September 2006
Environmental Technology
Verification  Report

EXEL Industrial, Inc.
Kremlin Airmix® Spray Gun
             Prepared by
  National Defense Center for Environmental Excellence
             Operated by

     Concurrent Technologies Corporation
               for the
      U.S. Environmental Protection Agency

      Under Contract No. W74V8H-04-D-0005
  with the U.S. Army Contracting Center of Excellence
  via EPA Interagency Agreement No. DW2192190801

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1.  AGENCY USE ONLY (Leave blank)
                    2. REPORT DATE
                        29 September 06
              3.  REPORT TYPE AND DATES COVERED
                 Revised Interim Final (Verification Report / Sep. 2005 - Jun.
                 2007)
    TITLE AND SUBTITLE
    Environmental Technology Verification Report - EXEL Industrial, Inc. Kremlin Airmix Spray Gun
6.   AUTHOR(S)
    Principal Author/PMt: Robert J. Fisher, CTC
                                                                5.  FUNDING NUMBERS
                                                                   Contract: W74V8H-04-D-0005
                                                                   Task: NDCEE Task No. 0428
7.   PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES)
    National Defense Center for Environmental Excellence
    Operated by Concurrent Technologies Corporation
    100 CTC Drive
    Johnstown, PA 15904
                                                                8.  PERFORMING ORGANIZATION
                                                                   REPORT NUMBER
9.   SPONSORING/MONITORING AGENCY NAME(S) AND ADDRESS(ES)
    NDCEE Program Office (Office of the Assistant Secretary of the Army for Installations and Environment)
    1235 Clark Street, Suite 307
    Arlington, VA 22202-3263
    Program Manager: Dr. Chuck Lecher, NDCEE Program Manager, 703-602-5538
                                                                10.   SPONSORING/MONITORING
                                                                     AGENCY REPORT NUMBER
                                                                     NDCEE-CR-2006-051
10   SUPPLEMENTARY NOTES
12a.  DISTRIBUTION/AVAILABILITY STATEMENT
     Distribution authorized to the DoD and DoD contractors only.
                                                                                                    12b. DISTRIBUTION CODE
13.   ABSTRACT (Maximum 200 words)
         The Environmental Technology Verification (ETV) Program has been established by the U.S. Environmental Protection Agency (EPA) to verify the
performance characteristics of innovative environmental technologies across all media and report this objective information to the states, buyers, and users of
environmental technology; thus, accelerating the entrance of these new technologies into the marketplace. Verification organizations oversee and report verification
activities based on testing and quality assurance protocols developed with input from major stakeholders and customer groups associated with the technology area. ETV
consists of six technology centers. Information about each of these centers can be found on the Internet at http://www.epa.gov/etv/.

         EPA's ETV Program, through the National Risk Management Research Laboratory (NRMRL), Air Pollution Prevention and Control Division (APPCD) has
partnered with Concurrent Technologies Corporation (CTC), through the National Defense Center for Environmental Excellence (NDCEE), to verify innovative
coatings and coating equipment technologies for reducing air emissions from coating operations. Pollutant releases to other media are considered in less detail.

     The following report describes the verification of the performance of EXEL Industrial, Inc. 's Kremlin Aimix® high transfer efficiency (TE) spray gun for wood
finishing applications.
14.   SUBJECT TERMS
                                                                                                    1 5 .   NUMBER OF PAGES
                                                                                                         38
                                                                                                    16.  PRICE CODE
17.   SECURITY CLASSIFICATION
     OF REPORT
     Unclassified
18.   SECURITY CLASSIFICATION
     OF THIS PAGE
     Unclassified
19.   SECURITY CLASSIFICATION
     OF ABSTRACT
     Unclassified
20.   LIMITATION OF ABSTRACT
     None
NSN 7540-01-280-5500
                                                                      Standard Form 298 Rev. 12/00
                                                                      Prescribed by ANSI ST. 239-18
                                                                      880922

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                                       Notice

This document was prepared by Concurrent Technologies Corporation (CTC) under Contract No.
W74V8H-04-D-0005 with the U.S.  Army Contracting  Center of Excellence, Task No. 0428,
Subtask 3.  The U.S. Environmental Protection Agency (EPA) and the U.S. Army are working
together under EPA Interagency Agreement No. DW2192190801.  This  document has been
subjected to EPA's technical peer and administrative reviews  and has  been approved for
publication.  Mention  of corporation names, trade  names, or commercial products does not
constitute endorsement or recommendation for use of specific products.

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                                           September 2006
    Environmental Technology
          Verification Report
          EXEL Industrial, Inc.
     Kremlin Airmix® Spray Gun
                    Prepared by

                   Robert Fisher
                  Lynn Summerson
                      Of the
     National Defense Center for Environmental Excellence
                    Operated by
           Concurrent Technologies Corporation
                Johnstown, PA 15904
Under Contract No. W74V8H-04-D-0005 (Task No. 0428, Subtask 3)
      with the U.S. Army Contracting Center of Excellence
      via EPA Interagency Agreement No. DW2192190801
                 EPA Project Officer:
                  Michael Kosusko
        Air Pollution Prevention and Control Division
       National Risk Management Research Laboratory
            Research Triangle Park, NC 27711

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                                      Foreword

The Environmental Technology Verification (ETV) Program has been established by the U.S.
Environmental Protection Agency (EPA) to verify the performance characteristics of innovative
environmental technologies across all media and report this objective information to the states,
buyers, and users of environmental technology; thus, accelerating the entrance of these new
technologies into the marketplace. Verification organizations oversee and report verification
activities based on testing and quality assurance protocols developed with input from major
stakeholders and customer groups associated with the technology area. ETV consists of six
technology centers. Information about each of these centers can be found on the  Internet at
http://www.epa.gov/etv/.

The National Risk Management Research Laboratory's (NRMRL) Air Pollution Prevention and
Control Division (APPCD) has  partnered with Concurrent Technologies Corporation  (C7U),
through  the  National  Defense  Center for Environmental  Excellence (NDCEE),  to verify
innovative coatings and coating equipment technologies for reducing air emissions from coating
operations. Pollutant releases to other media are considered in less detail.

The following report describes the verification of the performance of EXEL  Industrial, Inc.'s
Kremlin Airmix® high transfer efficiency (TE) spray gun for wood finishing applications.
                                           11

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                                  Table of Contents

                                                                                      Page
Foreword                                                                              ii
Verification Statement                                                                  v
Acknowledgments                                                                      ix
SI to English Conversions                                                               x
List of Abbreviations and Acronyms                                                      xi
Section 1 Introduction                                                                 1
      1.1   ETV Overview                                                              1
      1.2   Potential Environmental Impacts                                               1
      1.3   Technology Description                                                      2
      1.4   Technology Testing Process                                                   2
      1.5   Test Objectives and Approach                                                 3
      1.6   Performance and Cost Summary                                               3
Section 2 Description of the Technology                                                 5
      2.1   Technology Performance, Evaluation, and Verification                           5
      2.2   The Airmix® Test                                                           5
      2.3   Airmix® Spray Application Equipment                                         6
      2.3.1  Applications of the Technology                                                6
      2.3.2  Advantages of the Technology                                                 6
      2.3.3  Limitations of the Technology                                                 6
      2.3.4  Technology Deployment and Costs                                             7
Section 3 Description and Rationale for the Test Design                                   8
      3.1   Description of Test Site                                                       8
      3.2   Evaluation of Airmix® Performance                                           9
      3.2.1  Test Operations at CTC                                                       9
      3.2.2  Test Sampling Operations at CTC's ETF facility                                 10
      3.2.3  Sample Handling and Quality Assurance/Quality Control Procedures               11
      3.3   Data Reporting, Reduction, and Verification Steps                               11
      3.3.1  Data Reporting                                                              11
      3.3.2  Data Reduction and Verification                                               12
Section 4 Reference Data                                                               13
      4.1   HVLP Parameter Development                                                13
      4.2   HVLP Results                                                               14
Section 5 Results and Discussion                                                        15
      5.1   Potential Environmental Benefits and Vendor Claims                             15
      5.2   Selection of Test Methods and Parameters Monitored                             15
      5.2.1  Process Conditions Monitored                                                 15
      5.2.2  Operational Parameters                                                       15
      5.2.3  Parameters/Conditions Monitored                                              16
      5.3   Overall Performance Evaluation of the Airmix® Spray Gun                       16
      5.3.1  Re sponse Factors                                                            17
      5.3.2  Assessment of Laboratory Data Quality                                         18
      5.4   Technology Data Quality Assessment                                          18
      5.4.1  Accuracy, Precision, and Completeness                                         18
      5.4.2  Audits                                                                      19
                                           in

