NA NA
33,342 29,993
2,371 1,677
1,118 727
1,253 950
Ford

1975 1974

24,009 23,621
184 33
24,193 23,654

21,111 20,668
1,463 1,417

584 531

435 393
124 83
23,717 23,092
475 563
152 202
323 361
Chrysler

1975 1974

11,598 10,860
(84) (8)
11,514 10,852

10,538 9,814
747 740

124 182

171 139
168 108
11,748 10,983
(234) (131)
26 (78)
(260) (53)
AMC

1975 1974

2,282 2,000
17 23
2,299 2,023

2,048 1,736
216 199

19 16

35 24
16 7
2,334 1,982
(36) 42
(8) 14
(28) 28
Checker

1975 1974

77.5 83.5
1.2 1.1
78.7 84.6

67.8 74.1
5.9 5.6

4.6 4.3

NA NA
od od
76.9 84.0
0.4 0.6
0.1 0.1
0.3 0.5
00
to
       Includes other income, equity in nonconsolidated subsidiaries, and accounting changes.
       Includes general and administrative expenses.
       Includes special compensation provisions.
Equal to only $47,000 in 1975 and $51,000 in 1974.
     Note:  Numbers may not total exactly because of the rounding out of the figures.
     From:  Annual Reports, 10-K filings with Securities and Exchange Commision.

-------
8.1.5  Capital Structure
     There are two separate capital structures in the automobile industry.
One provides capital for the manufacturing and marketing of automobiles, th ;
other consumer financing for the purchase of vehicles.  Manufacturing and
marketing are financed primarily with equity, while consumer automobile
loans are financed primarily with debt through subsidiary corporations.  We
are concerned only with the first of the two capital structures, since con-
sumer loan financing subsidiaries will not be materially affected by regula-
tions on solvent emission.
     It is important to stress that the debt capital raised by the credit
affiliates is not available for the purchase of capital equipment or for op-
erating expenses.   Investors purchase the securities of the credit companies
with the understanding that the funds will be used primarily to finance in-
stallment loans  secured by the vehicle purchased.
     Historically,  automobile manufacturers have used primarily equity  finan-
cing.  Figure 8.1-5 portrays the  capital  structure of the  industry during  the
last ten years.   Figure  8.1-6 explains why the  industry has been reluctant to
depend heavily on long-term debt.  The industry is extremely volatile,  which
makes  debt risky.   Over  the past  ten years,  the automobile industry's  capital
structure as a whole has  consisted of only 10 percent debt.
     A brief glance at  some violent ups and  downs in the fortunes of
Chrysler and Ford in past years indicates the automobile market's volatility
and illustrates  how important styling is  in  marketing.  Chrysler decided  for
the 1954 model year to retain its 1953 designs,  which had  generated a  market
share  of  20  percent and  profits of $200 million.  The result was a market
share  of  13  percent and  profits of only  $21  million. Chrysler, happy  with
the 1957  design, made  a similar decision  for the 1958 model year; market
share  fell  from 18 percent to  14  percent, and earnings  went  from $252  millic n
In 1957  to  a loss of  $73 million  before  tax credits  the next  year.   The re-
 sounding failure of the Edsel  is  well known.  Ford's experience with the
 Mustang was equally spectacular,  only in that instance  resulted in success.
 Heavy debt financing  in a business with such fluctuations would be risky.
                                    8-28

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    Figure  8.1-5.   CAPITAL  STRUCTURE OF THE AUTO INDUSTRY



                       (TEN-YEAR AVERAGE)
100
90
80
70
+J 60
c
cu
CJ
n
£ 50
40
30
20
10













—
























-
—






















i
r—





















GM Ford Chrysler













I
—























—

























AMC Total
Industry
                              Debt



                       |~~|    Equity
Source:  Annual Reports
                          8-29

-------
00

u>
o
          W
o
Q

M-l
O

in
c
o
•H
         •H
         s

         c
         •H

         (Q
         -P
         •H
                            Figure  8.1-6.  VOLATILITY OF  TOTAL PROFITS OF GM, FORD,


                                       CHRYSLER, AND AMC FOR ALL PRODUCTS
             4,000
3,000   -•
    2,000   •'
             1,000  --
                        66
                      67
                         68
69
70
71
72
73
74
75
                                            Year (1966  - 1975)
            Source:  Annual Reports

-------
8.1.6.  Production
     Assembly lines are highly integrated operations.  Continuous operation
depends on every part performing at line speed.  The slowest operation sets
the maximum speed for the line as a whole.  The degree of backward integra-
tion varies substantially by company.  Ford is involved even in steel pro-
duction; smaller companies buy major components such as engines.
     The auto makers run their parts factories at a predetermined operating
rate, which greatly simplifies the tasks of management.  Additional require-
ments are filled by contract suppliers, which relieves the automobile manu-
facturers of a portion of the burden and cyclical risk of responding to mar-
ket fluctuations.  Naturally these risks are transferred to suppliers.
Double sources are usually maintained for essential components and the com-
panies reserve the right to manufacture parts in case of labor strikes
against suppliers.
     Coating operations are a relatively small part of an automobile assem-
bly complex, but are extremely important.  Because the line operates continu-
ously, a change in even a small part can have important effects.  In the con-
text of this report, coating operations refer only to the coating of the
vehicle body.  Parts such as air filter covers are painted separately.
     At present the topcoat color is potentially different for each succes-
sive vehicle passing through an assembly line.  This ability to change colors
is important to the simultaneous scheduling of dealer custom orders and of
speculative automobile output.  Coating quality is also an important
marketing consideration.
                                    8-31

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8.1.7.  References to Section 8.1.

1.     Fortune.   May 1976.   pp. 316 ff.
2.     Ford, Henry.  My Life and Work.  Doubleday, New York, 1923.  p. 72.
3.     Sloan, A.P., Jr.  My Years with General Motors.  McFadden, New
       York, 1965.  p. 163.
4.     Abernathy, William J. and Kenneth Wayne.  Limits of the Learning
       Curve.  Harvard Business Review.  September-October 1974.
       pp.  Ill, 115.
5.     Snell, Bradford C.  American Ground Transport.  U.S. Government
       Printing Office, Washington, D. C. 1973.  p. 56.

6.     White, Lawrence J.  The Automobile Industry Since 1945. Harvard
       University Press, Cambridge, Massachusetts, 1971.  p. 263.
7.     Lanzillotti,  Robert F.  The Automobile  Industry.  In The  Structure
       of American Industry.  Walter  Adams,  Editor.   Fourth Edition.
       Macmillan,  New York, 1971.  p.  286.
 8.     White.   The Automobile Industry Since 1945.   p.  104.
 9.     U. S. Bureau of The Census,  Statistical Abstract of the United
       States.   1974.  Government Printing Office,  Washington, D. C.
       1974. pp 560-561.

 16.    Beman, Lewis.  The  Coming Collision in the Auto Market.  Fortune,
       July 1976.  pp. 100,101.
 11.    The  Wall Street Journal.   January 7, 1976.  p. 1.
                                      8-32

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8.2.  COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS
     This section presents estimates of capital and annualized operating
costs for new facilities and for reconstructed facilities for the applica-
tion of low hydrocarbon emitting primer coatings and topcoatings in the
transportation industry; and the estimated effects on per-body primer coat-
ing and topcoating costs.  The models selected for analysis are a passenger
car body manufacturing facility, SIC 3711, having an output of 211,200
units per year (8 hours per shift, 2 shifts per day, 5 days per week, 240
days per year, 3,840 hours per year, 55 car bodies per hour); and a light-
duty truck body manufacturing facility, SIC 3713, having an output of
145,920 units per year  (38 bodies per hour, 3,840 hours per year).  Two-
shift operation, 240 days per year, represents standard industry practices.
     The base cases are those which apply to the passenger car or light-duty
truck body solvent-based prime coatings and solvent-based topcoatings over
the solvent-based prime coats.  Lines using solvent-based prime coatings and
solvent-based topcoats typically exhaust to the atmosphere about 85 percent
of the solvent which is vaporized in the coating line spray booths, accord-
ing to industry sources, the balance being captured by spray booth water
curtains; and also exhaust to the atmosphere without treatment all of the
solvent-containing exhaust air from the coating line ovens.  Electrophoretic
deposition  (EDP) dip water-borne prime coatings have been displacing solvent-
based prime coatings.
     The following sections cover new facilities  (8.2.1) and reconstructed
facilities  (8.2.2).  No cases have been found which meet the criteria for
modified facilities.
     In the section on  new facilities, for both passenger car bodies and
light-duty truck bodies, the  following comparisons are made:
      (1)    The solvent-based prime coating base case is compared with
            thirty-eight prime coating cases comprising incorporation
            of carbon adsorption and/or incinerator control  devices  on
            spray booths and/or ovens in  a solvent-based prime coating
            line; water-borne EDP dip prime coat with no guide coat;
            water-borne EDP dip prime coat with  solvent-based guide
                                     8-33

-------
           coat, with and without  spray booth and oven  control
           devices; and water-borne  EDP dip prime coat  with water-
           borne guide coat.
     (2)    The  solvent-based  topcoat base  case is compared with
           twenty-nine topcoat  cases comprising incorporation of
           carbon  adsorption  and/or  incinerator control devices on
           spray booths and/or  ovens in a  solvent-based topcoating
           line; water-borne  topcoat; and  electrostatic spray pow-
           der topcoat.
     In the section on reconstructed  facilities, for both passenger  car bodies
and light-duty truck bodies,  the following  comparisons are made:
     (1)    The solvent-based prime coating base case is compared with
            twenty-seven cases comprising addition of carbon adsorption
            and/or incinerator add-on control devices to spray booths
            and/or ovens on a solvent-based prime coating line.
     (2)    The solvent-based topcoat base case is also compared with
            twenty-seven cases comprising addition of carbon adsorp-
            tion and/or incinerator add-on control devices to spray
            booths and/or ovens on a  solvent-based topcoating line.
     For solvent-based prime coating  and solvent-based  topcoat lines, the fol-
lowing spray booth control devices applicable  to both new and reconstructed
facilities are included:
            Carbon adsorption, 1 percent LEL;
            Incinerator, 1 percent LEL, thermal, primary heat
                 exchange;
     iii.   Incinerator, 1 percent LEL, catalytic, primary  heat
                 exchange;
and the following oven control devices applicable to both new and reconstruc
ted facilities are included:
     i.     Carbon adsorption,  10  percent  LEL;
     ii.    Incinerator, 10 percent  LEL, thermal,  primary  heat
                 exchange;
                                     8-34

