September 2003
  Environmental Technology
  Verification  Report

  Allied Photochemical
  KrohnZone7014
  UV-Curable Coating
              Prepared by
   National Defense Center for Environmental Excellence
              Operated by
  cji^zConcurrent Technologies Corporation
                for the
       U.S. Environmental Protection Agency
       Under Contract No. DAAE30-98-C-1050
with the U.S. Defense Contract Command -Washington (DCC-W)
    via EPA Interagency Agreement No. DW2193939801

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                                      Notice

This document was prepared by Concurrent Technologies Corporation (CTC) under Contract No.
DAAE30-98-C-1050 with the U.S. Defense Contract Command - Washington (DCC-W), Task
N.306, SOW Task 4.  The U.S. Environmental Protection Agency (EPA) and the U.S. Army are
working together under EPA Interagency Agreement No. DW2193939801.  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 2003
    Environmental Technology
          Verification Report
          Allied Photochemical

KrohnZone 7014 UV-Curable Coating


                    Prepared by

                 Brian D. Schweitzer
                 Jacob E. Molchany
                  Robert J. Fisher
                 Lynn A. Summerson

                      of the
     National Defense Center for Environmental Excellence

                    Operated by
           Concurrent Technologies Corporation
                Johnstown, PA 15904
Under Contract No. DAAE30-98-C-1050 (Task N.306, SOW Task 4)
 with the U.S. Defense Contract Command - Washington (DCC-W)
     via EPA Interagency Agreement No. DW2193939801
                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/.

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

The following report describes the verification  of the performance of the Allied Photochemical
KrohnZone 7014 UV-curable coating for automotive manufacturing 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   UV-Curable Coating Technology Description	2
      1.4   Technology Testing Process	2
           1.4.1   Technology Selection	2
      1.5   Test Objectives and Approach	3
      1.6   Performance Summary	3
Section 2 Description of the Technology	5
      2.1   Technology Performance, Evaluation, and Verification	5
      2.2   The KrohnZone 7014 Test	5
      2.3   UV-Curable Coating Technology	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	9
      3.1   Description of Test Site	9
      3.2   Evaluation of KrohnZone 7014's Performance	9
           3.2.1   Test Operations at Allied Photochemical and CrC	9
           3.2.2   Test Sampling Operations at CTC's ETF	10
           3.2.3   Sample Handling and Quality Assurance/Quality Control Procedures	10
      3.3   Data Reporting, Reduction,  and Verification Steps	11
           3.3.1   Data Reporting	11
           3.3.2   Data Reduction and Verification	11
Section 4 Results and Discussion	13
      4.1   Potential Environmental Benefits and Vendor Claims	13
      4.2   Selection of Test Methods and Parameters Monitored	13
           4.2.1   Process Conditions  Monitored	13
           4.2.2   Operational Parameters	13
           4.2.3   Parameters/Conditions Monitored	14
      4.3   Overall Performance Evaluation of KrohnZone 7014	14
           4.3.1   Assessment of Laboratory Data Quality	14
      4.4   Technology Data Quality Assessment	14
           4.4.1   Accuracy,  Precision, and Completeness	14
           4.4.2   Audits	15
Section 5 Vendor Forum	17
Section 6 References	19
                                           in

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                                List of Tables

                                                                          Page
Table 1. Verification Factors for KrohnZone 7014	4
                         List of Associated Documents

KrohnZone 7014 Data Notebook (Available from CTCupon request)
                                      IV

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         THE ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
   &EPA
                                                                       Gmi-urirm
                                                                       TffiifHrftr^iex
                                                                       Qtrponuton
            ETV JOINT VERIFICATION STATEMENT
     TECHNOLOGY TYPE:
     APPLICATION:
                           ULTRAVIOLET (UV) CURABLE LIQUID COATING
                           LIQUID ORGANIC COATING FOR AUTOMOTIVE
                           MANUFACTURING
     TECHNOLOGY NAME:      KrohnZone™ 7014

                      Allied PhotoChemical
                      Roy Krohn, Founder & CSO
                      P.O. Box 328
                      Marysville, MI 48040-0328
                      roy@alliedphotochemical.com
COMPANY
POC:
ADDRESS:
EMAIL:

WEBSITE:
                      www.alliedphotochemical.com
PHONE:
FAX:
(810) 364-6910
(810) 364-6933
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 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; with 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 seven technology areas 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 an innovative liquid coating intended
for automotive manufacturing applications.  This verification statement provides a summary of the test results
for the KrohnZone 7014 UV-curable coating manufactured by Allied PhotoChemical.
                                             v

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VERIFICATION TEST DESCRIPTION

The ETV CCEP evaluated the pollution prevention capabilities of the KrohnZone 7014 UV-curable coating.
The  coating  application  phase and  a portion  of the laboratory  analyses  were conducted  at  Allied
PhotoChemical's facility in Marysville, MI.  The  remaining  testing was completed at  CTC's facility in
Johnstown, PA.  The test was designed to verify the environmental benefit of the UV-curable coating by
determining the total volatile content per ASTM D 5403. The test also verified the coating's finish quality
characteristics.