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Section 6 Vendor Forum                                                          20

Section 7 References                                                             2 1


                                  List of Tables

                                                                              Page
Table 1 . Verification Results for the Airmix® and HVLP Baseline                           4
Table 2. HVLP Baseline Guns Configuration and Setup                                   13
Table 3. HVLP Baseline Guns Response Factor Results                                   14
Table 4. Airmix® Configuration and Setup                                             16
Table 5. Airmix® Response Factor Results                                             17
                                 List of Figures

                                                                              Page
Figure 1 . Organic Finishing Line at CTC                                               8
Figure 2. Application Pattern Diagrams                                                 9
                           List of Associated Documents

Kremlin Airmix® Data Notebook (Available from CTC upon request)
                                        IV

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          THE ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
                                                                               Concurrent
                                                                               Technologies
                                                                               Corporation
             ETV JOINT VERIFICATION STATEMENT
     TECHNOLOGY TYPE:       HIGH TRANSFER EFFICIENCY (TE) LIQUID
                                 COATING SPRAY APPLICATION EQUIPMENT
     APPLICATION:             LIQUID ORGANIC COATINGS APPLICATION IN
                                 WOOD FINISHING
     TECHNOLOGY NAME:      Kremlin Airmix®

     COMPANY:       EXEL Industrial, Inc.
     POC:             Mr. John Patry - President
     ADDRESS:        1310 Washington St.                 PHONE:   (630)-231-1900
                       West Chicago, II60185                FAX:      (630)-231-2791
     EMAIL:           john.patry@kremlin.com
The United States  Environmental Protection Agency (EPA) has created the Environmental Technology
Verification  (ETV)  Program  to  facilitate  the  deployment of innovative  or improved  environmental
technologies through performance verification and dissemination of information.  The goal of the ETV
Program is to  further  environmental protection  by substantially accelerating the  acceptance and use of
improved,  cost-effective technologies.   ETV seeks to achieve this  goal by providing  high-quality,  peer-
reviewed data on technology performance to those involved in the design, distribution, financing, permitting,
purchase, and use of environmental technologies.

ETV works in partnership with recognized standards and testing organizations, stakeholder groups consisting
of buyers,  vendor  organizations, and  states, and with  the full participation  of individual technology
developers. The program evaluates the performance of innovative technologies by developing test plans that
are responsive to the needs of stakeholders, conducting  field or laboratory tests (as appropriate), collecting
and analyzing data, and preparing peer-reviewed reports. All evaluations are conducted  in accordance with
rigorous quality assurance protocols to ensure that data of known and  adequate quality are generated and that
the results are defensible.

The ETV Coatings and Coating Equipment Program (CCEP), one of six verification centers under the ETV
Program, is operated by Concurrent Technologies Corporation (CTC) under the National  Defense Center for
Environmental  Excellence  (NDCEE), in cooperation with  EPA's National  Risk  Management Research
Laboratory.  The ETV CCEP has recently evaluated the performance  of innovative liquid coating  spray
application  equipment  intended for  wood finishing applications. This verification statement provides a
summary of the test results for the Kremlin Airmix® high transfer efficiency (TE) spray gun, manufactured
by EXEL Industrial, Inc.
                                              v

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VERIFICATION TEST DESCRIPTION

The ETV CCEP evaluated the pollution prevention capabilities of high TE liquid spray equipment. The test
was conducted under representative factory conditions at CTC. It was designed to verify the environmental
benefit of the high-TE spray gun with specific quality requirements for the resulting finish. The finish quality
applied by the Airmix® was verified to be comparable to the finish quality obtained by three baseline high-
volume, low-pressure (HVLP) spray guns. The environmental benefit of HVLP spray guns compared to
conventional air spray equipment has previously been verified und the ETV Program. The results of the
HVLP verification tests can be found on the EPA's ETV website (www.epa.gov/etv). If a high-TE spray gun
cannot provide an acceptable finish while operating at efficiencies representative of HVLP spray guns, the
end users may have a tendency to raise the input air pressure to meet their finishing requirements. However,
these adjustments may reduce the environmental benefits of the high-TE spray gun. In earlier verification
tests, HVLP guns were shown to improve TE by 18.9% to 63.9% when compared to  conventional paint spray
guns, depending on the coating sprayed. This improved TE resulted  in a reduction of 16% to 40% of coating
material use, emissions of volatile organic compounds (VOC) and hazardous air pollutants (HAP), and of
solid waste generated. This verification test compared the TE of a high TE liquid spray gun against a baseline
of HVLP guns, which could be subsequently used to qualify the environmental benefits provided by the
Airmix® when compared to conventional air spray equipment.

In this test, the Airmix® high-TE spray gun was tested under conditions recommended by EXEL Industrial,
Inc., the gun's manufacturer. Two targets were used. The first target  consisted of 24 in. x 24 in. wood panel
backboards that were covered with heavy duty aluminum foil  and suspended in the spray booth by hooks.
The second target consisted of 12 in. x 24 in. wood panels that were sealed and sanded and suspended in the
spray booth by hooks. Three foil-covered backboards were coated in each of five runs for each gun to be used
for TE analysis. One wood panel was coated in each of five runs for each gun to be used for finish quality
analysis. The application pattern was consistent among each target type. The spray guns were triggered so
that 6 in. (3 in. lead and 3 in. lag) of overspray were obtained for each pass. The application pattern for all
guns also allowed 50% of the first and last pass to be either above or below the panel, respectively.  The spray
guns were mounted on a robotic translator to increase accuracy and repeatability of the test. The translator
moved the spray gun horizontally and/or vertically. The  TE improvement of the Airmix® spray gun over a
HVLP gun baseline was verified using American Society for Testing and Materials (ASTM) method D 5286.
The Airmix® and HVLP baseline guns were all pressure-feed guns. The finish quality of the Airmix® was
determined to be comparable  to the finish quality of the HVLP  baseline and was able to meet the
finish quality requirements of the test coating; thus, the TE values obtained for the Airmix® test are
representative of the actual operation of the equipment and the  TE comparison was deemed to be
valid.