-------
     iii.    Incinerator,  10 percent LEL,  thermal,  primary and
                 secondary heat exchange;
     iv.     Incinerator,  10 percent LEL,  catalytic,  primary
                 heat exchange;
     V.      Incinerator,  10 percent LEL,  catalytic,  primary
                 and secondary heat exchange;
     vi.     Incinerator,  5 percent LEL, catalytic, primary and
                 secondary heat exchange.
     For the solvent guide coat over the water-borne EDP dip prime coat,  the
following spray booth control devices are included:
     i.      Carbon adsorption, 1 percent LEL;
     ii.     Incinerator, 1 percent LEL, catalytic, primary heat
                 exchange;
and the following oven control devices are included:
     i-      Carbon adsorption, 10 percent LEL;
     ii-     Incinerator, 10 percent LEL, catalytic, primary
                 and  secondary heat exchange.
     The following code  is used to identify the compositions of the various
alternative cases in  this  section:
                                     8-35

-------
                IDENTIFICATION KEY FOR CODING EMISSION SYSTEMS
Code    Identification of Process or Control Device	
   Prime Coating
I       Solvent-borne prime coat  -  spray
II      Prime coat/electrodeposition/water-borne dip/no guide coat
III     Prime coat/electrodeposition/water-borne dip/solvent guide coat
IV      Prime coat/electrodeposition/water-borne dip/water-borne guide coat

   Top Coating
A       Solvent-borne topcoat
B       Water-borne topcoat
C       Powder topcoat
.  Spray Booth Controls for Either Prime Coat or Topcoat
1       Spray booth/carbon adsorption/1 percent LEL
2       Spray booth/incinerator/I percent LEL/thermal/primary heat exchange
3       Spray booth/incinerator/I percent LEL/catalytic/primary heat exchange

   Oven Controls for Either Prime Coat or Topcoat
a       Oven/carbon adsorption/10 percent LEL
b       Oven/incinerator/10 percent LEL/thermal/primary heat exchange
c       Oven/incinerator/10 percent LEL/thermal/primary and secondary
            heat exchange
d       Oven/incinerator/10 percent LEL/catalytic/primary heat exchange
e       Oven/incinerator/10 percent LEL/catalytic/primary and secondary
            heat exchange
f       Oven/incinerator/5 percent LEL/catalytic/primary and secondary
            heat exchange

EXAMPLE:
Case    Code    Control System		
Hi-la  in     Prime  coat/electrodeposition/water-borne dip/no  guide coat
        1       Spray  booth/carbon adsorption/1 percent LEL
        a       Oven adsorption/10 percent  LEL
                                     8-36

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8.2.1.  Cost Effectiveness Summarized
     For prime coat application, the most cost-effective emission control mea-
sure both in terms of incremental annualized costs and emission reduction
would be electrodeposition of water-borne coatings (EDP) were it not for the
fact that a guide coat or primer surfacer is almost always used in conjunction
with the EDP coating to provide a better surface for topcoat application.  In-
clusion of the guide coat with the EDP system increases costs considerably
even though high emission reduction is provided.  If means could be found to
eliminate the guide coat, EDP would certainly be the most effective emission
reducing system for prime coat application  (see Case II, Tables 8.2-1 and
8.2-5).
     The most cost effective control means would appear to be carbon adsorp-
tion systems, for both spray booth and oven emission control  (see I-la in the
above-mentioned tables).  Incinerators for oven emission control are also rela-
tively low as far as cost per ton of solvent removed is concerned, but their
use results in only 11 percent reduction in total line emission.  Incineration
as a means of controlling spray booth emissions is very costly primarily be-
cause of the high fuel costs even with heat recovery  (see 2 and 3 in the above
tables).
     For topcoat application, carbon adsorption units for spray booth emission
control combined with either carbon adsorption or incinerators on the bake
ovens appears to be most cost effective, achieving 90 percent reduction  for
under $1,000 per ton of  solvent removed  (see A-le through A-lb, tables 8.2-3
and 8.2-7).  Powder coating - while for  all intents and purposes eliminating
the solvent emission problem -  is expensive, rating with catalytic  incinera-
tion on spray booths and ovens  (see C  in the above-mentioned  tables).  The use
of water-borne coatings, however, provides  exemption  from most state and local
emission control laws, as will  be  seen.
     Only  thirteen  states currently have statewide regulations controlling
organic solvent emissions  from stationary  sources, but  eight  other  states with
a total of twelve districts within these states have  promulgated  individual,
non-statewide  regulations.   Most of these  regulations are  based on  or  are
similar to Rule  66  of  the  Los  Angeles  County Air Pollution Control  District.
                                       8-37

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This regulation limits oven emissions to 15 pounds per day per oven and all
emissions of photoreactive solvents from any machine, equipment, or other con-
trivance to 40 pounds per day.  The limit on "exempt" solvents is 3000 pounds
per day.  The law permits, however, these limits to be exceeded if the total
emissions have been reduced by 85 percent or more.  Most of the state and
local regulations follow these limits pretty closely.
     For the automobile or light-duty truck manufacturer, the oven emission
standards of 15 pounds per day could not possibly be met if it were not for
the 85 percent reduction clause.  As an example, the oven on a typical auto-
mobile topcoat line will emit over 1600 pounds of organic matter per day.  At
85 percent reduction, it still would emit over 240 pounds per day.  Costs for
controlling oven emissions by incineration or carbon adsorption are fairly low,
ranging  from $250 to  $650 per ton of solvent removed, depending on the type of
incinerator used and  the degree of heat recovery.  Carbon adsorption on ovens
is generally in the low end of this range.
      Four  states and  four districts have upper limits on the amounts of ex-
empt  (non-photoreactive)  solvents  emitted  from sources  other than ovens.
These generally follow Rule 66, which places a limit of 3000 pounds per day  -
except for Connecticut, which has  a  limit  of 800 pounds per day.  Achieving
these limits will  call for  controls  such as carbon adsorbers or incinerators
on spray booths or a  switch to a water-borne system (or powder coating for
topcoats).
      Because of  the large amounts  of air which  must be  processed from a typi-
 cal automotive spray booth,  control  by carbon  adsorbers on incineration be-
 comes expensive  - especially incineration, which can cost over $4000 per ton
 of solvent removed (see  A-2,  Table 8.2-3).   On the other hand, water-borne
 coatings and powder coatings for topcoat application to automobiles or light-
 duty trucks are also expensive, ranging from $2,300 to $2,800 per ton of sol-
 vent reduction (from organic solvent-borne topcoat case) for powder coating to
 almost  $4,000 per ton for water-borne topcoats  (see B and C in Table 8.2-3).
                                        8-38

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8.2.2.  Water Pollution and Solid Waste Disposal
     Control measures such as incineration and carbon adsorption do not con-
tribute to either water pollution or increase waste disposal problems.   Spent
carbon is usually returned to the manufacturer and reprocessed.
     In the electrodeposition process, water pollution and waste disposal of
sludge was initially a problem, but as discussed in Chapter 7, in today's
modern operation ultrafiltration is used to automatically remove amines, sol-
vents, and water-solubles which are left behind in the tank.  Hence, it is
possible to set up a completely closed system with practically no waste
problems.
    .With water-borne topcoat application, however, both increased water pol-
lution and increased sludge disposal problems occur.  The sludge problem, es-
pecially, is more severe with water-borne coatings, as they tend to form
gummy agglomerates requiring more  frequent and more difficult cleaning of set-
tling tanks, as was discussed in Chapter  7.  In the cost models, liquid and
sludge disposal costs were increased by  50 percent to reflect this.  Disposal
costs, however, play a  relatively  small  part in overall coating operation
costs.

8.2.3.  New Facilities
      Tables 8.2-1 and  8.2-2  list  the  thirty-eight alternative  cases and the
base  case  for new facilities  for  prime coating  of passenger car bodies,  rank-
ing them in decreasing order of emissions reduction and,  where two or  more
cases have equivalent  levels of emissions reduction,  in increasing order of
incremental annualized cost per car body over  the base  case.   Cost effective-
ness  is  shown  as  incremental annualized cost per car body over the base case.
      Table 8.2-1  shows, for each  case, percent emission reduction from the
base  case,  incremental annualized prime coating cost per car body over the
base  case, total  annualized prime coating cost per body,  decreased emission
over  the base  case  in metric tons per year,  and cost per metric  ton of re-
duced emission (defined as incremental annualized costs over the base case
divided by decreased annual emission).  Table 8.2-2 shows, for each case,
 total capital investment, increased investment over the base case, total
                                     8-39

-------
annualized costs, incremental annualized costs over the base case, and solvent
emitted in metric tons per year and pounds per day.   Costs are DSR estimates
as prepared for the second interim report to EPA, Contract 68-02-2062.
     Following the same format as Tables 8.2-1 and 8.2-2, Tables 8.2-3 and
8.2-4, respectively, list data for the twenty-nine alternative cases and the
base case for new facilities for topcoating of passenger car bodies; Tables
8.2-5 and 8.2-6, respectively, list data for the thirty-eight alternative
cases and the base case for new facilities for prime coating of light-duty
truck bodies; and Tables 8.2-7 and 8.2-8, respectively, list data for the
twenty-nine alternative cases and the base case for new facilities for top-
coating of light-duty truck bodies.
 *
 DeBell  &  Richardson,  Inc.,  now
 Springborn  Laboratories,  Inc.
                                     8-40

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Table 8.2-1.  ALTERNATIVE CASES - NEW FACILITIES



 PASSENGER CAR BODIES, PRIME COATING  -  PART I

Case

II
Ill-la
III-le
III-3a
III-3e
IV
III-l
III-3
I-la
I-le
I-ld
I-lc
I-lf
I-lb
I-3a
I-3e
I- 3d
I-3c
I-3f
I-3b
I-2a
I-2e
I-2d
I-2c
I-2f
I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
I-a
I-e
I-d
I-c
I-f
I-b
I (Base

Emission
Deduction ,
Percent

96
94
94
94
94
92
91
91
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
75
75
72
11
11
11
11
11
11
0

