United States Environmental Protection Agency Office of Air Quality Planning and Standards Washington, DC 20460 EPA-340/1 -86-01 6 July 1986 Air pDQ*7 4 74 o~7 a &EPA A Guideline for Surface Coating Calculations REPRODUCED BY U.S. DEPARTMENT OF COMMERCE NATIONAL TECHNICAL INFORMATION SERVICE SPRINGFIELD, VA 22161 &EPA . . * . R|^H . III H B TECHNICAL REPORT DATA (Please reed Inunctions ct the reverse before complerint) 1 REPORT NO. 3. EPA 340/1-86-016 *-" , *wr-TTre7 4«s ■ 4 TITLE ANO SUBTITLE A Guideline for Surface Coating Calculations 5. REPORT DATE February 1985 6. PERFORMING ORGANIZATION COOE 7 AUTHOBIS) PEI Associates, Inc. 8 . PERFORMING ORGANIZATION REPORT NO. I 9 PERFORMING ORGANIZATION NAME ANO AOORESS PEI Associates, Inc. 1006 North Bowen Road Suite 201 Arlington, Texas 76012 10. PROGRAM ELEMENT NO. ii. contbact/grant no. 68-02-3963 13. SPONSORING AGENCY NAME ANO AOORESS U.S. Environmental Protection Agency Stationary Source Compliance Division 401 M Street, S.W. Washington, D.C. 20460 13. TYPE OF REPORT ANO PERIOD COVERED | 14. SPONSORING AGENCY COOE 15. SuF'ltMENTARY NOTES >6. ABSTRACT The calculation of volatile organic compound emissions from surface coat¬ ing operations to determine compliance is often a complicated task, sometimes creating confusion with compliance authorities and sources alike. In an attempt to minimize this confusion, EPA (OAQPS) has periodically issued guidance in this area, generally in the form of memoranda to the EPA Regional Offices. The most recent document is entitled "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink and Other Coatings," published December 1984, EPA 450/3-84-019. "A Guideline for Surface Coating Calculations" takes the above guidance process one step further for surface coating operations. Guidance is provided on how to compute existing and allowed emissions based on the above document as well as previously issued Control Technique Guidelines for the individual cate¬ gories. Example calculations are included for basic emission problems, com¬ pliance determinations, equivalency determinations, application of transfer efficiency, and calculations involving complex multiproduct plants. The approp¬ riate data sheets, a list of various equations and notations, and graphs and tables useful in making the above calculations are also included. 17. *E V WORDS AND DOCUMENT ANALYSIS •» DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATi h ifld.ClOup Air Pollution Surface Coating V0C Data Sheets Calculations Compliance Determination Control Strategy Evaluation Air Pollution Control Organic Chemicals Coating Operations L>| S I R< bU 7 'ON ST A I E MEN t Release Uniimited 19 SICuBil* CL*!»S i/AiiW tpo'il Unclassified 2 1 NO C* * A(jt S 85 30 SECURITY Class trhnpmt*) Unclassified 33 PRICE C’A r«'m 2 2 701 (9-13) I It ■ r f innrflmr . m - . : ' . ,15 i- . > i f- J ' ; EPA-340/1 -86-016 A Guide For Surface Coating Calculations Prepared by PEI Associates, Inc. 11499 Chester Road Post Office Box 46100 Cincinnati, Ohio 45246-0100 Contract No. 68-02-3963 Work Assignment No. 6 Prepared for Project Officer: John Busik Work Assignment Manager: Dwight Hlustick U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air Quality Planning and Standards Stationary Source Compliance Division Washington, DC 20460 July 1986 DISCLAIMER This report was prepared for the U.S. Environmental Protection Agency by PEI Associates, Inc., Cincinnati, Ohio, under Contract No. 68-02-3767, Work Assignment No. 67. The contents of this report are reproduced herein as re¬ ceived from the Contractor. The opinions, findings, and conclusions expressed are those of the author and not necessarily those of the U.S. Environmental Protection Agency. ii CONTENTS Page Figures iv Tables iv Acknowledgment v Abstract vi 1. Introduction 1 1.1 Background 1 1.2 Description of VOC calculations 2 1.3 Negligibly photochemically reactive materials 3 2. Basic Calculations 5 2.1 Determining the mass of VOC emitted per volume of solids 5 2.2 Determining the mass of VOC emitted per volume of coating 6 less water 3. Transfer Efficiency 9 3.1 Determining the mass of VOC emitted per volume of solids 9 applied 3.2 Calculating average transfer efficiency 10 4. Compliance Determinations 12 4.1 Calculating coating compliance with a standard 12 4.2 Calculating compliance when add-on controls are used 13 5. Equivalency Determinations 16 5.1 Calculating allowable hourly emissions for a solvent-borne 16 coating 5.2 Equivalency calculations for a can coating operation 17 (continued) iii CONTENTS (continued) Page 6. Complex Calculations 23 6.1 Compliance determination for auto plant primer-surfacer 23 (guide coat) operation 6.2 Determining compliance for a large appliance coating line 26 using several types of spray equipment 7. Graphs and Tables Useful in Approximating and Double-Checking 30 Surface Coating Calculations References 41 Appendices A B C Glossary of Air Pollution Control of Industrial Coating A-l Operations" ] EPA-450/3-83-013R. December 1983. pp. 26-29. Procedures for Certifying Quantity of Volatile Organic B-l Compounds Emitted by Paint, Ink, and Other Coatings. EPA-450/3-84-019. December 1984. Reference Method 24. C-l iv FIGURES Number Page 1 Graph For Determining Equivalent Solids/VOC (Solvent) 31 