Standards of Performance for New Stationary Sources: Automobile and Light-Duty Truck Surface Coating Operations

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 60

[AD-FRL-5087-5]

RIN 2060-AF14

Standards of Performance for New Stationary Sources: Automobile

and Light-Duty Truck Surface Coating Operations

AGENCY: Environmental Protection Agency (EPA).

ACTION: Final rule.

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SUMMARY: On July 29, 1982, a revision to the new source performance

standard (NSPS) for automobile and light-duty truck prime coat

operations was proposed. Analysis of data submitted after this proposal

showed that the best demonstrated prime coating system and prime coat

materials could not consistently meet the proposed revised standard.

This revised final NSPS is consistent with the performance of the best

demonstrated prime coating system and prime coat materials. This

revision of the standard does not reflect a change in the basis of the

standard, but reflects a better understanding of the performance of the

prime coating system and prime coat materials upon which the standard

was originally based. The intended effect of this NSPS is to require

all new, modified, and reconstructed prime coat operations at

automobile and light-duty truck assembly plants to use the best

demonstrated system of continuous emission reduction considering costs,

nonair quality health, and environmental and energy impacts.

EFFECTIVE DATE: October 11, 1994.

Under section 307(b)(1) of the Clean Air Act (Act), judicial review

of this revision of a NSPS is available only by filing a petition for

review in the U.S. Court of Appeals for the District of Columbia

Circuit within 60 days of today's publication of this rule. Under

section 307(b)(2) of the ACT, the requirements that are the subject of

today's rule may not be challenged later in civil or criminal

proceedings to enforce these requirements.

ADDRESSES: Docket. Docket number A-82-10, containing supporting

information used in developing the revised standard, is available for

public inspection and copying between 9 a.m. and 4 p.m., Monday through

Friday, at EPA's Central Docket Section, West Tower Lobby, Gallery 1,

Waterside Mall, 401 M Street, SW., Washington, DC 20460. A reasonable

fee may be charged for copying.

FOR FURTHER INFORMATION CONTACT: Mr. David Salman, Chemicals and

Petroleum Branch, Emission Standards and Engineering Division (MD-13),

U.S. Environmental Protection Agency, Research Triangle Park, North

Carolina 27711, telephone (919) 541-0859.

SUPPLEMENTARY INFORMATION:

The Revised Standard

The revised standard limits emissions from electrodeposition (EDP)

prime coat operations as follows:

1. For RT greater than or equal to 0.160, the emission limit

is 0.17 kg VOC per liter of applied coating solids.

2. For RT greater than or equal to 0.040 and less than 0.160,

the emission limit is 0.17 x 350 (0.l60-RT) kg of VOC

per liter of applied coating solids.

3. For RT less than 0.040, no emission limit applies. RT

is the solids turnover ratio. This is the ratio of the volume of

coating solids added to an EDP system during a calendar month divided

by the total volume capacity of the EDP system.

Prime coat systems other than EDP systems would be required to

comply with a single numerical emission limit of 0.17 kg VOC per liter

of applied coating solids.

This revision is not a relaxation of the original prime coat

standard since it does not reflect a change in the technological basis

upon which the original standard was based. It does reflect a better

understanding of the operation and performance of this technology based

on an analysis of additional data which were not available at the time

the standard was originally developed. Consequently, this revision does

not result in any environmental, energy, cost, or economic impacts.

Information collection requirements contained in this regulation

(60.393) have been approved by the Office of Management and Budget

(OMB) under the provisions of the Paperwork Reduction Act of 1980

U.S.C. 3501 et seq. and have been assigned OMB control number 2060-

0034.

I. Background

On October 5, 1979, pursuant to Section 111 of the Act, standards

of performance to limit emissions of volatile organic compounds (VOC)

from new, modified, and reconstructed automobile and light-duty truck

surface coating operations were proposed (44 FR 57792). Final standards

limiting VOC emissions from prime coat operations to 0.16 kg VOC per

liter of applied coating solids were promulgated in the Federal

Register on December 24, 1980 (45 FR 85410).