Incremental
Annualized
Cost/Body,
$
1.58
11.98
12.04
13.93
13.99
15.99
11.90
13.85
3.23
3.25
3.28
3.29
3.30
3.35
11.09
11.11
11.14
11.15
11.16
11.21
18.00
18.02
18.05
18.06
18.07
18.12
3.08
10.94
17.85
11.11
11.17
11.03
0.15
0.17
0.20
0.21
0.22
0.27
-

Total
Annualized
Cost/Body,
$
24.81
35.21
35.27
37.16
37.22
39.22
35.13
37.08
26.46
26.48
26.51
26.52
26.53
26.58
34.32
34.34
34.37
34.38
34.39
34.44
41.23
41.25
41.28
41.29
41.30
41.35
26.31
34.17
41.08
34.34
34.40
34.26
23.38
23.40
23.43
23.44
23.45
23.50
23.23

Decreased
Emission,
Metric Tons
Per Year
983
957
957
957
957
942
931
931
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
807
807
807
761
761
734
110
110
110
110
110
110
—
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
340
2,645
2,658
3,075
3,088
3,586
2,702
3,145
745
749
754
757
759
770
2,554
2,558
2,564
2,567
2,569
2,580
4,147
4,151
4,156
4,159
4,161
4,172
806
2,862
4,672
3,086
3,102
3,174
296
330
377
402
419
509
—
                      8-41

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Table 8.2-2.  ALTERNATIVE CASES - NEW FACILITIES



 PASSENGER CAR BODIES,  PRIME  COATING  -   PART  II

Case

II
Ill-la
Ill-le
III-3a
III-3e
IV
III-l
III-3
I-la
I-le
I-ld
I-lc
I-lf
I-lb
I-3a
I-3e
I-3d
I-3c
I-3f
I-3b
I-2a
I-2e
I-2d
I-2c
I-2f
I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
I-a
I-e
I-d
I-c
I-f
I-b
I (Base)
Total
Capital
Investment,
$1,000
11,970
16,376
16,452
16,416
16,492
20,801
16,339
16,379
9,979
10,031
10,011
10,033
10,031
10,014
10,051
10,102
10,083
10,105
10,102
10,085
9,517
9,569
9,549
9,571
9,569
9,552
9,893
9,965
9,431
15,748
15,824
15,711
7,394
7,446
7,426
7,448
7,446
7,429
7,308
Increased
Investment
Over Base,
$1,000
4,662
9,068
9,144
9,108
9,184
13,493
9,031
9,071
2,671
2,723
2,703
2,725
2,723
2,706
2,743
2,794
2,775
2,797
2,794
2,777
2,209
2,261
2,241
2,263
2,261
2,244
2,585
2,657
2,123
8,440
8,516
8,403
86
138
118
140
138
121
-
Total
Annualized
Costs ,
$1,000
5,240
7,438
7,450
7,850
7,862
8,284
7,420
7,832
5,589
5,593
5,598
5,601
5,602
5,612
7,248
7,252
7,257
7,260
7,262
7,272
8,709
8,713
8,718
8,720
8,722
8,732
5,556
7,216
8,676
7,254
7,266
7,236
4,939
4,942
4,948
4,950
4,952
5,467
4,906
Incremental
Annualized
Costs
$1,000
334
2,532
2,544
2,944
2,956
3,378
2,514
2,926
683
687
692
695
696
706
2,342
2,346
2,351
2,354
2,356
2,366
3,803
3,807
3,812
3,814
3,816
3,826
650
2,310
3,770
2,348
2,360
2,330
33
36
42
44
46
561
—
Solvent Emitted |
Metric
Per Year
37
63
63
63
63
78
89
•89
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
213
213
213
250
250
286
910
910
910
910
910
910
1,020
Pounds !
Per Day i
339
577
577
577
577
715
816
816
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
1,952
1,952
1,952
2,374
2,374
2,622
8,342
8,342
8,342
8,342
8,342
8,342
9,350
                       8-42

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Table 8.2-3.  ALTERNATIVE CASES - NEW FACILITIES



   PASSENGER CAR BODIES, TOPCOATING  -  PART I

Case
C
A-le
A-la
A-lc
A- Id
A-lf
A-lb
A-3e
A-3a
A-3c
A- 3d
A-3f
A-3b
A-2e
A-2a
A-2c
A-2d
A-2f
A-2b
B
A-l
A- 3
A-2
A-e
A-a
A-c
A-d
A-f
A-b
A (Base

Emission
Reduction ,
Percent
100
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
80
79
79
79
11
11
11
11
11
11
) o

Incremental
Annualized
Cost/Body
$
19.76
4.19
4.21
4.23
4.24
4.28
4.32
14.98
15.00
15.02
15.03
15.07
15.11
24.42
24.44
24.46
24.47
24.51
24.55
24.09
4.00
14.79
24.23
0.19
0.21
0.23
0.24
0.28
0.32
-

Total
Annualized
Cost/Body,
$
81.08
65.51
65.53
65.55
65.56
65.60
65.64
76.30
76.32
76.34
76.35
76.39
76.43
85.74
85.76
85.78
85.79
85.83
85.87
85.41
65.32
76.11
85.55
61.51
61.53
61.55
61.56
61.60
61.64
61.32

Decreased
Emission,
Metric Tons
Per Year
1,489
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1.340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,194
1,179
1,179
1,179
161
161
161
161
161
161
0
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
2,803
661
664
667
668
675
681
2,362
2,365
2,368
2,369
2,376
2,382
3,849
3,852
3,856
3,856
3,863
3,870
3,920
717
2,650
4,340
251
278
305
311
368
421
-
                       8-43

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Table 8.2-4  ALTERNATIVE CASES - NEW FACILITIES



  PASSENGER CAR BODIES,  TOPCOATING  -  PART II

Case


C
A-le
A- la
A-lc
A-ld
A-lf
A-lb
A-3e
A-3a
A-3c
A- 3d
A-3f
A-3b
A-2e
A-2a
A-2c
A-2d
A-2f
A-2b
B
A-l
A-3
A-2
A-e
A-a
A-c
A-d
A-f
A-b
A (Base)
Total
Capital
Investment,
$1,000

43,800
22,321
22,290
22,317
22,301
22,336
22,295
22,567
22,536
22,564
22,547
22,583
22,541
21,840
21,809
21,836
21,820
21,855
21,814
34,332
22,168
22,415
21,687
18,945
18,914
18,941
18,925
18,960
18,919
18,792
Increased
Investment
Over Base,
$1,000

25,008
3,529
3,498
3,525
3,509
3,544
3,503
3,775
3,744
3,772
3,755
3,791
3,749
3,048
3,017
3,044
3,028
3,063
3,022
15,540
3,376
3,623
2,895
153
122
149
133
168
127
-
Total
Annual ized
Costs ,
$1,000

17,124
13,835
13,840
13,844
13,845
13,854
13,863
16,115
16,119
16,124
16,125
16,134
16,142
18,107
18,111
18,116
18,117
18,126
18,134
17,631
13,795
16,075
18 , 067
12,990
12 , 995
12,999
13,000
13,009
13,018
12,950
Incremental
Annual ized
Costs ,
$1,000

4,174
885
890
894
895
904
913
3,165
3,169
3,174
3,175
3,184
3,192
5,157
5,161
5,166
5,167
5,176
5,184
4,681
845
3,125
5,117
40
45
49
50
59
68
-
Solvent Emitted
Metric
Tons
Per Year
0
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
295
310
310
310
1,328
1,328
1,328
1,328
1,328
1,328
1,489
Pounds
Per Day

0
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
2,704
2,842
2,842
2,842
12,173
12,173
12,173
12,173
12,173
12,173
13,649
                      8-44

-------
 Table 8.2-5.  ALTERNATIVE CASES •>• NEW FACILITIES



LIGHT-DUTY TRUCK BODIES, PRIME COATING   -  PART I
Case
II
Ill-la
Ill-le
III-3a
III-3e
IV
III-l
III-3
I-la
I-le
I-ld
I-lf
I-lc
I-lb
I-3a
I-3e
I- 3d
I-3f
I-3c
I-3b
I-2a
I-2e
I-2d
I-2f
I-2c
I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
I-a
I-e
I-d
I-f
I-c
I-b
I (Base)
Emission
Reduction ,
Percent
97
94
94
94
94
92
91
91
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
73
73
70
11
11
11
11
11
11
0
Incremental
Annualized
Cost/Body
$
-0.14
10.36
10.46
12.29
12.39
14.12
10.26
12.19
3.11
3.18
3.19
3.19
3.21
3.26
9.83
9.90
9.91
9.91
9.93
9.98
15.70
15.77
15.78
15.78
15.80
15.85
2.94
9.66
15.53
9.36
9.46
9.26
0.17
0.24
0.25
0.25
0.27
0.32
-
Total
Annualized
Cost/Body,
$
22.51
33.01
33.11
34.94
35.04
35.77
32.91
34.84
25.76
25.83
25.84
25.84
25.86
25.91
32.48
32.55
32.56
32.56
32.58
32.63
38.35
38.42
38.43
38.43
38.45
38.50
25.59
32.31
38.18
32.01
32.11
31.91
22.82
22.89
22.90
22.90
22.92
22.97
22.65
Decreased
Emission,
Metric Tons
Per Year
628
610
610
610
610
600
592
592
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
514
514
514
475
475
456
70
70
70
70
70
70
0
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
-33
2,477
2,499
2,940
2,962
3,432
2,528
1,992
780
796
798
800
805
818
2,458
2,474
2,477
2,479
2,484
2,496
3,027
3,942
3,945
3,946
3,951
3,964
837
2,745
4,412
2,879
2,908
2,963
356
492
513
530
570
677
-
                       8-45

-------
 Table 8.2-6. ALTERNATIVE  CASES  -  NEW FACILITIES



LIGHT-DUTY TRUCK BODIES, PRIME COATING  -   PART II


Case

II
Ill-la
Ill-le
III-3a
III-3e
IV
III-l
III-3
I-la
I-le
I-ld
I-lf
l-lc
I-lb
I-3a
I-3e
I- 3d
I-3f
I-3c
I-3b
I-2a
I-2e
I-2d
I-2f
I-2c
I-2b
1-1
1-3
1-2
Ill-a
Ill-e
III
I-a
I-e
I-d
I-f
I-c
I-b
I (Base)

Total
Capital
Investment ,
$1,000
8,524
12,019
12,097
12,037
12,115
14,834
11,989
12,007
6,917
6,981
6,965
6,971
6,990
6,973
6,861
6,925
6,909
6,915
6,934
6,917
6,565
6,629
6,612
6,619
6,638
6,620
6,856
6,800
6,504
11,554
11,632
11,524
5,255
5,319
5,303
5,309
5,328
5,311
5,194