The details of the test, including a summary of the data and a discussion of results, may be found in Chapters
4 and 5 of "Environmental Technology Verification Report - EXEL Industrial, Inc. Kremlin Airmix® Spray
Gun," which was published by CTC. Copies of this Verification Statement and the associated Verification
Report are available at http://www.epa.gov/etv/verifications/vcenter6-16.html. Contact Robert J. Fisher of
CTC at (814) 269-2702 to obtain copies of the Data Notebook

TECHNOLOGY DESCRIPTION

The Airmix® spray gun was tested as received from EXEL Industrial, Inc. The gun was equipped with a
VX14 air cap and a 14-174+ fluid tip. The Airmix® is an improved version of an air assisted-airless spray
gun design. The paint is delivered to the gun under moderate pressure, a specially designed fluid tip atomizes
the pressurized paint, and a small amount of compressed air is used to shape the fan pattern.  The vendor
claims that the fan pattern achieved by this design exhibits a uniform density along the long axis of the
pattern, allowing for a more consistent and controllable film build. Because the Airmix® spray gun is
marketed to wood finishing applications, EXEL Industrial, Inc. selected a wood furniture finishing clear
topcoat manufactured by Valspar called 35 Sheen Ecoplast El.
                                               VI

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More information on the spray gun, including recommended air caps and fluid tips for various paint
formulations, is available from EXEL Industrial, Inc. At the time of this verification test, the list price of the
Airmix® spray gun and pressure pump was approximately $2,000.
VERIFICATION OF PERFORMANCE

The performance characteristics of the Airmix® spray gun include the following:

Environmental Factors

•   Transfer Efficiency (TE): The TE was determined per ASTM D 5286. The following TEs and associated
    standard deviations were obtained for the conditions tested:
Spray Gun
Average TE (%)
Std. Dev.
Airmix®
54.4
0.5
HVLP#1
51.6
0.6
HVLP#2
53.1
0.3
HVLP#3
52.2
0.5
    The Airmix® provided a higher TE than the three HVLP guns for all comparisons at 95% confidence
    interval.

Marketability Factors

•   Air Flow: The air consumption data was obtained using a calibrated air flow meter. The following air
    flows and associated standard deviations were obtained during this test:
Spray Gun
Average Air Flow
(SCFM)
Std. Dev.
Airmix®
Gun -3
Pump - 2
0.0
HVLP#1
14a
0.0
HVLP #2
9a
0.0
HVLP #3
12a
0.0
           The air consumption of the pressure pump used for the three HVLP spray guns was not significant
         compared to the air consumption of the guns themselves.

    Dry Film Thickness (DFT): The DFT data was obtained per ASTM D 6132. Based on recommendations
    in Valspar's product data sheets for the 35 Sheen Ecoplast El topcoat, the target DFT was established at
    approximately 1.0 mil in one coat. DFTs for all tests were determined from multiple points measured on
    each finish quality panel. The following DFTs and associated standard deviations were obtained during
    this test:
Spray Gun
Average DFT
Std. Dev.
Airmix®
1.1
0.1
HVLP#1
1.2
0.1
HVLP #2
1.2
0.1
HVLP #3
1.2
0.1
    Gloss: The gloss was measured per ASTM D 523 at multiple points on each finish quality panel. The test
    method has a range of 0-100 gloss units. Since each coating has its own gloss target, it is important to
    achieve similar gloss measurements using each piece of application equipment.  The following gloss
    measurements and associated standard deviations were obtained during this test:
Spray Gun
Average Gloss
Std. Dev.
Airmix®
30
2
HVLP#1
34
3
HVLP #2
32
2
HVLP #3
33
2
                                                Vll

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    Visual Appearance: CTC personnel assessed the visual appearance of all finish quality panels. The intent
    of this analysis was to identify any obvious coating abnormalities that could be attributed to the
    application equipment. The visual appearance of the coating was found to be acceptable with no obvious
    visual abnormalities that would render the coating unacceptable for its  intended application.
SUMMARY

The test results show that the Airmix® spray gun provides paint transfer efficiency higher than that of HVLP
spray equipment while maintaining comparable finish quality. HVLP spray equipment has been shown
during earlier verification testing to have significantly higher transfer efficiency than conventional paint spray
guns, thereby reducing VOC/HAP emissions, paint usage rates, and solid waste generation. Hence, the
Airmix® spray gun provides a significant environmental benefit when compared to conventional spray guns.
As with any technology selection, the end user must select appropriate paint spray equipment for a process
that can meet the associated environmental restrictions, productivity, and coating quality requirements.


Original signed on                                   Original signed on
9/26/06                                             10/2/06
Sally Gutierrez                                      Robert J. Fisher
Director                                            Manager
National Risk Management Research Laboratory       ETV CCEP
Office of Research and Development                  Concurrent Technologies Corporation
U.S. Environmental Protection Agency
   NOTICE: EPA verifications are based on evaluations of technology performance under specific, predetermined
   criteria and appropriate quality assurance procedures.  EPA and CTC make no expressed or implied warranties as
   to the performance of the technology and do not certify that a technology will always operate as verified.  The
   end user is solely responsible for complying with any and all applicable federal, state, and local requirements.
   Mention of commercial product names does not imply endorsement.	
                                                 Vlll

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                                 Acknowledgments

CTC acknowledges the support of all those who  helped plan and implement the verification
activities and prepare this report. In particular, a special thanks to Michael Kosusko, EPA ETV
CCEP Project Manager, and Shirley Wasson, EPA ETV CCEP Quality Assurance Manager, both
of EPA's National Risk Management Research Laboratory in Research Triangle Park, North
Carolina.

CTC also expresses sincere gratitude to EXEL Industrial, Inc., the manufacturer of the Kremlin
Airmix® spray gun, for their participation in, and support of this  program and their ongoing
commitment to improve organic finishing operations. In particular, CTC would like to thank Mr.
John Patry,  President  of EXEL Industrial, Inc. and Mr.  Michael Michalski, Regional Sales
Manager with EXEL Industrial, Inc.   EXEL Industrial, Inc.'s U.S. office is based in West
Chicago, Illinois.
                                           IX

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                           SI to English Conversions
                                                              Multiply SI
                                                              by factor to
SI Unit	English Unit	obtain English
o
 C                        °F                                1.80, then add 32
L                         gal. (U.S.)                                  0.2642
m                         ft                                           3.281
kg                        Ibm                                         2.205
kPa                       psi                                        0.14504
cm                        in.                                         0.3937
mm                       mil (1 mil = 1/1000 in.)                       39.37
m/s                       ft/min                                       196.9
kg/L                      Ibm/gal. (U.S.)                               8.345

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                     List of Abbreviations and Acronyms

ASTM       American Society for Testing and Materials
CCEP       Coatings and Coating Equipment Program
CTC         Concurrent Technologies Corporation
DEP         Department of Environmental Protection
DFT         dry film thickness
EPA         U.S. Environmental Protection Agency
ETV         Environmental Technology Verification
HAP         hazardous air pollutant
HVLP       high-volume, low-pressure
ID           identification
NDCEE      National Defense Center for Environmental Excellence
NIST        National Institute for Standards and Technology
P2           pollution prevention
PEA         performance evaluation audit
QA/QC      quality assurance/quality control
SCAQMD    South Coast Air Quality Management District
SCFM       standard cubic feet per minute
TCEQ       Texas Commission on Environmental Quality
TE          transfer efficiency
TNRCC      Texas Natural Resources Conservation Commission
TQAPP      Testing and Quality Assurance Project Plan
TSA         technical system audit
VOC         volatile organic compound
                                     XI

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                                       Section 1
                                    Introduction
1.1    ETV Overview
       Through the Environmental Technology Verification (ETV) Pollution Prevention (P2)
Innovative  Coatings  &  Coating  Equipment  Program  (CCEP)  pilot,  the  United  States
Environmental  Protection  Agency  (EPA)  is assisting  manufacturers  in  selecting more
environmentally  acceptable  coatings and equipment  to  apply coating  materials.  The ETV
program, established by the EPA as a  result of the President's environmental technology
strategy, Bridge to a Sustainable Future., was developed to accelerate environmental technology
development  and  commercialization  through  third-party  verification  and  reporting  of
performance.  Specifically, this pilot targets coating technologies that are capable of improving
organic finishing operations,  while reducing the quantity of volatile organic compounds (VOCs)
and hazardous air pollutants  (HAPs) generated by coating applications. The overall objective of
the ETV CCEP is to verify pollution prevention and performance characteristics of coatings and
coating equipment technologies and  to make the  results of the verification tests available to
prospective technology end  users.  The ETV CCEP is managed by Concurrent Technologies
Corporation (C7U), located  in Johnstown, Pennsylvania.  CTC, under the National  Defense
Center  for  Environmental  Excellence   (NDCEE)  program,  was  directed  to establish  a
demonstration factory with prototype manufacturing processes that are capable of reducing or
eliminating materials that are harmful to the  environment. The demonstration factory finishing
equipment was made available for this project.