On February 19, 1981, General Motors Corporation (GM) petitioned

the Administrator to convene a proceeding under section 307(d)(7)(B) of

the Act to reconsider the prime coat standard. The basis for the

petition was new data, which had become available following

promulgation of the standard, on the performance of the technology

which served as the basis for this standard. The basis for the standard

promulgated on December 24, 1980, was cathodic EDP prime coat systems

which use low-VOC content waterborne materials. An EDP system consists

of a large tank filled with coating material. Metal parts are submerged

in the tank and a voltage is applied to help deposit the coating solids

onto the parts. The low-VOC content cathodic EDP technology was quite

new at the time of promulgation; and data on only one system, which had

operated for less than 1 year, were available. Following receipt of

GM's petition for reconsideration, data and information on the

performance of this technology were solicited from GM, Ford Motor

Company (FMC), American Motors Corporation (AMC), Volkswagen

Corporation (VW), Chrysler Corporation, Nissan, Honda, Inmont, and

Pittsburgh Plate Glass Corporation (PPG). Analysis of the additional

data received confirmed that the promulgated standard did not

accurately reflect the performance of cathodic EDP prime coat systems.

Consequently, a revised standard of 0.17 kg VOC per liter of applied

coating solids (6-month average using the best 6 months out of a 7-

month period) was proposed on July 29, 1982.

A public hearing was not requested. The official public comment

period closed on September 27, 1982.

II. Comments and Changes to the Standard

Six comments were received on the proposed revised standard. Three

were from automobile manufacturers, one from a coating manufacturer,

one from an industry trade association, and one from a State regional

control agency. A significant amount of additional data on the

performance of EDP prime coating systems was included with these

comments. These data covered the performance of 37 cathodic EDP prime

coating systems using 10 different low-VOC content prime coating

materials over approximately 3,000 weeks of operation.

Several commenters stated that the additional data included with

their comments demonstrated that cathodic EDP prime coating systems

could not continuously meet the proposed revised emission limit. In

addition, several commenters suggested that flow control additive (FCA)

added to the EDP prime coat system to maintain good flow

characteristics during periods when the system is not coating vehicles

should be excluded from the emission calculations. The commenters felt

that the addition of FCA during production downtime was not

representative of normal operation and, if not accommodated in some

manner, would cause unavoidable violations of the emission limit. The

commenters argued that since the standard is expressed in terms of kg

of VOC per liter of applied coating solids, at times of near-zero use

(i.e., essentially no solids applied), even small evaporative losses

result in the standard being exceeded by a wide margin.

All of the data and information that were available, including the

new data and information received during the comment period, were

reanalyzed. The cathodic EDP prime coat materials used by FMC, GM, AMC,

and VW were very similar. The sole suppliers were PPG, Inmont

Corporation, and FMC. The coating materials consist of three

components: resin, pigment, and FCA. Table 1 presents the solids,

solvent, and water composition of these three components for a

representative coating.

Table 1.--Representative Coating Material Formulation

[Percent by volume]

------------------------------------------------------------------------

Solids Water

Formulation content VOC content content

------------------------------------------------------------------------

Resin............................ 32.4 2.9 64.7

Pigment.......................... 33.0 13.3 53.7

Flow control additive............ 4.3 95.4 0.3

------------------------------------------------------------------------

Each of these components may be added separately to the EDP prime

coating tank. The solvent contained in these components leaves the EDP

tank either by transport on the surface of the automobile body or by

evaporation from the liquid surface of the tank. Upon leaving the EDP

tank, the solvent clinging to the automobile body evaporates. All of

the solvent added to the EDP tank is ultimately released to the

atmosphere. The VOC emissions released to the atmosphere per unit of

solids applied to the automobile body may, therefore, be determined

directly by measuring the amount of VOC and solids added to the EDP

tank because additions are made to the tank to keep the coating

material in a near steady-state condition.

The ratio of resin to pigment added to the EDP tank is recommended

by the coating manufacturers and can vary with RT. The FCA is

added as needed to provide the desired coating properties and finish

quality and to maintain the coating material in a near steady-state

condition. Because of the high-solvent content of the FCA (95 percent

by volume) and the variable ratio (compared to resin and pigment) with

which it is added to the EDP system, this component is of overriding

importance in determining emissions from the EDP system.

All of the data were verified as being representative of good

operation. Two potential sources of variation were differences in the

operation and maintenance of EDP tanks from plant to plant and

differences among prime coat materials. Variations in performance due

to these two factors were analyzed and were not found to be

statistically significant. Based on this analysis, the coating

material, coating equipment, and operation and maintenance for all of

the data obtained were determined to represent best demonstrated

technology. Therefore, all of the data were used in establishing the

revised emission limit.

All companies submitting data were able to provide data on a weekly

basis. Averaging periods of 4 weeks, 8 weeks. 12 weeks, 24 weeks, and

the best 24 out of 28 weeks (6 out of 7 months) were employed to

examine the performance of EDP systems including and excluding periods

when the paint line was shut down, i.e., downtime. This analysis

revealed that the exclusion of periods of downtime slightly reduced the

variability in VOC emissions. Even with downtime excluded, however, the

proposed revised standard was not met consistently.