Increased
Investment
Over Base,
$1,000
3,330
6,825
6,903
6,843
6,921
9,640
6,795
6,813
1,723
1,787
1,771
1,777
1,796
1,779
1,667
1,731
1,715
1,721
1,740
1,723
1,371
1,435
1,418
1,425
1,444
1,426
1,662
1,606
1,310
6,360
6,438
6,330
61
125
109
115
134
117
-

Total
Annualized
Costs,
$1,000
3,285
4,818
4,831
5,100
5,114
5,365
4,802
5,085
3,761
3,771
3,772
3,773
3,776
3,784
4,741
4,751
4,752
4,753
4,756
4,763
5,598
5,607
5,609
5,610
5,613
5,620
3,736
4,716
5,573
4,672
4,686
4,657
3,331
3,341
3,342
3,343
3,346
3,353
3,306

ncremental
Annualized
Costs,
$1,000
-21
1,512
1,525
1,794
1,808
2,059
1,496
1,179
455
465
466
467
470
478
1,435
1,445
1,446
1,447
1,450
1,457
2,292
2,301
2,303
2,304
2,307
2,314
430
1,410
2,267
1,366
1,380
1,351
25
35
36
37
40
47
-
_ (
Solvent Emitted [
Metric
Tons
Per Year
21
39
39
39
39
49
57
57
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
135
135
135
174
174
193
579
579
579
579
579
579
649
Pounds
Per Day
192
357
357
357
375
449
522
522
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
1,237
1,237
1,237
1,595
1,595
1,769
5,307
5,307
5,307
5,307
5,307
5,307
5,949
                          8-46

-------
Table 8.2-7.  ALTERNATIVE CASES - NEW FACILITIES



 LIGHT-DUTY TRUCK BODIES, TOPCOATING  -  PART I

Case

C
A-la
A-le
A-ld
A-lc
A-lf
A-lb
A-3a
A-3e
A-3d
A-3c
A-3f
A-3b
A-2a
A-2e
A-2d
A-2c
A-2f
A-2b
A-l
A- 3
B
A-2
A-a
A-e
A-d
A-c
A-f
A-b
A (Base

Emission
Reduction,
Percent

100
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
79
11
11
11
11
11
11
) o
Incremental
Annualized
Cost/Body
g
T*
17.08
4.94
4.96
5.00
5.03
5.05
5.10
16.04
16.06
16.10
16.13
16.15
16.20
26.06
26.08
26.12
26.15
26.17
26.22
4.72
15.82
20.85
25.84
0.22
0.24
0.28
0.31
0.33
0.38
-
Total
Annualized
Cost/Body,
$

80.61
68.47
68.49
68.53
68.56
68.58
68.53
79.57
79.59
79.63
79.66
79.68
79.73
89.59
89.61
89.65
89.68
89.70
89.75
68.25
79.35
84.38
89.37
63.75
63.77
63.81
63.84
63.86
63.91
63.53
Decreased
Emission,
Metric Tons
Per Year

1,080
972
972
972
972
972
972
972
972
972
972
972
972
972
972
972
972
972
972
855
855
851
855
117
117
117
117
117
117
0
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
2,306
743
745
752
755
759
767
2,410
2,412
2,419
2,422
2,426
2,434
3,914
3,916
3,923
3,926
3,930
3,938
806
2,700
3,575
4,409
279
296
356
380
416
481
—
                       8-47

-------
Table 8.2-8.  ALTERNATIVE CASES - NEW FACILITIES



LIGHT-DUTY  TRUCK BODIES,  TOPCOATING  -   PART II

Case
•
C
A-la
A-le
A-ld
A-lc
A-lf
A-lb
A-3a
A-3e
A-3d
A-3c
A-3f
A-3b
A-2a
A-2e
A-2d
A-2c
A-2f
A-2b
A-l
A-3
B
A-2
A-a
A-e
A-d
A-c
A-f
A-b
A (Base)
Total
Capital
Investment,
$1,000
30,356
16,190
16,242
16,223
16,244
16,247
16,225
16,099
16,150
16,131
16,153
16,155
16,133
15,565
15,617
15,598
15,619
15,622
15,600
16,104
16,013
23,466
15,479
13,442
13,494
13,475
13,496
13,499
13,477
13,356
Increased
Investment
Over Base
$1,000
17,000
2,834
2,886
2,867
2,888
2,891
2,869
2,743
2,794
2,775
2,797
2,799
2,777
2,209
2,261
2,242
2,263
2,266
2,244
2,748
2,657
10,110
2,123
86
138
119
140
143
121
-
Total
Annualized
Costs,
$1,000
11,762
9,993
9,995
10,002
10,004
10,008
10,016
11,613
11,615
11,622
11,624
11,628
11,636
13,074
13,076
13,083
13,085
13,090
13,097
9,960
11,580
12,313
13,041
9,304
9,306
9,313
9,315
9,319
9,327
9,271
Incremental
Annualized
Costs ,
$1,000
2,491
722
724
731
733
737
745
2,342
2,344
2,351
2,353
2,357
2,365
3,803
3,805
3,812
3,814
3,819
3,826
689
2,309
3,042
3,770
33
35
42
44
48
56
-
Solvent Emitted
Metric
Tons
Per Year
0
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
225
225
229
225
963
963
963
963
963
963
1,080
Pounds
Per Day
0
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
2,062
2,062
2,099
2,062
8,827
8,827
8,827
8,827
8,827
8,827
9,900
                       8-48

-------
8.2.4.  Reconstructed Facilities
     Tables 8.2-9 and 8.2-10 list the twenty-seven alternative cases for
reconstructed facilities for prime coating of passenger car bodies, rank-
ing them in decreasing order of emissions reduction and, where two or more
cases have equivalent levels of emissions reduction, in increasing order of
incremental annualized cost per car body.  Cost effectiveness is shown as
incremental cost per car body over the base case.
     Table 8.2-9 shows, for each case, percent emission reduction from the
base case, incremental annualized prime  coating cost per car body over the
base case, decreased emission over the base case in metric tons per year,
and cost per metric ton of reduced emission  (defined as incremental annu-
alized costs over the base case divided  by decreased annual emission).
     Table 8.2-10 shows,  for each case,  capital investment, incremental an-
nualized costs  over the base case, and  solvent emitted in metric tons per
year and pounds per day.   Costs  are  DeBell  &  Richardson estimates  as pre-
pared for the  second  interim report  to  EPA, Contract  68-02-2062.
     Following the  same  format as Tables 8.2-9 and 8.2-10,  Tables  8.2-11
and 8.2-12,  respectively, list data for the twenty-seven  alternative  cases
for reconstructed  facilities for topcoating of passenger  car  bodies;  Tables
8.2-13  and 8.2-14,  respectively,  list data for  the twenty-seven alternative
cases for reconstructed facilities for prime coating of light-duty truck
bodies;  and Tables 8.2-15 and 8.2-16, respectively, list data for the
twenty-seven alternative cases for reconstructed facilities for topcoating
of light-duty truck bodies.
                                     8-49

-------
Table 8.2-9.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



     PASSENGER CAR BODIES, PRIME  COATING -  PART I
Case

la
le
Id
le
If
Ib
3a
3e
3d
3c
3f
3b
2a
2e
2d
2c
2f
2b
1
3
2
a
e
d
c
f
b
Emission
Reduction,
Percent

90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
11
11
11
11
11
11
Incremental
Annual ized
Cost/Body
$
3.23
3.25
3.28
3.29
3.30
3.35
11.09
11.11
11.14
11.15
11.16
11.21
18.00
18.02
18.05
18.06
18.07
18.12
3.08
10.94
17.85
0.15
0.17
0.20
0.21
0.22
0.27
Decreased
Emission,
Metric Tons
Per Year

917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
917
807
807
807
110
110
110
110
110
110
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
745
749
754
757
759
770
2,554
2,558
2,564
2,567
2,569
2,580
4,147
4,151
4,157
4,160
4,162
4,173
806
2,862
4,672
296
330
377
402
419
509
                           8-50

-------
Table 8.2-10.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



      PASSENGER CAR BODIES, PRIME COATING  -  PART II
Case

la
le
Id
le
If
Ib
3a
3e
3d
3c
3f
3b
2a
2e
2d
2c
2f
2b
1
3
2
a
e
d
c
f
b
Capital
Investment,
$1,000

2,671
2,723
2,703
2,725
2,723
2,706
2,743
2,794
2,775
2,797
2,794
2,777
2,209
2,261
2,241
2,263
2,261
2,244
2,585
2,657
2,123
86
138
118
140
138
121
Incremental
Annual! zed
Costs ,
$1,000

683
687
692
695
696
706
2,342
2,346
2,351
2,354
2,356
2,366
3,803
3,807
3,812
3,814
3,816
3,826
650
2,310
3,770
33
36
42
44
46
56
Solvent Emitted
Metric
Tons
Per Year
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
103
213
213
213
910
910
910
910
910
910
Pounds
Per Day

944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
944
1,952
1,952
1,952
8,342
8,342
8,342
8,342
8,342
8,342
                           8-51

-------
Table 8.2-11.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



        PASSENGER CAR BODIES,  TOPCOATING  -   PART  I
Case

le
la
1C
Id
If
Ib
3e
3a
3c
3d
3f
3b
2e
2a
2c
2d
2f
2b
1
3
2
e
a
c
d
f
b
Emission
Reduction,
Percent

90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
11
11
11
11
11
11
Incremental
Annual i zed
Cost/Body
$
4.19
4.21
4.23
4.24
4.28
4.32
14.98
15.00
15.02
15.03
15.07
15.11
24.42
24.44
24.46
24.47
24.51
24.55
4.00
14.79
24.23
0.19
0.21
0.23
0.24
0.28
0.32
Decreased
Emission,
Metric Tons
Per Year
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,340
1,179
1,179
1,179
161
161
161
161
161
161
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
661
664
667
668
675
681
2,362
2,366
2,369
2,369
2,376
2,383
3,849
3,852
3,856
3,856
3,863
3,869
717
2,650
4,340
251
279
305
311
368
421
                           8-52