In this test, the KrohnZone  7014 UV-curable coating was tested under conditions  recommended by Allied
PhotoChemical, the coating's vendor.   The  test panels were 15.2 cm long  and  10.2 cm  wide.   Allied
PhotoChemical recommended the ITW Automotive Refinishing GTi high-volume, low-pressure spray gun
equipped with a 1.4 mm fluid tip and a #2000 air cap. The test consisted of five runs. During each run, one
set often panels was sprayed manually.

The total volatile content of the KrohnZone 7014  UV-curable coating was determined using ASTM D 5403.
This method  determines the processing volatiles generated during the UV-cure  phase  and the potential
volatiles generated by heat curing the UV-cured coating.   Total  volatiles are determined  by adding the
processing and potential results.

The details of the test, including a summary of the data and a discussion of results, may be found in Section 4
of the "Environmental Technology Verification  Report:  Allied PhotoChemical - KrohnZone 7014 UV-
Curable Coating," which is available at http://www.epa.gov/etv/verifications/verification-index.html. A more
detailed discussion of the test conditions, test results, and data analyses can  be found in "Environmental
Technology Verification Data Notebook:  Allied  PhotoChemical -  KrohnZone  7014 UV-Curable Coating,"
which is available from CTC.

QUALITY ASSURANCE / QUALITY CONTROL (QA/QC)

The EPA ETV CCEP QA manager conducted a technical systems  audit to assure that testing conducted at
Allied PhotoChemical's facility  was performed in compliance with the approved test plan, and the ETV
CCEP QA officer conducted a performance  evaluation audit  of the  laboratory analyses conducted in
Johnstown, PA, to  assure that the measurement systems employed were adequate to produce reliable data.
Also,  prior to the certification of the data, the ETV  CCEP QA officer and the EPA ETV QA manager both
audited at  least 10% of the data generated during the KrohnZone 7014 test to assure that the reported data
represented the data generated during testing.  In addition, the EPA ETV CCEP QA manager has conducted a
quality systems audit of the ETV CCEP Quality Management Plan and onsite visits during previous tests.

TECHNOLOGY DESCRIPTION

The KrohnZone 7014 UV-curable coating was tested as received from Allied  PhotoChemical  to assess its
capabilities. The coating was manually applied using the ITW Automotive Refinishing GTi HVLP spray gun
equipped with a 1.4 mm fluid tip and #2000 air cap and was  set to obtain a fan pattern of 10.2 cm (4 in.) 15.2
cm (6 in.) from the gun. The KrohnZone 7014 UV-curable coating is marketed to automotive manufacturers
as a single layer clearcoat.
                                               VI

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VERIFICATION OF PERFORMANCE

The performance characteristics of the KrohnZone 7014 UV-curable coating include the following:

Environmental Factors

    •   Total volatile content: The KrohnZone 7014 UV-curable coating exhibited 1.6% processing volatiles
       and 1.0% potential volatiles, for a total volatile content of 2.6%. The standard deviation for the total
       volatile content was 0.9%.

    •   Energy Usage: The coating was UV-cured under a medium mercury vapor lamp followed by an iron-
       doped lamp. Both lamps were tubes 76.2 cm in length and rated for 157.5 watts/cm. The panels were
       passed under the lamps on a conveyor belt moving at 16.7 cm/s.  Assuming that each panel passes
       through a 15.2 cm cure zone for each lamp, it can be calculated that 8.1x10^ kWh is required to cure
       one panel.  This value does not include the energy required to warm up the lamps or the energy
       expended by the length of the lamps that are idle.

Performance Factors

    •   Dry Film Thickness (DFT): The  DFTs for all runs were determined from six points measured on each
       panel. The DFT averaged 3.1 mils with a standard deviation of 0.2 mil.

    •   Visual Appearance: CTC personnel assessed the visual appearance of all 50 coated panels.  The intent
       of this analysis was  to identify any obvious coating abnormalities that could be attributed to the
       application equipment. No defects were found, and the coating was uniform from panel to panel and
       run to run.