In addition to periods of downtime, periods of low production also

appeared to adversely affect performance. The relative usage of an EDP

system over any time period can be measured by either comparing the

amount of new coating material or new coating solids added to the total

capacity of the system. The volume of coating solids added gives a

better indication of usage because it is a measure of production. i.e.,

the number of vehicles coated. This is because, regardless of the

coating material used, the same volume of coating solids must be

deposited to coat a particular part to a specified film thickness. The

other major constituents of the EDP, coating material, VOC and water,

do not become part of the final dry coating and can evaporate from the

tank during periods of downtime. Therefore, using the volume of new

coating material added would not give a consistent measure of usage for

systems that use coating materials which contain varying amounts of

solids, VOC, and water.

The total volume of coating solids added to the EDP tank divided by

the total volume of the entire EDP system was found to correlate well

with VOC emissions. This ratio has been termed the solids turnover

ratio (RT). The relationship between RT and VOC emissions for

4-week periods is shown in Table 2.

As seen in Table 2, VOC emissions, in terms of kilograms per liter

of solids deposited, decrease as RT increases. At RT's above

0.160, emissions are below 0.17 kg of VOC per liter of applied coating

solids. Sources which operate at RT's of less than 0.160, however,

cannot consistently meet an emission limit of 0.17 kg of VOC per liter

of applied coating solids. Further analysis of the data used to

generate Table 2 indicates that for RT between 0.040 and 0.160,

VOC emissions are related to RT by the following equation: 0.17

x 350(0.l60-RT) kg of VOC per liter of applied coating

solids.

Table 2.--Solids Turnover Ratio Versus EDP Prime Coat System Performance

For 4-Week Periods

------------------------------------------------------------------------

Cumulative

Solids turnover ratio (RT) VOC Number of percent of

emissions1 observations data

------------------------------------------------------------------------

RTRTRTRTRTRTRTRT................ 0.17 70 100

Totals...................... .......... 2,602 ..........

------------------------------------------------------------------------

1VOC emission level in kilograms of VOC per liter of coating solids

deposited which was exceeded by no more than 1 percent of the data at

each turnover level.

The RT's of less than 0.040 represent periods of zero or

abnormally low production. These low-operating levels occurred more

frequently than normal during the period in which the data in Table 2

were generated because of the depressed operating level of the industry

at that time. Operation at RT's below 0.040 results in widely

varying VOC emissions in terms of kg VOC per liter of applied coating

solids. Under these low-operating conditions, emissions expressed in

units of the standard range from 0.17 kg of VOC per liter of applied

coating solids to over 19 kg of VOC per liter of applied coating

solids. Since operation with RT's below 0.040 result in widely

varying emissions even when EDP prime coat systems are operated and

maintained properly, it is infeasible to establish a standard for these

low-operating levels that distinguishes between proper and improper

operation regarding emissions of VOC. In addition, since the number of

vehicles produced during 4-week periods with RT's less than 0.040

is small, the total VOC emissions from the EDP tank during such periods

of operation are only a fraction of the emissions emitted when the EDP

tank is operating properly at full production. Consequently, the

revised standard includes no emission limit for operation at RT's

of 0.040 or less.

The emission limits discussed above, therefore, were selected for

the final revised standard. If there is little or no production, almost

no solids would be added to the EDP system, the RT would always be

below 0.040, and the owner would not have to comply with an emission

limit. Prime coat systems other than EDP would be required to comply

with a single numerical emission limit of 0.17 kg of VOC per liter of

applied coating solids.

One commenter suggested that the revised prime coat emission limit

be based on the performance of the single EDP system with the best

observed performance. As mentioned earlier, however, the statistical

analysis performed on 37 EDP prime coating systems showed that there

was no statistically significant difference in the observed performance

of any of the EDP systems. Consequently, all of the data on all of the

EDP systems were used to develop the final revised emission limits.

One commenter suggested that the units of the prime coat standard

be changed from kilograms of VOC per liter of applied coating solids to

kilograms of VOC per liter of coating minus water. The commenter

indicated that this change would make the prime coat standard units

consistent with most State emission limits for existing facilities.