-------
Table 8.2-12.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



       PASSENGER CAR BODIES, TOPCQATING  -  PART II
Case
le
la
le
Id
If
Ib
3e
3a
3c
3d
3f
3b
2e
2a
2c
2d
2f
2b
1
3
2
e
a
c
d
f
b
Capital
Investment,
$1,000
3,529
3,498
3,525
3,509
3,544
3,503
3,775
3,744
3,772
3,755
3,791
3,749
3,048
3,017
3,044
3,028
3,063
3,022
3,376
3,623
2,895
153
122
149
133
168
127
Incremental
Annual ized
Costs ,
$1,000
885
890
894
895
904
913
3,165
3,169
3,174
3,175
3,184
3,192
5,157
5,161
5,166
5,167
5,176
5,184
845
3,125
5,117
40
45
49
50
59
68
Solvent Emitted
Metric
Tons
Per Year
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
149
310
310
310
1,328
1,328
1,328
1,328
1,328
1,328
Pounds
Per Day
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
1,366
2,842
2,842
2,842
12,173
12,173
12,173
12,173
12,173
12,173
                            8-53

-------
Table 8.2-13.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



      LIGHT-DUTY TRUCK BODIES, PRIME  COATING  -   PART  I
Case
la
le
Id
If
le
Ib
3a
3e
3d
3f
3c
3b
2a
2e
2d
2f
2c
2b
1
3
2
a
e
d
f
c
b
Emission
Reduction ,
Percent
90
90
90
90
90
90
90
90
90
90
90
90
90 .
90
90
90
90
90
79
79
79
11
11
11
11
11
11
Incremental
Annual i zed
Cost/Body
$
3.11
3.18
3.19
3.19
3.21
3.26
9.83
9.90
9.91
9.91
9.93
9.98
15.70
15.77
15.78
15.78
15.80
15.85
2.94
9.66
15.53
0.17
0.24
0.25
0.25
0.27
0.32
Decreased
Emission,
Metric Tons
Per Year
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
584
514
514
514
70
70
70
70
70
70
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
780
796
798
800
805
818
2,458
2,474
2,477
2,479
2,484
2,496
3,926
3.942
3,945
3,946
3,951
3,964
837
2,745
4,412
356
492
513
530
570
677
                            8-54

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Table 8.2-14.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



     LIGHT-DUTY TRUCK BODIES, PRIME COATING  -  PART II

Case
la
le
Id
If
le
Ib
3a
3e
3d
3f
3c
3b
2a
2e
2d
2f
2c
2b
1
3
2
a
e
d
f
c
b
I
Capital
Investment,
$1,000
1,723
1,787
1,771
1,777
1,796
1,779
1,667
1,731
1,715
1,721
1,740
1,723
1,371
1,435
1,418
1,425
1,444
1,426
1,662
1,606
1,310
61
125
109
115
134
117
Incremental
Annualized
Costs ,
$1,000
455
465
466
467
470
478
1,435
1,445
1,446
1,447
1,450
1,457
2,292
2,301
2,303
2,304
2,307
2,314
430
1,410
2,267
25
35
36
37
40
47
Solvent Emitted

Metric
Tons
Per Year
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
65
135
135
135
579
579
579
579
579
579

Pounds
Per Day
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
596
1,237
1,237
1,237
5,307
5,307
5,307
5,307
5,307
5,307
                            8-55

-------
Table 8.2-15.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



       LIGHT-DUTY TRUCK BODIES,  TOPCOATING  -   PART  I

Case
la
le
Id
le
If
Ib
3a
3e
3d
3c
3f
3b
2a
2e
2d
2c
2f
2b
1
3
2
a
e
d
c
f
b

Emission
Reduction,
Percent
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
79
79
79
11
11
11
11
11
11
	
Incremental
Annualized
Cost/Body
$
4.94
4.96
5.00
5.03
5.05
5.10
16.04
16.06
16.10
16.13
16.15
16.20
26.06
26.08
26.12
26.15
26.17
26.22
4.72
15.82
25.84
0.22
0.24
0.28
0.31
0.33
0.38

Decreased
Emission,
Metric Tons
Per Year
972
972
972
972
972
972
972
972
972
972
972
972
9.72
972
972
972
972
972
855
855
855
117
117
117
117
117
117
Cost Per
Metric Ton
Reduced
Emission,
$/Ton
743
745
752
755
759
767
2,410
2,412
2,419
2,422
2,426
2,434
3,914
3,916
3,923
3,926
3,930
3,938
806
2,700
4,409
279
296
356
380
416
481
                             8-56

-------
Table 8.2-16.  ALTERNATIVE CASES - RECONSTRUCTED FACILITIES



      LIGHT-DUTY TRUCK BODIES, TOPCOATING  -  PART II
Case
la
le
Id
le
If
Ib
3a
3e
3d
3c
3f
3b
2a
2e
2d
2c
2f
2b
1
3
2
a
e
d
c
f
b
Capital
Investment,
$1,000
2,834
2,886
2,867
2,888
2,891
2,869
2,743
2,794
2,775
2,797
2,799
2,777
2,209
2,261
2,242
2,263
2,266
2,244
2,748
2,657
2,123
86
138
119
140
143
121
Incremental
Annualized
Costs,
$1,000
722
724
731
733
737
745
2,342
2,344
2,351
2,353
2,357
2,365
3,803
3,805
3,812
3,814
3,819
3,826
689
2,309
3,770
33
35
42
44
48
56
Solvent Emitted
Metric
Tons
Per Year
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
108
225
225
225
963
963
963
963
963
963
Pounds
Per Day
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
990
2,062
2,062
2,062
8,827
8,827
8,827
8,827
8,827
8,827
                            8-57

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8.3.  OTHER COST CONSIDERATIONS







      (To be prepared by EPA.)
8.4.  ECONOMIC IMPACT OF ALTERNATIVE EMISSION CONTROL  SYSTEMS





      (To be prepared by EPA.)
8.5.  POTENTIAL SOCIO-ECONOMIC AND INFLATIONARY IMPACTS
      (To be prepared by EPA.)
                                     8-58

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                  9.  RATIONALE FOR THE PROPOSED STANDARDS

     This chapter presents the rationale for the selection of the emission
sources, pollutants, and emission control systems for use in recommendations
for an air quality standard for stationary sources in the automotive industry.
Also discussed are modificication and reconstruction considerations.  The ref-
erences for much of the data contained here are included in Chapters 3 through
8, which chapters develop the data for these recommendations.
9.1.  SELECTION OF SOURCE FOR CONTROL
     Section 111 of the Clean Air Act of 1970 and 1974 extends authority to
EPA to regulate emissions by developing standards of performance for new sta-
tionary sources based on the degree of emission limitations achievable through
the application of the best systems of emission reduction.
     Section 111  (b) , which allows EPA to limit emission of pollutants for
which air quality criteria have been prescribed, is appropriate for the auto-
motive industry - a major source of hydrocarbon  (HC) emissions.  Hydrocarbon
emissions from automotive finishing lines depend on the rates of organic sol-
vents to nonvolatile solids in the coatings used, the transfer efficiency of
the method of applying the coatings and the quantities of coating materials
used on the products.  For example, lacquers having 15-17 volume percent solids
are higher in organic solvents than enamels consisting of 30-35 volume percent
solids.
     The sources  studied are automobile and light-duty truck assembly plants.
Automobiles include  all passenger  cars, or passenger cars modified  to be capa-
ble of  seating twelve or  fewer passengers.  Light-duty trucks include any
motor vehicles rated at 8500 pounds gross vehicle weight or  less which are de-
signed primarily  for purposes of transportation of materials, goods, or prod-
ucts - or are modifications of  such vehicles.  Included in this category are
pick-up trucks, vans, and window vans.
                                     9-1

-------
     Automobile and light-duty truck assembly plants produce finished vehi-
cles from parts received from various sources.  Various models may be assem-
bled on one production line, but they are usually of the same general body
style.  A plant may have more than one line.  The source selected for control
of organic emission discharge is the assembly plant only, and not other
places where automobiles and light-duty trucks may be finished - such as cus-
tomizers, body shops, or repaint shops.
     Typical assembly lines can produce 30 to 70 automobiles per hour.  Light-
duty trucks are usually produced at the rate of 30 trucks per hour.  The line
is operated at two shifts a day, using the third shift for clean-up.  Depend-
ing on demand, the rate and number of shifts can be varied; most plants oper-
ate about 4000 hours per year.  Plants are usually shut down on holidays and
for several weeks during model changeover period.
     Locations of U.S. automobile and light-duty truck assembly plants are
shown in Figure 9.1-1.  Division of the map of the continental United States
into zones shows where the various percentages of vehicles are assembled.
Over 50 percent of the automobiles and light-duty trucks are assembled in
Zone 2, which covers the east, north, and south central portions of the coun-
try.  The concentration of assembly lines is in the east north central sec-
tion, 'where the least stringent air pollution controls are in force.
     The major objective of new source performance standards is to obviate
future air pollution problems rather than to correct them after the fact.  The
most practical time, from both an economic and technical viewpoint, to install
pollution control equipment is during the construction phase of a new facility-
Add-on systems or devices are more costly than those incorporated in the plant
design, and they may not represent the application of best technology due to
the constraints placed on them by existing structures and process considera-
tions.  Pollution control equipment, designed as an integral part of a pro-
cess or operation, is the most effective means of reducing emissions at the
least possible expense.
                                      9-2

-------
           Figure 9.1-1.  CONCENTRATION OF ASSEMBLY LINES FOR

       AUTOMOBILES AND LIGHT-DUTY TRUCKS  IN ZONED AREAS OF THE U.S.