       The ETV CCEP is a  program  of partnerships among the EPA, CTC, the vendors of the
technologies  being  verified, and a  stakeholders  group.  The stakeholders group  comprises
representatives  of  end  users,  vendors,  industry  associations,  consultants,  and  regulatory
permitters.

       The purpose of this report is  to present the results of verification testing of the EXEL
Industrial, Inc. Kremlin Airmix® pressure-feed spray gun,  hereafter  referred  to as Airmix®,
which is designed for use in wood finishing.  This test compared the Airmix® against three high-
volume, low-pressure (HVLP) spray guns  using a clear topcoat from Valspar intended for wood
furniture finishing applications.  Analyses performed  during these tests followed American
Society for Testing and Materials (ASTM) methods or other standard test methods.

1.2    Potential Environmental Impacts

       VOCs are emitted to  the atmosphere from many industrial processes as well  as through
natural  biological reactions.   VOCs  are  mobile in the vapor phase,  enabling  them to travel
rapidly to the troposphere where they combine with nitrogen oxides in the presence of sunlight to
form photochemical oxidants.  These photochemical oxidants are precursors  to ground-level
ozone or photochemical smog.1  Many VOCs, HAPs,  or the subsequent  reaction products are
mutagenic, carcinogenic, or  teratogenic,  (i.e., cause gene mutation, cancer, or abnormal fetal
development).2   Because of these  detrimental  effects,  Titles  I and III of the  Clean  Air  Act
Amendments of 1990 were established to control ozone precursors and HAP emissions.2'3

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       Painting operations contribute approximately 20% of stationary source VOC emissions.
These operations also contribute to HAP emissions, liquid wastes, and solid wastes. End users
and permitters often overlook these multimedia environmental effects of coating operations.
New technologies are needed and are being developed to reduce the total generation of pollutants
from coating operations. However, the emerging technologies must not compromise coating
performance and finish quality.
             testing equipment is located in a demonstration factory that was established under
the NDCEE  program. This equipment includes  full-scale, state-of-the-art  organic  finishing
equipment, as well as the laboratory equipment required to test and evaluate organic  coatings.
The  equipment and facilities have been made  available  for this  program for the  purpose of
testing and verifying the abilities of finishing technologies.

1.3    Technology Description

       The Airmix® was developed to reduce air pollution that typically results from organic
finishing operations  by improving  paint transfer efficiency  (TE).  Many current  regulations
require the use of HVLP spray guns or spray equipment that is at least as efficient as HVLP

       EXEL Industrial, Inc. proposes that the Airmix® can provide a high TE, comparable to
HVLP spray guns. That high TE leads to a reduction in paint usage, VOC and HAP emissions,
solid waste disposal, and spray booth maintenance costs.  Reduced overspray and bounce-back
provide a cleaner work environment with improved operator visibility.

1.4    Technology Testing Process

       Technology focus areas were  selected based on input from  the ETV CCEP stakeholders
group and market research. Upon initiating agreements with interested vendors, a draft Generic
Verification Protocol for high TE  spray  equipment was developed by CTC.   CTC, with
significant input from the vendors, then  developed a technology-specific Testing and Quality
Assurance Project Plan (TQAPP) for each piece of equipment being verified. After the vendor
concurred with, and  the EPA and CTC approved, the TQAPP, CTC personnel performed the
verification test. The Verification Statement that is produced as a result of this test may be used
by the technology vendor for marketing purposes,  or by end users selecting high TE spray
equipment. The Verification Statement for this product is included on pages v-viii of this report.

       Organic finishing technologies that  demonstrated  the ability to provide environmental
advantages were reviewed  and  prioritized  by the ETV  CCEP  stakeholders group.  The
stakeholders  group  is  composed  of  coating  industry  end  user  and  vendor  association
representatives, end  users, vendors, industry  consultants, and state and regional  technical
representatives. The  stakeholders group  reviewed  the  pollution prevention  potential  of each
candidate  technology  and considered the interests of industry. High TE spray equipment was
found to have a large pollution prevention potential, could be widely used by industry in organic
finishing activities,  and could potentially satisfy the HVLP equivalent alternatives allowance
provided by many regulating agencies and government specifications. As a result, High  TE spray
equipment received a high ranking by the Stakeholders.

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1.5    Test Objectives and Approach

       The testing was performed according to the EXEL Industrial Kremlin Airmix® TQAPP.
This project was designed to verify that the Airmix® is capable of providing the end user with a
pollution prevention benefit and an acceptable quality finish that is comparable or better than
HVLP spray equipment.  This project supplies the end users with the best available, unbiased
technical data to assist them  in determining whether the Airmix® meets their  needs. The
quantitative pollution  prevention benefit, in terms of improved  TE, depends on innumerable
factors that are often unique to each coating production line. Attempting to verify every possible
combination of these factors is  unrealistic. For this verification test, a specific combination of
these factors was  selected by CTC,  EPA,  EXEL  Industrial,  Inc., and  the ETV  CCEP
stakeholders. The data presented in this report are representative only of the specific conditions
tested; however, the test design represents an independent, repeatable evaluation of the pollution
prevention benefits and performance of the technology. To determine the environmental benefit,
the Airmix®'s TE is quantitatively and qualitatively compared to a three-gun, HVLP baseline
(see Section 4).  The HVLP guns used for this verification test were also pressure-feed.

       All  processing  and laboratory analyses  were performed at CTC  facilities. TE was
calculated to determine the relative  pollution prevention benefit of the technology. Dry film
thickness (DFT), gloss, and visual appearance were evaluated to verify finish quality. The finish
quality of the HVLP baseline panels was also evaluated to validate the comparability of the TE
data.

1.6    Performance and Cost Summary

       This verification has quantitatively shown that the Airmix® is capable of providing an
environmental benefit equivalent or better than HVLP guns (see Table 1). This environmental
benefit was quantified through the ability of the Airmix® to apply a coating at the same or higher
TE. This verification test has also shown that the Airmix® is capable of providing the end user
with an  acceptable quality finish.  The increased TE reduces  paint usage  and solid  waste
generation. The reduction in paint usage translates into a reduction in VOC and HAP emissions.
The extent that emissions and wastes are reduced depends on each individual application, which
must be determined on a case-by-case basis.

       TE is defined as the percentage of the paint solids sprayed that actually adhere to the
substrate.  This  test was designed to determine whether the Airmix® was capable of meeting or
exceeding the efficiency of three HVLP spray guns.  The test utilized wood panels for finishing
quality and wood panels wrapped with aluminum foil for TE  measurement.  A wood furniture
clear topcoat was used for both the Airmix®  and HVLP baseline tests.   Each  spray gun
completed five  runs, with each  run consisting of three TE foils and one wood panel. Table 1
summarizes the results for TE, air flow, DFT, gloss, and visual appearance.

