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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Use of Water Reducible Industrial Coatings. SME Technical Paper. FC74-639:3-6, 1974. 3. Schrantz, J. Off-Line Cleaning and Electrocoating of Truck Cabs. Industrial Finishing. 52_(6) :40-46, June 1976. 4. Bardin, P.C. Chevrolet Primes Truck Parts in Two 60,000- Gallon EDP Tanks. Industrial Finishing. 49(2);58-65, February 1973. 5. Primer Electrodeposition at GM South Gate Plant. Products Finishing. March 1968. 6. Levinson, S.B. Electrocoat. 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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. 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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 ------- 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. 4-58 ------- 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. 5-1 ------- 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. 5-2 ------- (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 5-3 ------- 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. 5-4 ------- 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 5-5 ------- 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 5-6 ------- 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. 5-7 ------- 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. 5-8 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 9.5. SELECTION OF EMISSION LIMITS (To be prepared by EPA.) 9.6. VISIBLE EMISSION STANDARDS (To be prepared by EPA.) 9-18 ------- 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. 9-19 ------- 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. 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.) 9-21 ------- 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. A-l ------- 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. A-2 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) ------- |