    •   Gloss: The gloss was measured per ASTM D 523 Test Method at three points on one panel per run at
       both 20°  and 60°. The test method has a range of 0 to 100 gloss units. The 20° analyses yielded an
       average of 80.8 gloss units with  a standard deviation of 4.4 gloss units. The  60° analyses yielded an
       average of 92.3 gloss units with a standard deviation of 2.1 gloss units.

    •   Salt Spray Resistance: The salt spray resistance was determined per ASTM B  117 from one coated
       panel per run exposed to 2000 hours of salt spray. Corrosion appeared on the scribed areas between
       120 and  240 hours and on the unscribed areas between 120 and 1508 hours.  The creepage at the
       scribe ranged from 0 to 1.6 cm.  After the full 2000 hours, the scribed panels obtained an average
       rating of 6 (10 being no corrosion and 0 being total corrosion), and the unscribed panels obtained an
       average rating of 4.

    •   Humidity Resistance: The humidity resistance measurements were determined per ASTM D 1735
       from  one coated panel per run.  The panels were  placed in  the humidity chamber unscribed  and
       were  subjected to  2000 hours in the chamber. Three of the five panels developed between 7 and 30
       small blisters of 0.1 cm or less in size. The panels obtained an average rating of 9 (10 being no
       corrosion) after the full 2000 hours.

    •   Tape  Adhesion: Two tape adhesion tests were conducted according to  ASTM  D 3359,  one per
       Method A and one per Method B. Method A uses a scribe in the shape of an 'X'.  Method B uses a
       scribe in  a Crosshatch shape.  The rating scale for both methods ranges from 1 to 5, with 5 meaning
       no visible loss of adhesion or removal of coating.  The coated panels were rated 5A and 5B, which
       means that no visible loss of adhesion or coating  removal was present using Methods A and B,
       respectively.
                                               vn

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    •  Direct Impact: The direct impact measurements were  determined per ASTM D 2794 from one
       coated panel per run.  The measurements for all panels  averaged 3.1 J (27 in.-lbs) with a standard
       deviation of 0.1 J (1.0 in.-lbs).

    •  Mandrel Bend: The mandrel bend measurements for flexibility were determined per ASTM D 522
       on a conical mandrel from one coated panel per run.  The coating on all panels cracked and/or
       separated from the panels the entire 15.2 cm length of the sample panels.

    •  MEK (Methyl Ethyl Ketone) Rub:  The MEK rub measurements  were  determined per ASTM D
       5402 from one coated panel per run.  The measurements for all panels rated a 4 out of 5, indicating
       minor effects on the coating.

    •  Abrasion Resistance:  The abrasion resistance measurements were  determined per ASTM D 4060
       from one coated panel per run.  All panels were subjected to 1000 cycles using a CS-10 wheel and
       1000 g weight.  The weight  loss measurements for all panels were  92.6  mg with  a standard
       deviation of 8.8 mg.
Original signed on                                  Original signed on

September 30, 2003                                  September 30, 2003
Lee A. Mulkey                                     Brian D. Schweitzer
Acting 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 Allied Photochemical, the  manufacturer of  the
KrohnZone 7014 UV-curable coating, 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 Roy Krohn, Founder and Chief Science Officer (CSO) and Scott Howe, Vice
President, Operations. Allied Photochemical is based in Marysville, MI.
                                           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, liq(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, liq(U.S.)                           8.345

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                     List of Abbreviations and Acronyms

APC         Allied Photochemical
APPCD      Air Pollution Prevention and Control Division
ASTM       American Society for Testing and Materials
CCEP       Coatings and Coating Equipment Program
CSO         Chief Science Officer
CTC         Concurrent Technologies Corporation
DFT         dry film thickness
EPA         U.S. Environmental Protection Agency
ETF         Environmental Technology Facility
ETV         Environmental Technology Verification
HAP         hazardous air pollutant
HVLP       high-volume, low-pressure
ID           identification
MEK        methyl ethyl ketone
NDCEE      National Defense Center for Environmental Excellence
NIST        National Institute for Standards and Technology
NRMRL     National Risk Management Research Laboratory
OSHA       Occupational Health and Safety Administration
P2           pollution prevention
PEA         performance evaluation audit
PEL         permissible exposure limit
QA/QC      quality assurance/quality control
RFU         ready-for-use
SAE         Society of Automotive Engineers
TQAPP      Testing and Quality Assurance Project Plan
TSA         technical systems audit
UV          ultraviolet
VOC         volatile organic compound
                                      XI

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This Page Intentionally Left Blank

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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 U.S. 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 former President Clinton'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
P2 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 consists  of
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 Allied
Photochemical (APC)  KrohnZone 7014 UV-curable coating, hereafter referred to  as  the
KrohnZone 7014, which is designed for use in automotive manufacturing.  The test  spray gun
chosen by APC was the ITW Automotive Refmishing GTi high-volume, low-pressure (HVLP)
spray gun.  Where possible, 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 their 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.