                       Total  Percent of Production
Percent
                                    Zone 3      Zone 2
                                 I	WEST-(2
                                    NORTH
                                    CENTRA
                                                           SOUTH
                                                          lATLANTl
"LEAST
 SOUTH
 CENTRAL  ,
                                    WEST
                                    SOUTH
                                    CENTRAL
 Automobiles

 Light-Duty
   Trucks
                                       9-3

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9.2.  SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
     The pollutants for which New Source Performance Standards are being pre-
pared are airborne organic solvents emitted from stationary sources such as
automobile and light-duty truck finishing lines.
     The automotive industry uses three types of organic solvent-borne coat-
ings:  paints, enamels, and lacquers.  Applied paints dry and cure in the
oven by evaporation of thinners and by oxidation of a drying oil which polym-
erizes to form a resinous film.  Paints represent a small fraction of the coat-
ings used in the sources under study.  Enamels are cured in ovens in the same
manner as paints but have a higher concentration of synthetic drying oils.
     Lacquers, when exposed to the oven heat, are dried without going through
a chemical reaction, but they release solvents.  The solvents are:  aromatic
hydrocarbons, alcohols, ketones, ethers, and esters - used in enamels, lac-
quers, and varnishes.  The thinners  are:  aliphatic hydrocarbons, mineral
spirits, naphtha,  and  turpentine - used in paints, enamels, and varnishes.
     The process of finishing an automobile or  light-duty truck body may vary
in  detail from one plant  to  another; however, there are many  features common
to  all assembly plants.   The process usually begins when the  automobile body
emerges from the body  shop and undergoes a metal  treatment, usually a phos-
phate wash cycle,  to improve paint adhesion and corrosion resistance.
     The first coating is a  primer,  applied by  dipping or spraying.  The ve-
hicle body is then baked  to  cure the coating.   Some dip coatings  are applied
by  electrodeposition to provide corrosion resistance over the entire surface
of  the metal.  This coating  conforms to the metal surface and usually  requires
an  additional coating  of  primer surfacer  (also  known as guide coat).   This
coating can  be sanded  and provides a surface  for  the topcoat.  The primer
surfacer is  cured  in a bake  oven.
     The topcoating is applied next  -  sometimes several  coatings  are  applied,
usually with a bake step  after each  coat.   The  painted body moves to  the trim
 shop where  assembly of the  vehicle is completed.   In those  instances  where
 coatings are damaged during the  trim process,  the vehicle body is repainted
 as required in a repair spray booth.  Low-temperature  drying ovens are util-
 ized for the organic  solvent-borne coating used in repairs  because the body
                                    9-4

-------
now contains heat-sensitive materials such as polymers and elastomers which
would be damaged by high-temperature cure cycles.  Production volume in the
repair area is intermittant, and  separate control equipment for reducing emis-
sions would be less cost effective than for the primary coating area.  There-
fore, emission controls for the repair spray booth and oven are not recom-
mended.
     The technology for controlling emissions at affected facilities was
studied and comparisons were made to determine emission reduction capabilities
of various techniques and  systems.  Some  thirty-eight emission control sys-
tems were analyzed from the viewpoints of environmental impact and cost effect
on the industry.   These  systems  are tabulated  in Chapter 8.2.  Such  systems
were selected for study on the basis  that the  technology to  implement them
was available or demonstrated to be  in use in  the  industry.  Emission reduc-
tion capability,  when compared to a  base case  in a model plant using organic
solvent-borne coatings,  ranges from 11 percent to 100 percent for  the topcoat-
ing operation and from 11 percent to 94  percent for prime  coating  operations.
     The  cost analysis of systems with these capabilities  of emission reduc-
tion included all direct and indirect manufacturing costs,  including an allow-
ance  for capital investment depreciation.  The system costs have a wide range,
depending on the design capability of emission reduction and on the approach
 to the use of energy to effect the emission reduction.  All of these systems
 studied are based on model plants scaled to produce 211,200 automobiles per
 year or 145,920 light-duty trucks per year.  The model plant design was based
 on field surveys of actual plants.
      Cost effectiveness is measured in terms of dollars per metric ton of re-
 duced emissions and  energy effectiveness is measured in British Thermal Units
 per metric ton of reduced emissions.  As expected,  the lowest cost  systems
  (most effective)  are also the most effective in energy utilization.
      The percent  reduction of organic emissions can be accomplished by using
  several different systems.  However, within the emission reduction  range  of
  79 percent to 100 percent is  found the  lowest cost range systems  for top-
  coating operations.   For  primer coating,  the  range of percent emission reduc-
  tion with the lowest cost systems is between  70 and 92 percent.   The compari-
  son of cost  effectiveness and energy effectiveness is  graphically shown on
  figures  9.2-1 through 9.2-8, inclusive.

                                     9-5

-------
2.0
1.0

0.9

0.8

0.7

0.6

0.5


0.4



0.3
 0.2
 0.1
            Figure  9.2-1.   COMPARISON OF ENERGY REQUIREMENTS FOR

          PERCENT REDUCTION OF ORGANIC EMISSIONS IN A MODEL PLANT6

                     PRIME COATING OPERATION - AUTOMOBILES
      Billions of
       Btu's Per
       Metric  Ton
High Range
Low Range
                           11
                          72    75
79
90
                                                       91
92
                                                            94
                             Percent Reduction of Organic Emissions

   Model plant capacity is 211,200 automobiles per year using solvent-borne
   prime coat, 25% nonvolatiles per volume, as a base.  High range and low
   range are shown for each group of control systems capable of the percent
   reduction shown. Systems from Table 8.2-1.
                                     9-6

-------
2.0
1.0
0.9

0.8

0.7

0.6

0.5


0.4



0.3
 0.2
 0.1
            Figure 9.2-2.  COMPARISON OF ENERGY REQUIREMENTS FOR

          PERCENT REDUCTION OF ORGANIC EMISSIONS  IN A MODEL PLANT0

                 PRIME COATING OPERATION - LIGHT-DUTY TRUCKS
      Billions of
       Btu's Per
       Metric Ton
High Range - -

LOW ReUlljfc! " * '
                            11    70   73    79   90    91    97

                          Percent Reduction of Organic Emissions
   Model plant capacity is 145,000  light-duty trucks per year using solvent-
   borne prime coat, 24% nonvolatiles per volume, as a base.  High range and
   low range are shown for each group of control systems capable of the per-
   cent reduction shown.    Systems  from Table 8.2-5.
                                       9-'

-------
            Figure 9.2-3.   COMPARISON OF ENERGY REQUIREMENTS FOR

          PERCENT REDUCTION OF ORGANIC EMISSIONS IN A MODEL PLANT'

                    TOPCOATING OPERATION - AUTOMOBILES
2.0
1.0

0.9

0.8

0.7

0.6


0.5


0.4



0.3
 0.2
 0.1
     Billions of
      Btu's Per
      Metric  Ton
     High Range - - - - -
     Low Range ------
                            11   79    80   90    100

                      Percent Reduction of Organic Emissions
 3 Model plant capacity is 211,200 automobiles per year using solvent-borne
   topcoat,  25% nonvolatiles per volume, as a base.  High range and
   range are shown for each group of control systems capable of the per-
   cent reduction shown.   Systems from  Table 8.2-3.
                                     9-8

-------
2.0
1.0
0.9

0.8

0.7

0.6


0.5


0.4



0.3
0.2
0.1
            Figure 9.2-4.  COMPARISON OF ENERGY REQUIREMENTS FOR

          PERCENT REDUCTION OF ORGANIC EMISSIONS IN A MODEL PLANTC

                 TOPCOATING OPERATION - LIGHT-DUTY TRUCKS
      Billions of
       Btu's Per
       Metric Ton
              nign
                                                      _ Low Range
                                   11
79
90
100
                            Percent Reduction of Organic  Emissions
  Model plant capacity is 145,000 light-duty trucks  per year  using  solvent-
  borne topcoat,  24%  nonvolatiles per volume,  as  a base.   High  range  and
  low range are  shown for each group of control systems capable of  the  per-
  cent reduction shown.    Systems from Table 8.2-7.
                                    9-9

-------
                                    9-10
             Figure 9.2-5.  COMPARISON OF COST EFFECTIVENESS FOR

            ORGANIC EMISSION  REDUCTION SYSTEMS  IN A MODEL PLANT3
4000
3000
2000
 1000

  900

  800

  700


  600



  500



  400




  300
  200
  100
                   PRIME COATING OPERATION - AUTOMOBILES
          Dollars Per Ton
         Emissions Reduced
High Range 	
            .—r-- - -
                       11    72   75    79   90     91    92    94    96

                           Percent Reduction of  Organic  Emissions
 3 Model plant capacity is 211,200  automobiles/year using  solvent-borne  prime
   coat, 25% nonvolatiles per volume,  as  a base  case.
                                      9-10

-------
                                      9-11

              Figure 9.2-6.   COMPARISON OF  COST EFFECTIVENESS FOR

              ORGANIC EMISSION  REDUCTION SYSTEMS  IN A MODEL PLANT3
4000
3000
2000
1000

 900

 800

 700

 600


 500


 400



 300
 200
 100
                    PRIME  COATING OPERATION  - LIGHT-DITTY TRUCKS
        Dollars Per Ton
       .Emissions Reduced
 High Range - -
_Low Range - -
                                                                      Cost Less
                                                                      Than Base
                                                                         Case
                       11    70    73    79    90    91   92    94    97

                          Percent  Reduction of Organic Emissions
  Model plant capacity is  145,000 light-duty trucks per year using solvent-borne
  prime coat, 24% nonvolatiles per volume, as a base case.
                                       9-11

-------
                                    9-12
             Figure 9.2-7.  COMPARISON OF COST EFFECTIVENESS FOR

            ORGANIC EMISSION REDUCTION SYSTEMS  IN A MODEL PLANTa
4000
3000
2000
 1000

  900
  800

  700

  600

  500


  400



  300
  100
                     TOPCOATING OPERATION - AUTOMOBILES
        Dollars Per Ton
       Emissions Reduced
High Range - - - -
        Low  Range  -  -  -  -
                            11
                      Percent Reduction of Organic Emissons
 a Model plant capacity is 211,200 automobiles/year using solvent-borne top-
   coat, 25% nonvolatiles per volume, as a base case.
                                    9-12

-------
                                     9-13
             Figure 9.2-8.  COMPARISON OF COST EFFECTIVENESS FOR

             ORGANIC EMISSION REDUCTION SYSTEMS  IN A MODEL PLANT3
4000
3000
2000
1000
 900

 800

 700

 600


 500


 400



 300
  200
  100
                   TOPCOATING OPERATION - LIGHT-DUTY TRUCKS
         Dollars Per Ton
      - Emissions Reduced
High Range
          Low Range
                                 11    79    90   100
                          Percent Reduction of Organic Emissions
   Model plant capacity is 145,000 light-duty trucks/year using solvent-borne
   topcoat,  24% nonvolatiles per volume, as a base case.
                                      9-13