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             Table 1. Verification Results for the Airmix® and HVLP Baseline
Factor
Transfer Efficiency3 (%)
Air Flow (SCFM)
Dry Film Thickness (mil)
Gloss, gloss units
Visual Appearance
Target
Equivalent or better than
the HVLP baseline
Minimal
Approximately 1 mil
Comparable to the HVLP
baseline
No significant defects
Results
Airmix®
54.4
3-5
1.1
30
No defects
HVLP
(ave. of 3 guns)
52.3
12
1.2
33
No defects
     Note that the TE for the Airmix® is better than the average and all individual HVLP data. In addition, the DFT and gloss are
    comparable.
       The capital costs of high TE spray guns are typically lower than HVLP spray guns. At the
time of this verification test, the list price of the Airmix® system (i.e., spray gun and high-
pressure fluid pump) was approximately $2,000, and the HVLP guns used for the baseline testing
ranged in list price from $450  - $550 (gun only).  Pressure-feed spray guns can  be used with
multiple fluid delivery  systems (e.g.,  pressurized paint  pots, low-pressure fluid  pumps, etc.),
which increases the cost of an HVLP system by another $500 - $2,000.  The operating costs of
the Airmix® and HVLP guns are similar, except that the Airmix® consumes less compressed air
at lower pressures than the HVLP guns.

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                                      Section 2
                           Description of the Technology

2.1    Technology Performance, Evaluation, and Verification

       The overall objectives of this  verification study are to verify  pollution prevention
characteristics and performance of coating equipment technologies and to make the results of the
verification tests available to the technology vendor for marketing to prospective technology end
users. The Airmix® is designed for use in wood finishing applications.  The combination of the
fluid tip and air cap determines the quality of the finish and the productivity potential. For this
verification study,  the Airmix® used a pressure-feed system, which utilized a fluid pump to
deliver the coating to the gun at 380 psig. The HVLP spray guns used a similar pressure-feed
system, but the coating was delivered to the spray guns at between 30-40 psig. A wood furniture
finishing clear topcoat,  35 Sheen Ecoplast El manufactured by Valspar, was used for both the
Airmix® and HVLP baseline tests.

       CTC, the independent, third-party evaluator, worked with the vendor of the technology
and the EPA throughout verification testing. CTC prepared this verification  report and was
responsible for performing the testing associated with this verification.

2.2    The Airmix® Test

       This verification test is based on the ETV CCEP EXEL Industrial Kremlin Airmix® and
the Valspar 35 Sheen Ecoplast El HVLP Baseline TQAPPs, which were reviewed by the EPA
and the vendor. EXEL Industrial, Inc., the manufacturer of the Airmix®, worked with CTC to
identify the optimum performance settings for the gun. EXEL Industrial, Inc. had determined the
parameters through tests that their personnel conducted at their facility and at CTC's facility in
Johnstown, Pennsylvania. CTC personnel used this  data to optimize the setup of the Airmix®
prior to the actual verification test.  Certain parameters used in the setup of the Airmix® spray
gun were utilized to establish a basis for optimization f    or  the  HVLP spray guns.    CTC
personnel used these parameters and the manufacturers'  documentation to optimize the setup of
the HVLP spray  guns.   Preliminary  TQAPPs  were  generated using  the vendor supplied
information and were submitted to EPA for review of content. Following review by EPA and
incorporation of their comments,  the  vendor was given the  opportunity to comment on the
specifics  of the TQAPPs. Any information pertinent to maintaining the quality of the study was
incorporated into the TQAPPs. A final draft  of the TQAPPs were reviewed by the vendor and
technical peer reviewers then approved by the EPA and CTC prior to testing.

       Testing was conducted under the direction of CTC personnel, with a representative from
EXEL Industrial,  Inc.  present  during  a  portion of  the testing. The EXEL  Industrial, Inc.
representative aided CTC in the initial Airmix spray gun setup, including making suggestions as
to which  fluid tip, air and fluid pressures to use. However, during the actual verification test, the
EXEL Industrial, Inc. representative served only as an observer.

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       All  information gathered  during verification  testing  was  analyzed,  reduced,  and
documented in this report. TE and finish quality measurements of the Airmix® and the relative
TE comparison to an  HVLP baseline were the primary  objectives of this report. The  data
comparison highlights the pollution prevention benefit of the Airmix® spray gun, as well as its
ability to provide the required finish quality. A portion of the test data has been quality audited
by EPA and the CTC Quality Assurance Officer to ensure the validity of the data.

2.3    Airmix® Spray Application Equipment

       Pressure-feed systems consist of a fluid pump and a fluid hose capable of handling the
required pressures. The fluid pumps are designed to maintain a relatively constant paint flow rate
to the spray guns during operation.  The Airmix®,  a modified air-assisted airless spray  gun,
operates at fluid pressures somewhat higher than typical HVLP spray guns. However, the fluid
pressure is significantly less than a typical airless spray gun.

       2.3.1  Applications of the Technology

             The Airmix® is  relatively universal in its  applications, with some applications
       obtaining better results.  The Airmix® can be used for many applications; however, a
       wood finishing application was the subject of this verification test.  Wood finishing
       operations use the Airmix® because it is a nearly a drop-in substitute  for conventional
       and HVLP spray guns, requires less air flow, is capable of high production rates, and has
       comparable maintainability and is interchangeable with other spray guns.

       2.3.2  Advantages of the Technology

             The Airmix® is  designed  to reduce VOC emissions that typically result from
       spray  painting  operations  by  increasing paint  TE. HVLP  equipment  use  has been
       legislated as a requirement in many states, such as, California South Coast Air Quality
       Management  District's  (SCAQMD) Rules 1151 and 1145, the  Texas  Commission on
       Environmental Quality (TCEQ), Texas Administrative Code  30  TAC 115.422,  and the
       Pennsylvania Department of Environmental Protection's (DEP) Title 25, Section 129.52.
       Similar  requirements have  been adopted in legislation  throughout the  United  States.
       High efficiency spray guns, like the Airmix®, have the potential for being recognized as
       equivalent to HVLP for  regulatory  purposes  and,  therefore,  eligible  for  use in
       traditionally HVLP-only  areas.

       2.3.3  Limitations of the Technology

             If the Airmix®  is  accepted by the  appropriate local regulatory  agencies as
       compliant with the applicable regulatory requirements,  there are no apparent limitations
       on the Airmix® for wood finishing or any other organic finishing operations.  However,
       some agencies may require approval prior to using the Airmix® in their jurisdiction.  The
       use of the Airmix® may be limited in areas were approval is not granted.

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2.3.4   Technology Deployment and Costs

       The  Airmix® has many potential applications,  with few  limitations  on its
distribution throughout the various finishing industries. The use of a portable fluid pump
and reduced air consumption enhances its usability. The Airmix® is cost  effective
because it is similar in capital and operating costs to HVLP; however, economic benefits
are realized through reduced paint usage as  a result of improved TE and finish quality.

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                                       Section 3
                  Description and Rationale for the Test Design

3.1    Description of Test Site

       The testing of the Airmix® was  conducted at the Organic Finishing Line, in CTC's
Environmental Technology Facility Demonstration Factory. The layout of the Organic Finishing
Line is shown in Figure 1.
                                             CLEANING PRETREATMENT
                        Figure 1.  Organic Finishing Line at CTC
       The finishing quality test panels were provided to CTC by EXEL Industrial,  Inc.  The
panels were sealed and mechanically sanded prior to shipment to CTC.  The TE foils were
wrapped on wood panels similar in shape and size to the finish quality panels.  The aluminum
foil sheets were cut, weighed and stored until needed for testing.