       CTC is serving as the verification organization for the ETV CCEP, and their 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    UV-Curable Coating Technology Description

       KrohnZone 7014 is manufactured by APC.  It is an UV-curable coating utilizing free-
radical chemistry.  This product was developed as  a high performance coating for automotive
manufacturing applications. KrohnZone 7014 is reported to be low in VOCs and HAPs.  The
coating is a one-component clearcoat.

1.4    Technology  Testing Process

       The ETV CCEP developed a technology-specific Testing  and Quality Assurance Project
Plan (TQAPP) for KrohnZone 7014, with significant input  from  the vendor4.  After the vendor
concurred with, and the EPA and CTC approved, the TQAPP, the ETV CCEP performed the
verification test.  The Verification Statement, which is produced  as a result of this test, may be
used by APC for marketing  purposes or by end users  of the  KrohnZone 7014 UV-curable
coating.  The Verification Statement for KrohnZone  7014 is included on pages v-viii of this
report. A Data Notebook has been compiled by the ETV CCEP, which includes a more detailed
discussion of the test conditions, the test results,  and the  data analyses.  The Data Notebook is
available from the ETV CCEP upon request.

1.4.1   Technology Selection

       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 P2 potential of each candidate technology
and considered the interests of industry.  UV-curable coatings were found to have a large P2
potential and were being considered by industry in organic finishing replacement activities.

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1.5    Test Objectives and Approach

       The testing was performed according to the Allied  Photochemical KrohnZone 7014
TQAPP.   This project was  designed to verify the performance of KrohnZone 7014 and its
capability to provide the end user with a P2 benefit while maintaining or improving the expected
finish quality of the applied coating.  This project supplies the end users with the best available,
unbiased technical data to assist them in determining whether KrohnZone 7014 meets their
needs.

       The quantitative P2 benefit will  result from an analysis of the  coating's  total volatile
content per ASTM D 5403. For this verification test, a specific combination of test factors were
selected by the ETV CCEP, EPA, APC, 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 P2  benefits and performance of the
technology.

       Representatives of APC,  under supervision of the ETV CCEP,  completed the coating
application and curing.  The  EPA ETV CCEP QA Manager was on site to observe verification
testing. ETV CCEP  staff performed  all processing and laboratory analyses. The total volatile
content was determined to quantify the P2 benefit of the technology.  The following analyses
were performed on the coated test panels to verify the coating's finish quality: dry film thickness
(DFT), visual appearance, gloss, salt spray, humidity resistance, tape adhesion, direct impact,
mandrel bend, MEK (methyl ethyl ketone) rub, and abrasion resistance.

1.6    Performance Summary

       This verification has quantitatively shown that the KrohnZone 7014 UV-curable coating
is capable of providing an environmental benefit and an acceptable coating finish (see Table 1).
The environmental benefit was quantified through the total volatile content of the UV-curable
coating.  The end user should review these data carefully to ascertain the applicability of APC
Krohnzone 7014 for its process.

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                    Table 1. Verification Factors for KrohnZone 7014