-------
9.3.  SELECTION OF THE BEST SYSTEM OF EMISSION



      REDUCTION CONSIDERING COSTS







      (To be prepared by EPA.)
                                      9-14

-------
9.4.  SELECTION OF THE FORMAT OF THE PROPOSED STANDARD
     The format for writing a standard is needed to uniformly measure per-
formance of compliance to that standard.  The term "format" is defined, for
the purposes of this Chapter, as a ratio of emissions to a prescribed unit.
The format could be chosen from any of the following approaches:  concentra-
tion, mass/time, mass/unit of production, equipment standard, or mass/unit
of coating material consumption.   Each of these approaches has advantages as
well as some disadvantages; however, most provide no long-range incentive to
the user for energy reduction as required to abate emissions.
     A brief discussion of each of these approaches will indicate why the best
format for a standard is based on the mass/unit of coating material consump-
tion.
9.4.1.  Concentration - Airborne Emissions
     The standards written in terms of concentration allowable in parts per
million or whatever units by definition would govern the quantity of organic
emissions discharged  from the affected  facility in terms of  the quantity of
air exhausted  to the  atmosphere  from  the affected facility.  To enforce this
format-standard would require constant monitoring of the discharge, which
can be done with present technology.  However, to reduce significantly the
organic emissions  from  solvent-borne  coatings, the use  of  add-on control
equipment such as  carbon adsorbers or incinerators is required.  This  is also
possible within the present  technology.
     For compliance,  another alternative would be to change  coating  formula-
tions; but  unless  organic  solvents were significantly reduced,  the emission
problem would  persist.
     The reduction in the  use of energy by means of  add-on controls  required
to abate organic  emissions would most likely take place over a long  period of
time.  This constitutes an indirect  approach to  the  long-range solution  of
the organic emission problem.
                                     9-15

-------
9.4.2.  Mass/Time - Airborne Emissions
     This format suggests that a limitation be placed on the mass of organic
emissions from an affected facility within a time period which is now in use
within many states and localities in the states.  The format is enforceable
and requires monitoring equipment, as stated above.  Also, add-on equipment
involving the same energy excesses for total abatement will be required to
abate emissions from organic solvent-borne coatings.  This format, as with
the previous one, does not get at the root of the problem of providing an
incentive to reduce the use of organic solvents and thinners in the coating.
9.4.3.  Equipment Standard - Airborne Emissions
     This format suggests that equipment used in the coating process be de-
signed to meet an emission limitation.  The burden of this requirement would
fall on the equipment manufacturer, who probably could not comply without
qualifying the type of coatings to be used with such equipment.  The perform-
ance of the coating would dictate its selection by the end user, and the
equipment manufacturer would want to place restrictions that would probably
not be compatible with the performance of the coating.  An unwieldy situa-
tion would develop and, as in the previous formats discussed, the long-range
aspects of energy reduction in emission abatement would not be directly
approached.
9.4.4.  Mass of Emissions/Unit of Coating Material Consumed
     The standards written in the format of liters or kilograms of organic
emissions per liter  of coating materials used by an affected facility is
the most direct approach to a long-range solution to the problem of control
of organic emissions from stationary sources.  A graphic presentation of the
effect on emission reduction through the use of higher solids coatings will
be found in Chapter 4 - Emission Control Techniques - figures 4-10 and 4-11,
pages 4-44 and 4-45.
     The energy consumption for emission abatement  from present organic
solvent-borne coatings will increase over the short term in new stationary
sources that must comply with performance standards.  The use of incinera-
tion or adsorption techniques may have to be considered until higher solids
coatings are used.  The pressure to provide high-solids coatings will be
                                    9-16

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on the coating manufacturer who will respond to the industry.  In the long
term, there will be in effect the incentive to use coatings with less vola-
tiles in order to reduce energy costs of emission abatement.
     This format will be easily measurable at the source, and the quantities
of coating, volatiles, or  solvents used per time period can be reported by
the user and trade organizations.  Routine monitoring tests and plant sur-
veys will confirm compliance with new source performance  standards.
                                      9-17

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9.5.  SELECTION OF EMISSION LIMITS
      (To be prepared by EPA.)
9.6.  VISIBLE EMISSION STANDARDS
       (To be prepared by EPA.)
                                     9-18

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9.7.  MODIFICATION/RECONSTRUCTION CONSIDERATIONS
     Modifications and reconstructions which apply to affected facilities are
discussed in Chapter 5, and a review of these categories as they are consid-
ered for new source performance  standards is presented in this sub-chapter.
9.7.1.  Raw Material Substitutes
     Existing  sources  would  require compliance measures for new source per-
formance standards under  the  following conditions where organic emissions were
increased from affected  facilities.
      (1)    Lower Solids  Coating
            A  change  from higher solids  to  lower  solids coating - e.g.,
            from an enamel to a lacquer,  requiring  more material hence
            more solvent - will be used to  maintain the same dry coating
            thickness.   This change would increase  the mass of organic
            emissions per volume of coating used.
      (2)    Use of  Higher Density Solvent
            A change  of solvents to higher density would  result  in  more
            kilograms of solvent emitted per volume of coating used.
      (3)     Change  to Larger Parts
             Automobile assembly lines are usually capable of accepting
             a range of body sizes.  A changeover in an existing line to
             accept a larger body size - assuming a capital expenditure is
             not necessary - would not be under new compliance measures
             of air quality standards for new sources, or the change would
             qualify as a reconstruction subject to new source perform-
             ance standards, in  which case higher emissions would result
             since more coating  per automobile would be used.
      (4)    Additional Coating  Stations
             This may be  required because a better  finish may be attained
             if the coating is applied in two coats with a  bake following
             each coat.   Capital investment would be involved, and  the new
             facility would be  subject  to regulation under  provisions of
             40 FR 58416.
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     Conditions where new source performance standards on air quality would
not apply to existing sources are:
     (1)    Increase of production hours or production speeds without
            increasing the capital investment.
     (2)    Change to larger parts:  increase of the body size of the
            vehicle being handled by the production line without an
            increase in capital investment.
     (3)    Change to thicker coatings without increasing capital
            investment.
     (4)    Reduced deposition efficiency:  this may occur because of
            a process modification such as a switch from electrostatic
            spray to conventional spray.  For economical reasons, this
            could be only a temporary situation.
9.7.2.  Reconstruction Compliance Measure
     Reconstruction would come under new source performance standards as de-
fined in 40 FR 58416.  Reconstruction occurs when components of an existing
facility are replaced to such an extent that:
     (1)    The fixed capital cost of the new components exceeds 50 per-
            cent of the fixed capital cost that would be required to
            construct a comparable entirely new facility, and
     (2)    It is technologically and economically feasible to meet
            the application standards.
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 9.8.  SELECTION OF MONITORING REQUIREMENTS
       (To be prepared by EPA.)
9.9.  SELECTION OF PERFORMANCE TEST METHODS
      (To be prepared by EPA.)
                                       9-21

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              APPENDIX A.   EVOLUTION OF PROPOSED STANDARDS

A.I.  PASSENGER CARS

June 27, 1975
     EPA authorized DeBell & Richardson to conduct an Air Pollution Control
Engineering and Cost Study on the Transportation Surface Coating Industry.
DeBell & Richardson Program Manager:  Dr. Bernard Baum.  EPA Contract
Project Officer:  David Patrick.
August 11, 1975
     DeBell & Richardson made a  telephone survey to equipment manufacturers
to discuss equipment associated  with automotive finishing and to request lit-
erature .
August 15, 1975
     DeBell & Richardson made a  telephone survey to equipment suppliers to
discuss equipment associated with the automotive finishing processes and to
request literature.
August 20, 1975
     DeBell S Richardson made survey by telephone  of  surface coating equip-
ment manufacturers  to  discuss equipment associated with automotive finish-
ing processes and to request literature.
August 25, 1975
     DeBell & Richardson visited Nordson Corporation in Amherst,  Ohio,  to
discuss powder coating equipment and to gather information on powder  coat-
ing application  in  the automotive industry.
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August 27, 1975
    DeBell & Richardson visited Interrad Corporation in Stamford, Connecti-
cut, to discuss powder coating technology and equipment.
August 28, 1975
    DeBell & Richardson met with EPA representatives in Durham, North
Carolina, to discuss progress of the study.
September 9, 1975
    EPA visited the General Motors plant in Framingham, Massachusetts, to
observe the water-borne primer process  (EDP) and  to discuss powder coatings.
September 26,  1975
    Office of  Management  and Budget approved the  EPA questionnaire for dis-
tribution in the industrial finishing industry.
October 23, 1975
    DeBell & Richardson met with EPA representatives in Durham, North
Carolina, to discuss progress of the study.
November 11, 1975
    DeBell & Richardson and EPA visited the Checker Motors plant in Kalama-
zoo, Michigan, to observe the  solvent-borne coating operation  and obtain
related data.
November 12, 1975
    EPA and DeBell  & Richardson representatives met with  General Motors in
Detroit, Michigan,  to discuss  finishing methods presently in use at GM's
assembly plants.  Water-borne,  powder,  and polyurethane coatings were
discussed.
November  12,  1975
    Representatives of DeBell & Richardson and EPA met with Chrysler  spokes-
men in Detroit,  Michigan, to discuss hydrocarbon emissions and automotive
finishing processes at Chrysler assembly plants.  Urethane,  water-borne,
and powder  coatings were also discussed at this meeting.
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November 13, 1975
    DeBell & Richardson and Ford representatives met at Ford headquarters
in Detroit, Michigan, to discuss automotive coating processes.
November 13, 1975
    DeBell & Richardson visited the Ford Motor Assembly Plant in Wayne,
Michigan, to observe the finishing operation.  Information on water-borne
primer (EDP) and solvent-borne topcoat was obtained.
November 17, 1975
    DeBell S Richardson met with EPA in Durham, North Carolina, to discuss
the progress of the study.
December 8, 1975
    DeBell  & Richardson visited the Chrysler Corporation plant in Detroit,
Michigan, to observe the  "autophoretic" primer operation.
December 9, 1975
    DeBell  & Richardson visited the General Motors,  Fleetwood Plant,  Detroit,
Michigan, to observe the  automotive coating operation.  Data was obtained
on water-borne primer  (EDP) and solvent-borne topcoat operations.
December 10, 1975
    DeBell  & Richardson visited the General Motors plant  in Pontiac,
Michigan, to observe the  automotive coating operation.  Solvent-borne primer
and low dispersion lacquer topcoat materials were discussed.
December 11, 1975
    DeBell  & Richardson visited the Chrysler Corporation  Belvidere  Plant,
Belvidere,  Illinois, to observe the automotive  finishing  operation  and ob-
tain  related data.
January  14, 1976
    DeBell & Richardson met with  EPA representatives in Durham,  North
Carolina,  to discuss progress of  the study.
                                   A-3

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January 15, 1976
    DeBell s Richardson visited the Ford Motor Company plant in Metuch, New
Jersey, to observe the automotive powder coating operation.
February 1, 1976
    EPA and DeBell &  Richardson representatives met with Phil Townsend,
Consultant, in Enfield, Connecticut,  to discuss the economic impact section
of the study.
February 5, 1976
    DeBell  &  Richardson visited  the Ford  Motor Company Ontario Plant,
Oakville,  Canada,  to observe the water-borne topcoat  operation and to  obtain
data  on the overall  automotive finishing  process.
February  26,  1976
    DeBell &  Richardson and EPA representatives met in Enfield,  Connecticut,
to discuss progress of the study.
March 10,  1976
     DeBell & Richardson visited the  General Motors Plant in South Gate,
 California, to observe the waterrborne primer and topcoat operations.