       The spray booths are capable of producing air velocities of over 0.6 m/s (120 ft/min). The
three  stages of dry filters are equipped with a gauge that monitors the pressure drop across the
filter bank. Air supply lines for operating the guns and gauge readouts are located at the spray
booths and were used for this test. A linear robotic translator was used to move the spray guns
vertically and horizontally when applying  the  coatings.  The computer-controlled  translator
system was used to remove any operator bias.

       CTC's Environmental Laboratory  maintains extensive state-of-the-art facilities that are
dedicated to coating technology evaluations and can also  measure and characterize products,
processes, and waste specimens resulting from factory activities.

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3.2    Evaluation of Airmix® Performance
       The overall objectives of the verification study were to establish the pollution prevention
benefit  of the Airmix®, relative to the  TE  of HVLP spray guns,  and to determine  the
effectiveness of the Airmix® in providing an acceptable coating finish. Section 4  discusses the
details of the HVLP baseline. Finish quality  cannot  be compromised  in most  applications,
despite the environmental benefit that may be achieved; therefore, this study has evaluated both
of these crucial factors. Results from the Airmix® verification testing will benefit prospective
end users by enabling them to better determine whether the Airmix® will provide  a pollution
prevention benefit while meeting the finish quality requirements for their application.

       3.2.1   Test Operations at CTC

              The TQAPPs for the Airmix® and HVLP baseline identified that testing would
       consist of foils used  for TE and wood panels used for finish quality. The statistical
       analyses for all response factors were performed using  a Microsoft Excel spreadsheet.
       The spreadsheet was programmed to calculate values like standard deviation,  confidence
       interval, and relative percent difference.

              The TE foils measured approximately 91.4 cm by 91.4 cm (36 in. x 36 in.).  All
       foils were wrapped onto wood panels measuring 61.0 cm by 61.0 cm (24  in. x 24 in.),
       which were suspended in the spray booth using two hooks. The foil covered panels were
       carried by hand to and from the booth.  Once coated, the foils were carefully moved to a
       location outside the spray booth and allowed to air dry for at least four days.

              The finish quality panels  used for  verification testing were flat, wood panels,
       sealed and sanded.  The wood panel dimensions were 30.5 cm by 61.0 cm (12 in. x 24
       in.). The wood panels were also suspended in the spray booth using two hooks. Once the
       panels were coated,  they were moved to a location outside the spray booth by hand  and
       allowed to air dry for  at least four days.  Figure 2 illustrates the application pattern used
       both the TE foils and the finish quality wood panels.
                                             A
                                                               12"x24" panel
         W—.
                                                                          I
                                                                         7
                                                             I  100% coverage area  	!     \ j
                          Figure 2. Application Pattern Diagrams

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       The Valspar clear topcoat used for this test was  mixed 10:1 with the Valspar
reducer.  The mixed clear topcoat had an estimated pot life of 4 hours. A single batch of
coating was mixed for each gun.  Samples were taken just prior to each of the five runs to
measure the temperature, viscosity, percent solids, and density.

       The Airmix® and HVLP spray guns were mounted  on a nylon arm extending
from the carrier plate  of the  robotic translator, which was computer-controlled. The
computer also controlled the pneumatic cylinder that triggered the gun. The product data
sheets  for the Airmix® and baseline HVLP spray guns can be  found in Appendix A of
the Kremlin Airmix® Data Notebook.  The air traveled from a quick disconnect at the
shop line to the air inlet to the spray gun using 9.5-mm (3/8-in.) inside diameter air hose.
The operating  parameters  for  the  spray   guns   were  based  on  manufacturer's
recommendations (see Sections 4 and  5).

       The booth air velocity  was measured in close proximity to the panels. The air
velocity through the booth was measured between 0.6 and 0.7  m/s (-120 and 140 ft/min).
The velocity measured near the panels may vary greatly because of the disruption of the
air currents by the rack and panels.  The pressure drop across the filters was also checked
prior to each run and at the end of the test. To ensure that the filter bank system was
functioning properly, a pressure drop across the filter bank greater than  1.0 cm of water
indicated that the system required service.

       Once the foils/panels were in position, all pertinent measurements taken, and
equipment adjustments made, the computer system was used to activate the motors that
drove the linear motion translators and the pneumatic cylinder that triggered the gun. The
panels  were automatically sprayed using vertical overlap of the fan pattern.  The foils and
panels  were air dried in the factory  for at least four days prior to being transferred to the
laboratory for analysis.

       Fifteen foils and five wood panels were coated by each of the four spray guns.
TE was determined using the average weight gain of the foils,  per the ASTM standard.
Coated wood panels were analyzed for DFT, gloss, and visual  appearance.

3.2.2   Test Sampling Operations at CJCs ETF facility

       Foils and panels  were used  in this project.  The foils  were  marked  with  a
permanent marker prior to checking their initial weight. Wood  panels were also marked
with a  unique alphanumeric identifier. The experimental design used 3 foils and 1 wood
panel in each of five runs  per gun.

       The laboratory analyst  recorded the date and time of each  run  and the time at
which  each measurement  was taken. After curing, the foils and panels were transferred to
the laboratory for analysis.
                                    10

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       3.2.3   Sample Handling and Quality Assurance/Quality Control Procedures

              Each batch of test coating was mixed in the laboratory by a laboratory analyst.
       The components were all taken from the same  production batches.  All coating batches
       were  mixed  to  the  same  ratio  recommended  by the  coating  manufacturer.   The
       temperature,  viscosity,  density,  VOC  content,  and  percent solids  analyses  were
       performed.  Data were logged on bench  data sheets, precision and accuracy data were
       evaluated, and  results  were recorded on  the  ETV CCEP Quality Assurance/Quality
       Control (QA/QC) Data forms. Another laboratory staff member reviewed the data sheets
       for QA.

              After curing,  the laboratory  analyst logged the  coated samples panels into the
       laboratory system, giving each a unique  laboratory identification  (ID)  number. The
       analyst who delivered  the test panels to the laboratory completed  a custody log that
       indicated the sampling point IDs, sample material IDs, quantity of samples,  time and date
       of testing, and the analyst's initials. The product evaluation tests were also noted on the
       custody log, and the laboratory's sample custodian verified this information. The analyst
       and the sample  custodian both signed the custody log, indicating  the transfer of the
       samples from the processing area to  the laboratory analysis area. The laboratory sample
       custodian logged the test panels into a bound record book, stored the test panels under the
       appropriate conditions, and created a  work order to initiate testing.

              Each apparatus used to assess the quality of a coating on a test panel is set up and
       maintained  according to the manufacturer's instructions  and/or the appropriate reference
       methods. Actual sample analysis was performed only after setup was verified per the
       appropriate instructions. As available, samples of known  materials, with  established
       product quality,  were used to verify that a system was working properly.