Total Volatiles (%)
[Processing + Potential]
Cure Oven Line Speed (cm/s)
Calculated Energy Usage per
Panel (kWh)
Average DFT (mils)
Visual Appearance
Average Gloss
(gloss units, 20° angle)
Average Gloss
(gloss units, 60° angle)
Salt Spray (2000 h)
Scribed (out of 10)
Unscribed (out of 10)
Humidity Resistance
Tape Adhesion
(X-Cut)
Tape Adhesion
(Cross Hatch)
Direct Impact
(J [in.-lb])
Conical Mandrel Bend
MEKRub
(Average DFT = 3.0 mils)
Abrasion Resistance (mg)
Average
2.6
16.7
S.lxKT4
3.1
Standard Deviation
0.9
0.0
N/A
0.2
No major defects. Coating was uniform from
rack to rack and from run to run.
80.8
92.3
6
4
9
5A
5B
3.1 [27]
Adhesion loss or
cracking across
sample width
4 out of 5
92.6
4.4
2.1
N/A
N/A
N/A
N/A
0.1 [1.0]
N/A
N/A
8.8
             N/A - Not applicable
The KrohnZone 7014 requires UV-curing equipment, but the coating can be cured via direct
sunlight, but the process takes  several minutes to several hours,  depending on the UV light
intensity, the wet film thickness and the pigmentation of the coating.  The calculated energy
usage in Table 1 represents only the energy required to cure one 10.2 cm by 15.2 cm panel. This
value does not include the energy required to warm up the lamps or the energy expended by the
length of the lamps that are idle (i.e., not directly over a panel being cured).  The operating costs
of KrohnZone 7014 include the  UV oven, maintenance, and cleanup.  The economic advantage
of KrohnZone 7014  is realized  after consideration  of the  reduced volatile emissions and
reduction in coating wastes due to the ability to recycle the uncured material.

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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  P2 characteristics and
performance of UV-curable coating technologies and to make the results of the verification tests
available to the technology vendor and to prospective technology end users. KrohnZone 7014 is
designed for use in automotive manufacturing applications. For this verification study, the spray
gun used to apply KrohnZone 7014 was a gravity-feed GTi HVLP spray gun, manufactured by
ITW Automotive Refmishing. The spray gun was equipped with a 1.4 mm fluid tip and a #2000
air cap.

       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 KrohnZone 7014 Test

       This  verification test is  based on the ETV CCEP  UV-Curable  Coatings  - Generic
Verification  Protocol,  which  was  reviewed by  the  ETV  CCEP  stakeholders.5    Allied
Photochemical (APC), the manufacturer of KrohnZone 7014, worked with CTC to identify the
optimum performance settings for the coating/gun  combination.  APC had determined the
parameters through tests that their personnel conducted  at their facility in Marysville,  MI.  A
preliminary TQAPP was generated using the vendor supplied information and was submitted to
EPA for review of content.  Following  the initial EPA review  and incorporation of their
comments, the vendor was given the opportunity  to comment on the specifics of the TQAPP.
Any information pertinent to maintaining the quality of the study was incorporated into the
TQAPP.  A final draft of the TQAPP was  reviewed by the vendor  and technical peer reviewers
then approved by the EPA and CTC prior to the start of verification testing.

       Testing was conducted under the direction of ETV CCEP personnel, with representatives
from APC assisting with the coating application and curing phase.  All information gathered
during verification testing was analyzed, reduced, and  documented in this report.  Total  volatile
content and finish quality measurements of KrohnZone 7014 were the primary objectives of this
test.  The data highlight the P2 benefit of the KrohnZone 7014 coating  as well  as its ability  to
provide the required finish quality. A randomly selected portion of at least 10% of the test data
has been quality audited by EPA and the ETV CCEP QA officer  to ensure the validity of the
data.

2.3    UV-Curable Coating Technology

       This  section contains information on KrohnZone 7014,  its  current applications  in
industry, the advantages  and  benefits of  the technology,  and  information  on technology
deployment.

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       KrohnZone 7014 is a UV-curable coating that was developed for automotive applications
and  other  metal  coating  applications that require  only  one-coat  applications,  (such  as
lawnmowers and metal coil).  KrohnZone 7014 is a one-component, ready-to-spray, or ready-
for-use (RFU), coating with a manufacturer recommended shelf life of 1 year.  The coating can
be tailored to a specific viscosity range as designated by the customer. The standard KrohnZone
materials are RFU in the 300 to 1000 cps range, which can be applied by a HVLP spray gun.

       The  KrohnZone  7014  UV-curable  coating  is  reported to  meet  the  following
specifications:

       .   100% UV-curable
       .   contains 100% solids with no VOCs or HAPs
          one-component, RFU coating
       .   shelf life of 1  year with no prolonged exposure to light
       .   theoretical coverage of  1020  ft2/gal (at 65% transfer efficiency and 1 mil thickness)
          curable up to 6 mils with a cure energy greater than 0.35 J/cm2

2.3.1   Applications of the Technology

       KrohnZone 7014 can  be used in many applications,  such as automotive, plastics, and
wood finishing;  however, an automotive  manufacturing application was  the  subject of this
verification test.   Automotive manufacturers  may use the KrohnZone  7014 because it is low
volatile content material capable of being recycled and produces a durable, corrosion resistant
finish.