 March 11, 1976
     DeBell &  Richardson visited the  General Motors Plant in Van Nuys,
 California, to observe the water-borne primer and topcoat operations.
 March 12, 1976
     DeBell &  Richardson visited the Ford Motor Company Plant in Milpitas,
 California,  to observe the  automotive finishing operation.  Information on
 water-borne  primer  and fume incinerator  was obtained.
 March 25,  1976
      Several  of the  smaller industry categories were  dropped from the  study
 because  of the absence of new control technology in those industries, an
 insufficient emission reduction potential, or because the industry was
 highly fragmented.
                                     A-4

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March 30, 1976
    James Berry replaced David Patrick as EPA Contract Project Officer.
April 20, 1976
    DeBell & Richardson and EPA representatives met in Durham, North
Carolina, to discuss progress of the study.
April 21, 1976
    DeBell & Richardson attended the Chemical Coating Conference in
Cincinnati, Ohio.
July 15, 1976
    DeBell & Richardson submitted the  first interim report on Transporta-
tion Surface Coating  Industry.
July 21, 1976
    DeBell & Richardson and EPA representatives met in  Durham, North
Carolina, to discuss  progress of the study.
August  25, 26,  1976
    DeBell & Richardson and EPA representatives met  in  Enfield,
Connecticut, to discuss progress of the study.
September 2, 1976
    C-E Preheater in  Wellsville, New York, completed a study on "Operating
Parameters, Capital Cost  and Operating Expense for Catalytic and Thermal
 Incinerators".
 September 9,  1976
     DeBell  &  Richardson and EPA representatives met in Durham,  North
 Carolina,  to  discuss progress of the study.
 November 17,  1976
     DeBell & Richardson representatives met with EPA people in Durham,
 North Carolina, and submitted the first draft of the second interim report.
                                     A-5

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January 28,  1977
    DeBell  & Richardson met with EPA representatives  in Durham, North
Carolina, to discuss progress  of the study.

A. 2.  LIGHT-DUTY  TRUCKS
    Those dates on which basic steps were  taken in the progress of this Air
Pollution Control Engineering  and Cost  Study on the Transportation Surface
Coating Industry  will be found in the previous section, A.I.  The following
dates are specific to the Light-Duty Truck study.
December 12,  1975
    DeBell  & Richardson visited the  General Motors Truck and Coach Division,
Pontiac, Michigan, to discuss  the finishing line.  Data was obtained on the
EDP primer  and solvent  consumption.
December 22,  1975
    DeBell  & Richardson visited Hackney &  Sons, Washington, North Carolina,
to observe  truck  body finishing operations.
January 9,  1976
    DeBell'  & Richardson visited the  Chrysler Corporation Warren Truck Plant
in Detroit,  Michigan, to inspect the assembly line and to discuss the finish-
ing operations.
January 9,  1976
    DeBell  & Richardson visited the  Ford Motor Company, Michigan, and speci-
fically the  truck plant in Wayne,  Michigan, to observe the finishing opera-
tion.  Data  was obtained on solvent-borne  painting process.
February 10,  1976
    DeBell  & Richardson visited International Harvester, Fort Wayne,
Indiana, to  observe the finishing operations of their light-duty truck plant.
                                  A-6

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        APPENDIX B.  INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
  Agency Guidelines for Preparing
  Regulatory Action Environmental
  Impact Statements (39 FR 37419)
Location Within the Standards Support
 and  Environmental  Impact  Statement
Background description of the do-
mestic automotive industry (number
of plants, location, production
trends, etc.).

General procedures, basic process.
Processes or facilities and their
emissions.

Affected facilities and types of
sources.
Modifications and reconstruction.

Emission control technology.
Chapter 3, sections 3.1.1 and 3.1.2;
pages 3-1 through 3-12.  Data are
found also on pages 7-13 and 7-14.
Chapter 3, sections 3.2.1 and 3.2.2;
pages 3-13 through 3-36.

Chapter 3, section  3.2;  pages 3-13
through 3-36.

Chapter 4, sections 4.1.1 through
4.2.6; pages 4-1 through 4-45.
Chapter 9, section 9.2; pages 9-4 and
9-5.

Chapter 5; pages 5-1 through 5-7.

A discussion of the alternative emis-
sion control systems and their effec-
tiveness is presented in Chapter 6;
pages 6-1 through 6-19.

The various relationships between these
alternatives are tabulated in Tables
6-1 and 6-2, pages 6-2 and 6-3; and in
Tables 6-3 to 6-6, pages 6-15 through
6-19.

Flow diagrams illustrating these alter-
native systems are presented in Figures
6-1 through 6-8, pages 6-7 through 6-14.
                                     B-l

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  Agency Guidelines  for Preparing
  Regulatory Action  Environmental
  Impact Statements  (39 FR 37419)
Location Within the Standards Support
 and Environmental  Impact Statement
Environmental  impacts  of suggested
alternative control systems.
Secondary impacts associated with
the suggested alternative control
systems.
 Other environmental impacts and
 concerns.
 Extension of time and effective
 date of standards.
A discussion of the suggested alterna-
tive control systems is presented in
Chapter 7.

Estimated hydrocarbon emission reduc-
tion in future years is discussed in
sections 7.1.3.1 and 7.1.3.2.  These
are shown also in a tabulated form for
1976, 1977, 1978, 1979, and 1985 in
Tables 7-6 through 7-18, pages 7-16
through 7-29.

Current emissions versus future emis-
sions of these control systems are
shown, as related to automobile and
light-duty truck productions, graphi-
cally in Figure 7-1, page 7-9; Figure
7-2, page 7-22; Figure 7-3, page 7-30;
and Figure 7-4, page 7-31.

Secondary impacts are discussed under
Chapter 7, section 7.2  (water), pages
7-32 through 7-34; section 7.3  (solid
waste disposal), pages 7-34 through  .
7-36; and section 7.4  (energy), pages
7-36 through 7-44.

Tables 7-19 through 7-26 show energy
balances  and energy requirements of
the various suggested  alternative  con-
trol systems on pages  7-37 through 7-44.

Chapter 7, sections 7.5 and  7.6, page
7-45, discuss  impacts  other  than pri-
mary and  secondary  impacts associated
with the  suggested  alternative  control
systems.

Chapter 7,  sections 7.6.2  and 7.6.3,
pages  7-45 and 7-46, deal  with  impacts
of delayed and no standards.
                                     B-2

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  Agency Guidelines for Preparing
  Regulatory Action Environmental
  Impact Statements (39 FR 37419)
Location Within the Standards Support
 and  Environmental  Impact  Statement
Energy requirements for alternative
control systems.
Economic impacts of alternative
control systems.

Capital and operating costs for
alternate control systems.

Affected facilities and energy
requirements.
Cost effectiveness for emission re-
duction systems.
State regulations and controlled
emissions.

Uncontrolled emissions.
Chapter 7, section 7.4, Tables 7-19
through 7-26, pages 7-37 through 7-44,
show energy balances in tabulated form.

Chapter 8, sections 8.1 and 8.2, pages
8-

Chapter 8, section 8.2, pages 8-
Chapter 9, section 9.2, Figures 9.2-1
through 9.2-4, pages 9-6 through 9-9,
show the comparison of energy require-
ments in bar chart form of systems dis-
cussed in Chapter 8.2.

Chapter 9, section 9.2, Figures 9.2-5
through 9.2-8, pages 9-10 through 9-13,
show the comparison of cost effective-
ness in bar chart form.

Chapter 7, section 7.1.1, pages  7-2
and 7-3.

Chapter 7, section 7.1.2, page 7-3 and
page 7-4; and section 7.1.2.2, page
7-10.
                                    B-3

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                                   TECHNICAL REPORT DATA
                            (Please read l/islnictions on the reverse before completing/
  EPA°-P4'5fr73-77-020
                              2.
                                                            3. RECIPIENT'S ACCESSION-NO.
4. TITLE ANJD SUBTITLE
   Study to Support New Source  Performance Standards for

   Automobile and  Light-Duty Truck  Coating
                             5. REPORT DATE
                                June 1977
                             6. PERFORMING ORGANIZATION CODE
 . AUTHOR(S)

    Springborn  Laboratories,  Inc.
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
     Springborn  Laboratories
     Enfield,  Connecticut  0608Q

     (Formerly DeBell  & Richardson,  Inc.)
                                                            10. PROGRAM ELEMENT NO.
                             11. CONTRACT/GRANT NO.

                                 EPA 68-02-2062
12.3PONSORIMG AGENCY NAMEANDAQDRESS
  Environmental Protection Agency
  Office of Air  Quality Planning  and Standards
  Emission  Standards & Engineering Division
  Research  Triangle Park, N.C.   27711
                             13. TYPE OF REPORT AND PERIOD COVERED
                                       Final      	-
                             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
      The purpose of this report is to provide  the  information for EPA to establish
      Standards of Performance for New Stationary  Sources for Automobile and  Light
      Duty Truck Coating under Section 111 of  the  Clean Air Act as amended.   Included
      are industry description and organic air emission control techniques and  costs.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
 Air Pollution Control
 Equipment,  Hydrocarbons,
 Organic  Solvents, New
 Source  Performance
 Standards
Automobiles,
Truck, Surface
Coating.Paint
                                               b. IDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
Air Pollution  Control
Stationary  Sources
Hydrocarbon  Emission
Control
 13. DISTRIBUTION STATEMENT
                                               19.
                                                                iis Report)
                          Unlimited
                                               20. SECURITY CLASS /This page)
                                                   Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (9-73)

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