3.3    Data Reporting, Reduction, and Verification Steps

       3.3.1   Data Reporting

              Raw data were generated and collected  manually and  electronically by the
       analysts at  the bench and/or process level. Process data were  recorded on process log
       sheets  during factory  operations. The recorded  data  included  original  observations,
       printouts, and readouts from equipment for sample, standard, and reference QC analyses.
       Data was checked twice by the analyst or  operator before being recorded.  The analyst
       processed raw data and was responsible for reviewing  the  data according to specified
       precision, accuracy, and completeness policies.  Raw data bench sheets, calculations, and
       data summary sheets for each sample batch were kept together.  The data transcribed into
       electronic format was reviewed by a second staff member.
                                           11

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3.3.2   Data Reduction and Verification

       A preliminary data package was assembled by the primary analyst(s). The data
package was reviewed  by a different analyst to ensure that tracking, sample treatment,
and calculations were correct. A preliminary data report was prepared and submitted to
the Laboratory Manager, who then reviewed all final results for adequacy to  project QA
objectives.  After  the EPA reviewed the results and  conclusions from  the Technical
Project Manager, the Verification  Statement/Verification Report was written, sent to the
vendor for comment, passed through technical peer review,  and submitted to EPA for
approval. The Verification Statement was disseminated by permission of the vendor.
                                    12

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                                      Section 4
                                  Reference Data

4.1    HVLP Parameter Development

       Each of the HVLP guns was set up in the same apparatus as the Airmix®. The HVLP
guns were set at 17.8 cm (7 in.) from the surface of the targets, and their air adjustments were set
to achieve a 30.5 cm (12 in.) fan pattern at the target.  The Airmix® was set at 20.3 cm (8 in.)
from the targets with its air adjustment wide open in order to maintain the same 30.5 cm (12 in.)
fan pattern as the HVLP spray gun.  The HVLP spray gun parameters were optimized by CTC
personnel according to the manufacturers' documented procedures.

       The fan pattern, application pattern, and horizontal gun speed were fixed to establish the
basis for comparison.  Using information from the gun manufacturers'  product data sheets,  a
trial-and-error method  was used to obtain a wet film thickness of approximately 3 mils, which
corresponds to a dry film thickness of 1.0 mil. A wet film thickness  gauge was used during this
process. The fluid pressure delivered to the guns was the primary method of adjustment.  If the
wet thickness obtained on a practice specimen was  less than 3 mils,  then the fluid pressure was
increased, and vice-versa. Table 2 lists the configuration and  setup  conditions the three HVLP
guns.
                 Table 2. HVLP Baseline Guns Configuration and Setup
HVLP Gun
Air Cap
Fluid Tip (mm)
Fluid Pressure (psig)
Fluid Flow Rate (g/min)
Fluid Adjustment
Fan Adjustment
Fan Pattern (cm)
Number Passes
Number Coats
Distance to Target (cm)
Horizontal Travel Distance per
Pass (cm)
[Foil / Wood Panels]
Spray Distance per Pass (cm)
[Foil / Wood Panels]
Vertical Drop Between Passes
(cm)
Horizontal Gun Speed (cm/s)
Paint Temperature (°C)
Viscosity (s)
Density (g/L)
Weight % solids (%)
#1
192-321
1.4 mm
40
658
Wide Open
1 full turn in
30.5
5
1
17.8
106.7/76.2
76.2/45.7
15.2
61.0
21.0
29.4
961
33.9
#2
VLP5
1.4 mm
30
567
Wide Open
!/2 turn in
30.5
5
1
17.8
106.7/76.2
76.2/45.7
15.2
61.0
21.5
29.7
958
34.1
#2
95AP
1.4 mm
32
601
Wide Open
1 % turn in
30.5
5
1
17.8
106.7/76.2
76.2/45.7
15.2
61.0
20.6
29.3
960
34.0
                                          13

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4.2    HVLP Results
       The data in Table 3 shows the operational characteristics obtained for each of the three
HVLP guns. The data indicate that finish quality was not sacrificed to maximize TE.  Therefore,
the comparison of the TE data from the HVLP baseline and the Airmix® is valid.

                 Table 3. HVLP Baseline Guns Response Factor Results
HVLP Gun
Dynamic Input Air Pressure (psig)
Dynamic Output Air Pressure (psig)
Air Flow (scfm)
Average DFT (mils)
Average Gloss (units)
Visual Appearance
Average TE (%)
#1
40
Horn -5
Center -10
14
1.2
34
NDa
51.6
#2
40
Horn -7
Center -10
9
1.2
32
ND
53.1
#3
50
Horn -8
Center -10
12
1.2
33
ND
52.2
         1 ND - No Defects
                                          14

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                                      Section 5
                               Results and Discussion

       This section presents an overview of the verification test results, including an analysis of
environmental benefits of the Airmix® spray gun and a summary of data quality. Data generated
during this test are being compared to  an  HVLP  baseline in  order to establish the relative
environmental benefit of the product. An explanation  of the manner in which the  data were
compared is provided. Subsequently, the actual tabulation, assessment, and evaluation of the data
are presented. The accuracy, precision, and completeness data, the process and laboratory bench
sheets, raw data tables,  and calculated data tables  are included in  Section  5  of the Kremlin
Airmix® Data Notebook.

5.1    Potential Environmental Benefits and Vendor Claims

       The primary purpose of this test is to verify  that the Airmix® spray gun provides a TE
and finish quality comparable or better than and HVLP baseline. EXEL Industrial, Inc. makes no
claims on the absolute TE obtainable by the Airmix®.

5.2    Selection of Test Methods and Parameters Monitored

       CTC, the ETV CCEP partner organization, performed the laboratory testing required for
this verification test. CTC possesses the skills, experience, and most of the laboratory equipment
required by this verification study. The ETV CCEP selected test  procedures, process conditions,
and parameters to be monitored based on their correlation to, or impact on, TE or finish quality.

       5.2.1  Process Conditions Monitored

             The  conditions listed  below  were documented  to ensure  that there were no
       significant fluctuations in conditions during the Airmix® verification test and the HVLP
       baseline tests. No significant differences  were recorded.  A more detailed discussion of
       the data is presented in Section 3 of the Kremlin Airmix® Data Notebook.

             •  Coating area relative humidity ranged from 22.3% to 28.4%
             •  Curing area relative humidity ranged from 21.8% to 28.6%
             •  Coating area temperature ranged from 22.0 to 23.3 °C
             •  Curing area temperature ranged from 21.0 to 24.8 °C
             •  Spray  booth air velocity ranged from 0.6 to 0.7 m/s
             •  Panel temperature ranged from 22.2 to 22.8 °C

       5.2.2  Operational Parameters

             A number of operational parameters were also monitored because they  often vary
       from gun to gun. These  parameters were documented to explain TE  and finish quality
       improvements over HVLP guns, and to identify parameters that are likely to change when
       replacing HVLP  guns with the Airmix®. The dynamic input air pressures varied from
       gun to gun. The  Airmix® was operated at 10 psig, and  the three HVLP baseline guns
                                          15

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       were run at 40, 40, and 50 psig, respectively.  The distance to target was maintained at
       17.8 cm for all HVLP spray guns, and 20.3 cm for the Airmix®, in order to maintain the
       same fan pattern size for all four spray guns.  The fan pattern obtained from each gun was
       maintained at 30.5 cm. The horizontal gun speed was maintained at 61.0 cm/s for all
       spray  guns.  A more detailed  discussion of the data is presented in Section 3 of the
       Kremlin Airmix® Data Notebook.

       5.2.3  Parameters/Conditions Monitored

             Other parameters and conditions were monitored to ensure that they  remained
       relatively constant throughout Airmix® verification testing and HVLP baseline testing.
       Constancy was desired in order to reduce the number of factors that could significantly
       influence TE calculations and evaluation of finish quality. Most of these parameters were
       relatively constant within each test and from gun to gun. Table 4 lists the configuration
       and setup conditions of the Airmix® gun.