2.3.2   Advantages of the Technology

       The KrohnZone  7014 UV-curable  coating  has a very  small  percentage of VOCs,
significantly reducing the VOC emissions that typically result from spray painting operations.  It
does not depend  on solvents to transport the coating solids to the  target surface, only to require
volatilization in  later  steps.   The coating can be applied by traditional means  (conventional,
HVLP, brush,  roller, etc).  The cure process requires significantly less space than traditional
thermal curing methods, allowing for multiple coatings to be applied wet  on dry in a shorter
period of time.

2.3.3   Limitations of the Technology

       For some applications,  KrohnZone 7014  may exhibit incomplete curing due to the
complexity of the shape  to be coated. The UV radiation is line-of-sight  and may not be able to
contact all of the coated areas. The UV lamps require  special protection eyewear for operators.
Also, the UV lamps generate ozone,  especially during the lamp warm-up period.  Workers must
be  protected  from  ozone  concentrations  exceeding  Occupational  Health  and   Safety
Administration (OSHA) standards.  The permissible exposure limit (PEL) for an 8-hour, time-
weighted average value of 0.1  ppm.

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       Also, the coating fractured and/or lost adhesion during the conical mandrel bend testing.
The  end user should note that the direct impact test result was 3.1 J (27  in.-lb) and that the
abrasion resistance test result was 92.6 mg.  Also, please note that the DFT of 3 mils was thicker
than planned, which may have impacted the results of some of these analyses.

2.3.4  Technology Deployment and Costs

       KrohnZone  7014  has   many  applications,  with  few limitations  on its  distribution
throughout the various finishing industries.  One area of concern is the efficient  curing of
complex shapes. The coating is cost effective because of its capability to be recycled, the ease of
removing the uncured coating from painted surfaces, and the high solids content of the material.
KrohnZone 7014 is similar in operating costs to standard solvent coatings; however, initial
capital cost of switching from thermal to UV-cure ovens may be significant.

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                                      Section 3
                  Description and Rationale for the Test Design

3.1    Description of Test Site

       The testing of KrohnZone  7014 was conducted at Allied Photochemical's (APC's)
facility in Marysville, MI and at CTC's Environmental Technology Facility (ETF) in Johnstown,
PA.  APC applied the coating to the test panels under the ETV CCEP's supervision.   The spray
booth is a tabletop model approximately 5 ft wide by 2.5 ft deep by 5 ft tall, with a 2.5 ft by 2.5
ft opening.  The back wall  of the booth contained booth filters, and the exhaust was ducted into
the factory because of  the small  amount of VOCs emitted.  Coating  application involved
manually positioning the test panels lying flat in the spray booth. After being coated,  the panels
were placed on a conveyor  that passes the panels under two UV light sources, a medium mercury
vapor lamp and  an iron-doped lamp.  The panels were then packaged and shipped to CTU's
facility for further testing.

3.2    Evaluation of KrohnZone 7014's Performance

       The overall objectives  of the verification  study were to establish the  P2  benefit of
KrohnZone 7014,  and to  determine the  effectiveness of  KrohnZone  7014 in  providing an
acceptable coating  finish.  Finish quality cannot be compromised in most applications, despite
the environmental benefit that may be achieved; therefore, this study has evaluated both of these
factors.  Results from the KrohnZone 7014 verification testing will benefit prospective end users
by enabling them to better determine whether KrohnZone 7014 will provide a P2 benefit while
meeting the finish quality requirements for their application.

3.2.1   Test Operations at Allied PhotoChemical and CTC

       The standard test panels used for verification testing were flat, cold-rolled 22-gauge steel
with a 0.6-cm (1/4-in.) hole in one end that meets Society of Automotive Engineers (SAE) 1008
specifications.  The panel dimensions were 15.2 cm by 10.2 cm (6 in. x 4 in.). The panels were
received treated with a zinc phosphate pretreatment by ACT Laboratories, Inc. Five random test
panels were removed prior  to the test for pretreatment analysis. All panels were manually coated
while lying flat on  a cardboard sheet. The whole sheet was positioned on the UV-curing oven
conveyer to cure the coated test panels.

       The test spray gun chosen by APC was the ITW Automotive Refinishing GTi HVLP gun.
The  spray  gun product  data  sheet is shown in Appendix B of the KrohnZone  7014 Data
Notebook.  Prior to each run, temperature measurements were taken of the coating, panel, and
spray booth. The relative humidity  of the spray booth was also measured.   Samples were taken
at  the  beginning  of each  run for weight percent  solids, density, and volatile  content
measurements  (all  data are provided in the KrohnZone 7014 Data Notebook).  One batch of
coating was used to complete this test. A small container of material was used to fill  the gravity
cup on the spray gun. As the panels were coated, the level of coating in the gravity cup dropped.
The small container was then used to refill the gravity cup before each run.  The cup was refilled
to maintain a consistent fluid flow rate from the gravity cup.