Such a change would have the effect of deleting the requirement that a

transfer efficiency be used in determining compliance with the emission

limit. For an EDP system, the system upon which the standard is based,

the transfer efficiency that is allowed to be used for determining

compliance is 100 percent. Therefore, for an EDP system, such a change

would have little effect on the allowable or actual emissions. However,

if prime coat application systems other than EDP which have transfer

efficiencies of less than 100 percent are used, then the suggested

changes in the units of the standard could result in allowing increased

actual VOC emissions while still apparently meeting the emission limit.

Since there is a possibility that systems other than EDP will be used

in the future and a format of kg of VOC per liter of applied coating

solids is most consistent with the use of the solids turnover ratio,

the units of the standard were not changed.

The Administrator certifies that a regulatory flexibility analysis

under 5 U.S.C. 605(b), is not required for this rulemaking because the

rulemaking would not have a significant impact on a substantial number

of small entities. The rulemaking would not impose any new

requirements; therefore, no additional costs would be imposed.

Under Executive Order 12866 (58 FR 51735 (October 4, 1993)), the

Agency must determine whether the regulatory action is ``significant''

and therefore subject to OMB review and the requirements of the

Executive Order. The Order defines ``significant regulatory action'' as

one that is likely to result in a rule that may:

1. Have an annual effect on the economy of $100 million or more or

adversely affect in a material way the economy, a sector of the

economy, productivity, competition, jobs, the environment, public

health or safety, or State, local, or tribal governments or

communities;

2. Create a serious inconsistency or otherwise interfere with an

action taken or planned by another agency;

3. Materially alter the budgetary impact of entitlements, grants,

user fees, or loan programs or the rights and obligations or recipients

thereof; or

4. Raise novel legal or policy issues arising out of legal

mandates, the president's priorities, or the principles set forth in

the Executive Order.

Pursuant to the terms of Executive Order 12866, it has been

determined that this rule is a ``significant regulatory action'' within

the meaning of the Executive Order. For this reason, this action was

submitted to OMB for review. Changes made in response to OMB

suggestions or recommendations will be documented in the public record.

Information collection requirements contained in this regulation

(60.393) have been approved by OMB under the provisions of the

Paperwork Reduction Act of 1980, 44 U.S.C. 3501 et seq. and have been

assigned OMB control number 2060-0034.

List of Subjects in 40 CFR Part 60

Environmental protection, Air pollution control, Motor vehicles,

Volatile organic compounds.

Dated: September 30, 1994.

Carol M. Browner,

Administrator.

40 CFR part 60 is amended as follows:

PART 60--STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES

1. The authority citation for part 60 continues to read as follows:

Authority: Sections 101, 111, 114, 116, and 301 of the Clean Air

Act as amended (42 U.S.C. 7401, 7411, 7414, 7416, 7601).

2. Section 60.391 is amended by adding definitions in alphabetical

order to paragraphs (a) and (b) to read as follows:

Sec. 60.391 Definitions.

* * * * *

(a) * * *

Solids Turnover Ratio (RT) means the ratio of total volume of

coating solids that is added to the EDP system in a calendar month

divided by the total volume design capacity of the EDP system.

* * * * *

Volume Design Capacity of EDP System (LE) means the total liquid

volume that is contained in the EDP system (tank, pumps, recirculating

lines, filters, etc.) at its designed liquid operating level.

* * * * *

(b) * * *

LE = the total volume of the EDP system (liters),

* * * * *

3. Section 60.392 is amended by revising paragraph (a) to read as

follows:

Sec. 60.392 Standards for volatile organic compounds.

* * * * *

(a) Prime Coat Operation

(1) For each EDP prime coat operation:

(i) 0.17 kilogram of VOC per liter of applied coating solids when

RT is 0.16 or greater.

(ii) 0.17 x 350 (0.160-RT) kg of VOC per liter of applied

coating solids when RT is greater than or equal to 0.040 and less

than 0.160.

(iii) When RT is less than 0.040, there is no emission limit.

(2) For each nonelectrodeposition prime coat operation: 0.17

kilogram of VOC per liter of applied coating solids.

* * * * *

4. Section 60.393 is amended by adding paragraph (c)(l)(i)(E) to

read as follows:

Sec. 60.393 Performance test and compliance provisions.

* * * * *

(c) * * *

(1) * * *

(i) * * *

(E) For each EDP prime coat operation, calculate the turnover ratio

(RT) by the following equation:

TR11OC94.000

Then calculate or select the appropriate limit according to

Sec. 60.392(a).

* * * * *

[FR Doc. 94-25066 Filed 10-7-94; 8:45 am]

BILLING CODE 6560-50-P