                       Table 4. Airmix® Configuration and Setup
Air Cap
Fluid Tip (mm)
Fluid Pressure (psig)
Fluid Flow Rate (g/min)
Fluid Adjustment
Fan Adjustment
Fan Pattern (cm)
Number Passes
Number Coats
Distance to Target (cm)
Horizontal Travel Distance per Pass (cm)
[Foil / Wood Panels]
Spray Distance per Pass (cm)
[Foil / Wood Panels]
Vertical Drop Between Passes (cm)
Horizontal Gun Speed (cm/s)
Paint Temperature (°C)
Viscosity (s)
Density (g/L)
Weight % solids (%)
VX14
14-174+
380
468
N/A
Wide Open
30.5
5
1
20.3
106.7/76.2
76.2/45.7
15.2
61.0
21.4
29.9
960
34.0
5.3    Overall Performance Evaluation of the Airmix® Spray Gun

       The DFT  and gloss  obtained using the Airmix® are  both  within  10% of the HVLP
baseline averages.  Therefore, the finish quality of the Airmix® is determined to be comparable
to the finish quality of the HVLP baseline and was able to meet the finish quality requirements of
the test coating; thus, the TE values obtained for the Airmix® test are representative of the actual
operation of the equipment. The DFT and gloss of the HVLP baseline panels are considered to
be representative of the actual operation of the equipment, and the TE values obtained from the
HVLP baseline are determined to be representative of the HVLP guns tested. The DFT and gloss
                                           16

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values obtained for the HVLP baseline are similar to those for the panels from the Airmix® test;
therefore, the comparison of the TE data from the Airmix® and the HVLP baseline is valid.

       This test determined that the Airmix® provided a direct environmental benefit, in terms
of higher TE than the baseline HVLP spray guns.  Tables 3 and 5  show that the Airmix®
achieved a higher transfer efficiency than each of the individual HVLP guns, while maintaining a
finish quality similar to the baseline.  The  increased TE leads to  reduced air emissions, paint
usage, and solid waste generation.  In addition, reduced Dynamic Input Air Pressure and Air
Flow provide an indirect environmental benefit since they represent lower energy usage.  A 95%
confidence interval is being utilized to statistically evaluate the data.  Section 5 of the Kremlin
Airmix® Data Notebook shows that the Airmix® is statistically better than the individual HVLP
guns and the HVLP average for all combinations.

       The test results indicate that the Airmix® was able to provide an environmental benefit
equivalent to or better than an HVLP baseline and maintain the required finish quality of the
applied coating.

       5.3.1  Response Factors

             Responses to the process conditions  and  parameters  were considered to be
       important due to their effect on, or ability to evaluate, TE  and  finish quality; therefore,
       these  responses were documented,  and the appropriate tests required to identify these
       characteristics  were performed. Any response  that was  characterized using laboratory
       equipment followed accepted  industrial and  ASTM standards. Table  5 presents the
       average  results for the response  factors for the Airmix®  spray gun. A more detailed
       discussion of the data is presented in  Section 3 of the Kremlin Airmix® Data Notebook.

                       Table 5. Airmix® Response Factor Results
Dynamic Input Air Pressure (psig)
Air Flow (scfm)
Average DFT (mils)
Average Gloss (units)
Visual Appearance
Average TE (%)
10
3-5
1.1
30
NDa
54.4
               aND-No Defects

              The DFT and gloss data indicate that the coating finish applied by the Airmix® is
       comparable to the HVLP baseline based on the intended application of the test coating.

              The TE for each gun is a representation of the exact verification test conditions,
       which includes the paint that was sprayed while the guns were outside the boundaries of
       the panels. The calculation of the  TE uses the total amount  of paint sprayed and the
       weight  gain  of the  coated panels,  both determined  through gravimetric weight
       measurements.
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       5.3.2  Assessment of Laboratory Data Quality

             The Airmix® TE results were compared to the HVLP baseline data. The Airmix®
       results for DFT and gloss were compared to the HVLP baseline data. The information
       gathered was considered to be statistically valid and significant such that the advantages
       and limitations of Airmix®, per these test conditions, could be identified with a high
       degree of confidence. It can be stated with greater than 95% confidence that the Airmix®
       provided a higher TE than the HVLP baseline.

5.4    Technology Data Quality Assessment

       Accuracy, precision, and completeness goals were established for each process parameter
and condition of interest, as well as each test method used. The goals are outlined in the TQAPP.

       All laboratory analyses and monitored process conditions/parameters met the accuracy,
precision, and completeness requirements  specified  in the TQAPP, except  for the  deviations
listed in  Section 2  of the Kremlin  Airmix® Data Notebook.  These deviations  did not
significantly affect the results and conclusions of this test. The definition of accuracy, precision,
and completeness, as well as the methodology used to maintain the limits placed on each in the
TQAPP,  are presented below. The  actual  accuracy, precision, and completeness values,  where
applicable, are presented in Section 5 of the Kremlin Airmix® Data Notebook.

       5.4.1  Accuracy, Precision, and Completeness

             Accuracy is defined  as  exactness of a measurement;  i.e., the degree to which a
       measured value corresponds with that of the actual value.  To ensure that measurements
       were accurate,  standard reference materials, traceable  to  the National Institute  of
       Standards and  Technology (NIST), were used  for instrument calibration  and  periodic
       calibration verification.  Accuracy was determined to be within the expected values listed
       in the TQAPP. Accuracy results are located in Section 5 of the Kremlin Airmix® Data
       Notebook.

             Precision  is defined  as  the agreement of two or more measurements that have
       been performed in exactly the same manner. Ensuring that measurements are performed
       with  precision is an important  aspect of verification  testing.   The exact number of test
       parts coated is identified in the TQAPP, and the analysis  of replicate test parts  for each
       coating property  at each of the experimental conditions occurred by  design.  Precision
       was determined to be within the expected values listed in the TQAPP.  All precision data
       are listed in Section 5 of the Kremlin Airmix® Data Notebook.

             Completeness is defined as the number of valid determinations and expressed as a
       percentage of the total number of analyses conducted, by analysis type. CTU's laboratory
       was striving for  at least 90%  completeness.  Completeness is ensured by evaluating
       precision  and accuracy data during analysis. All laboratory results for finish quality were
       100% complete.  All results  were reviewed and considered usable for statistical analysis.
       Completeness results are shown in Section 5 of the Kremlin Airmix® Data Notebook.
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5.4.2   Audits

       The ETV CCEP QA Officer conducted an internal technical systems audit (TSA)
and a performance evaluation audit (PEA) of the Airmix® verification test.  Also, prior to
the certification of the data, the ETV CCEP  QA Officer audited a portion of the data
generated during the Airmix® test.

       The TSAs verified that CTCs personnel were adequately trained and prepared to
perform their assigned duties, and that routine procedures were adequately documented.
The  ETV  CCEP  QA Officer examined copies of test  data  sheets  that recorded
information  such as process conditions, spray booth conditions,  equipment setup, and
coating preparation and reviewed  laboratory bench sheets  showing  data for  coating
pretreatment weights, densities,  and percent nonvolatile matter.

       The ETV CCEP QA Officer audit found that the Airmix® test was conducted in a
manner that provides valid  data to  support this Verification Statement/Report.  Several
deviations from the original TQAPP were identified by the  TSA and PEA and are
discussed in Section 2 of the Kremlin Airmix® Data Notebook.
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                                 Section 6
                              Vendor Forum

[EXEL Industrial, Inc. has been offered the opportunity to comment on the findings
of this report. Their comments are presented in this section of the report and reflect
their opinions. CTC and EPA do not necessarily agree or disagree with the vendor's
comments and opinions.]
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                                  Section 7
                                 References

1.  Curran, T., et al., National Air Quality and Emissions Trends Report, 1990, EPA-
   450/4-91-023, NTIS PB92-141555, U.S. Environmental Protection Agency, Office of
   Air  Quality Planning and  Standards, Research Triangle Park, North Carolina,
   November 1991.

2.  Clean Air Act Amendments of 1990, Title III - Hazardous Air Pollutants, November
   15, 1990

3.  Clean Air Act Amendments of 1990, Title I - Attainment/Maintenance of National
   Ambient Air Quality Standards (NAAQS), November 15, 1990.
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