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       Ten panels were coated during each run. Five additional panels from the same batch as
the coated panels were used for zinc phosphate coating weight determination.  Total volatile
content was determined using circular pans and 15.2 cm x 10.2 cm aluminum foil dishes.  Coated
standard test  panels were  also analyzed for DFT, gloss, and visual  appearance in addition to
other performance characteristics analyses.

3.2.2  Test Sampling Operations at CTC's ETF

       Standard test panels were used in this project, and each panel  was labeled with a unique
alphanumeric identifier.  The experimental design used 50 samples for the test (5 runs with 1 set
per run and 10 panels per set).

       The panels were processed under the supervision of CTC personnel. The CTC laboratory
analyst recorded the  date and time of each run and the time at which each measurement was
taken.  Once coated  and cured, the panels were stacked, each  being separated by a layer of
packing material, and transported to the CTC laboratory by ETV CCEP personnel.

3.2.3  Sample Handling and Quality Assurance/Quality Control Procedures

       Prior to performing the required analyses, the laboratory analyst logged panels, 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 (ambient room temperature and humidity), and created a
work order to initiate testing.

       The temperature of the coating, as applied, was measured during the test by ETV CCEP
personnel.  APC  provided the  ETV CCEP  with  a sample of the coating batch, which was
transported to Johnstown,  PA, for analysis.   The viscosity, density, VOC content, and percent
solids  analyses were completed by ETV CCEP personnel in the ETF laboratory.  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.

       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.
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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. 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.

3.3.2   Data Reduction and Verification

       The primary analyst(s) assembled a preliminary data package.  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 ETV CCEP laboratory
leader, who then reviewed all final results for adequacy to project QA objectives. After the EPA
reviewed the results and conclusions from  the  ETV CCEP 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 will be
disseminated only after agreement by the vendor.
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                                       Section 4
                               Results and Discussion

       This section presents an overview of the verification test results, including an analysis of
environmental benefits of KrohnZone 7014, a summary of panel finish quality, and a summary
of data quality.  Data generated during this test are being evaluated in order to establish the
environmental benefit and the finish quality characteristics of the product. An explanation of the
manner in which the data were gathered is provided. Subsequently, the 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 KrohnZone 7014 Data Notebook.

4.1    Potential Environmental Benefits and Vendor Claims

       The primary  purpose  of this  test  is to verify that KrohnZone  7014  is a  low  volatile
content coating that offers a finish quality suitable for automotive manufacturing applications.

4.2    Selection of Test Methods and Parameters Monitored

       CTC, the ETV CCEP partner organization, performed the laboratory testing required for
this verification test.   The  ETV CCEP selected  test procedures, process  conditions,  and
parameters to be monitored based on their correlation to, or impact on, volatile content or finish
quality.

4.2.1   Process Conditions Monitored

       The conditions listed below were  documented to ensure that there were no significant
fluctuations in conditions during the verification test.  A more  detailed discussion of the data is
presented in Section 3 of the KrohnZone 7014 Data Notebook.

       •  Spray booth relative humidity ranged from 16.7% to 18.1%.
       •  Cure area relative humidity ranged from 16.5% to 19.0%.
       •  Spray booth temperature ranged from 19.3 to 21.1 °C.
       •  Cure area temperature ranged from 20.4 to 21.2 °C.
       •  Panel temperature ranged from  20.1 to 20.8 °C.

4.2.2   Operational Parameters

       The conditions listed below were  documented to ensure that there were no significant
fluctuations in conditions during the verification test.  A more  detailed discussion of the data is
presented in Section 3 of the KrohnZone 7014 Data Notebook.
                                           13

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       •   Zinc phosphate weight ranged from 2.3 to 3.0 g/m2.
       •   Coating density was 1031 g/L.
       •   Weight percent solids ranged from 25.01% to 25.16%.
       •   Coating temperature ranged from 20.0 to 21.0 °C.
       •   Coating viscosity ranged from 23.9 to 24.1 seconds using a #4 Ford cup.

4.2.3   Parameters/Conditions Monitored

       Other parameters and conditions were monitored to ensure that they remained relatively
constant throughout the verification test.   Constancy was desired in order to reduce the number
of factors that could significantly influence total  volatile content calculations and the evaluation
of finish quality.  A more detailed discussion of these data is presented in Section 3  of the
KrohnZone 7014 Data Notebook.

4.3    Overall Performance Evaluation of KrohnZone 7014

       The verification factors for KrohnZone 7014 are listed in Table 1  of this report. The test
results indicate that the KrohnZone 7014 UV-curable coating provided an environmental benefit
and maintained the required finish quality of the applied coating.

4.3.1   Assessment of Laboratory Data Quality

       The KrohnZone 7014 data results were subjected to an internal data quality audit by the
ETV CCEP QA officer.  The information gathered was considered to be statistically valid and
significant  such that the advantages and limitations of KrohnZone  7014,  per  these test
conditions, could be identified to 95% confidence.

4.4    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 KrohnZone 7014 Data Notebook.  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 KrohnZone 7014 Data Notebook.

4.4.1   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
                                           14

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determined to be within the expected values listed in the TQAPP. Accuracy results are located
in Table 26 of the KrohnZone 7014 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 Tables 28 to 32 of the
KrohnZone 7014 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. Evaluating precision  and accuracy data during analysis
ensures completeness. All  laboratory results for finish quality were 100% complete. All results
were reviewed and considered usable for statistical analysis.  Completeness results are shown in
Table 27 of the KrohnZone 7014 Data Notebook.

4.4.2   Audits

       The EPA ETV CCEP  QA manager conducted a technical systems audit (TSA) and  a
performance evaluation audit (PEA) of the KrohnZone 7014 verification test.  Also, prior to the
certification of the data, the ETV CCEP QA manager audited a portion of the  data generated
during the KrohnZone 7014 test.

       The TSAs verified that CTU's personnel were adequately trained and prepared to perform
their assigned duties and that routine procedures were adequately documented. The EPA  ETV
CCEP  QA manager  examined copies of  process conditions data  sheets  during the coating
application process.

       The EPA ETV CCEP QA  manager  audit found that the KrohnZone  7014 test was
conducted in a manner that provides valid data to support this Verification Statement/Report.
Several deviations from the original TQAPP were made and are discussed in Section 2 of the
KrohnZone 7014 Data Notebook.
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                                       Section 5
                                   Vendor Forum

[Allied PhotoChemical has been offered the opportunity to comment on the findings of this
report.  Its 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.]

       The Manufacturer's Suggested Retail Price of the KrohnZone 7014 UV-curable coating
at the time of this verification test was $100/gal. Significant volume discounts were available.

       The KZ 7014 UV-curable coating has been tested in an industrial  application. A paint
line for real manufacturing is being developed for future production.  Allied Photochemical
cannot disclose the name of the company at this time.

      Utilizing Allied's   100%  UV-curable paint system  has  allowed  an automotive  parts
manufacturer to paint parts with Allied's UV paint at a much faster speed  and lower costs than
the current standard water-based paint.

      Allied's paint system has reduced the size of the paint line and capital investment by
65%.  This includes, but is not limited to, less square footage for the actual paint line because of
some  of the processing steps that could be omitted and still produce quality parts.  For example
with the water-based coating currently in use, the parts must be sand blasted to take of the slag to
get a  good, final finish.   Allied's paint covered the roughness of the slag.   The phosphating
process has been deleted.  Some of the washing steps are deleted.  The energy costs of the water-
based paint line are $2,000,000 per month for gas and electricity.  The estimated combined costs
are to be less  than $100,000 per month  with  the UV process,  a huge energy savings.  This
particular company had to run a 9-inch gas line for 2  miles to have enough energy to run their
current single  water based line.  The water-based  line  had an initial capital investment of
approximately  $10,000,000. The UV line using Allied's paint is estimated to have an initial cost
of less than $1,000,000.
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                                     Section 6
                                    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.

4.  Environmental Technology  Verification  Coatings and  Coating Equipment Program  (ETV
   CCEP):  Allied Photochemical KrohnZone™ 7014 - Testing and Quality Assurance Project
   Plan     (TQAPP),    Revision    #0,    March    3,    2003,    http://www.epa.gov/
   etv/pdfs/testplan/06_tp_allied.pdf.

5.  Environmental Technology  Verification  Coatings and  Coating Equipment Program  (ETV
   CCEP):  UV Curable Coatings - Generic Testing and  Quality Assurance Protocol (Draft),
   March 24, 1998, http://www.epa.gov/etv/pdfs/vp/06_vp_curable.pdf (Finalized 09/03)
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