Contents of Waterborne and Organic-Borne Coatings 2 Graph For Determining Pounds of VOC (Solvent) Per Gallon 32 Of Coating Solids 3 Smaller-Scale Graph For Determining Pounds of VOC (Solvent) 33 Per Gallon of Coating Solids TABLES Number Page 1 Example Calculation of Average TE When Several Different 11 Coating Application Methods Are Used 2 Suggested Format For Determining Compliance for Can Coating 21 Operations 3 Large Appliance Multitransfer Efficiency Calculation 27 4 CTG Volume Percent Solids Equivalency Data 34 5 CTG Equivalency Data 36 6 Equivalent Solids Deposited Limits 39 7 Metric Conversion Factors 40 v ACKNOWLEDGMENT This guideline was prepared for the U.S. Environmental Protection Agency by PEI Associates, Inc. under Contract No. 68-02-3963. It is primarily a re¬ vision of a preliminary draft manual with the same title, dated January 1982, and prepared by Messrs. William Polglase, Brock Nicholson, and Tom Williams of the Control Programs Development Division (CPDD), U. S. Environmental Protec¬ tion Agency, Research Triangle Park, North Carolina. PEI especially appreci¬ ates the support and input given by Mr. Dwight Hlustick, the Work Assignment Manager, during the preparation of this guideline. The review and comments provided by Messrs. Robert Blaszczak, Douglas Cook, Richard Dalton, Paul Kahn, Laxmi Kesari, William Polglase, Michael Pucci, David Salman, Dennis San- tella, and James Topsale are also gratefully acknowledged. ABSTRACT The calculation of volatile organic compound emissions from surface coat¬ ing operations to determine compliance is often a complicated task, sometimes creating confusion with compliance authorities and sources alike. In an at¬ tempt to minimize this confusion, EPA (OAQPS) has periodically issued guidance in this area, generally in the form of memoranda to the EPA Regional Offices. EPA guiGance for submitting data on surface coatings and performing basic cal¬ culations is contained in the document entitled "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink and Other Coat¬ ings," EPA 450/3-84-019, published in December 1984. "A Guiaeline for Surface Coating Calculations" takes the above guidance process one step further. Example calculations are included for basic emis¬ sion problems, compliance determinations, equivalency determinations, appli¬ cation of transfer efficiency, and calculations involving complex multiproduct plants. Graphs ana tables useful in approximating and double-checking these calculations are also included. vli ■ . . ' ■ ' ’ SECTION 1 INTRODUCTION i.l BACKGROUND Surface coating entails the deposition of a solid film on a surface through the application of a coating material such as paint, lacquer, or var¬ nish. Surface coating operations are significant volatile organic compound (VOC) emission sources. Most coatings contain VOCs which evaporate during the coating application and curing processes, rather than becoming part of the dry fi lm. The U.S. Environmental Protection Agency (EPA) has issued Control Tech¬ niques Guidelines (CTGs) for many surface coating operations, including cans, metal coils, paper, fabric, automobiles, light-duty trucks, metal furniture, large appliances, magnet wire, miscellaneous metal parts and products, graphic arts, and flatwood paneling. The emission limits recommended in these guide¬ lines have been adopted by many state and local agencies. The EPA has also issued new source performance standards (NSPS) for many surface coating opera¬ tions, including automobile, light-duty trucks, beverage cans, metal coils, large appliances, metal furniture, pressure sensitive tapes and labels, vinyl printing and topcoating, and publication rotogravure printing. To comply with these regulations, a surface coating operator might elect to change to low VOC content coatings, to use add-on controls such as inciner¬ ation or carbon adsorption, or to improve transfer efficiency. In cases where compliance is achieved by a change in coating alone, VOC emissions can be cal¬ culated from the VOC content of the coating as applied to the substrate. When add-on controls or transfer efficiency improvements are used, more complex calculations can be performed to determine the effectiveness of the control strategy. It is more convenient (and frequently more reliable) to establish VOC compliance or non-comp!iarice through these calculations than it is to measure total VOC emissions directly. 1 The emission limits for existing sources recommended in the CTGs and adopted by many state and local agencies are expressed in terms of pounds of VOC per gallon of coating less water. These units are directly useful only for cases where compliance is achieved with low VOC content coatings alone. When add-on controls or transfer efficiency improvements are used, compliance calculations must be done on an equivalent solids basis. The reasons for this are explained graphically in Glossary of Air Pollution Control of Industrial Coating Operations , EPA-450/3-83-013R, December 1983. Pages 26-29 of this document are located in Appendix A. The emission limits in most surface coat¬ ing NSPSs are expressed in terms of pounds of VOC per gallon of coating solids applied. The reader should review this concept in Appendix A before contin¬ uing in this guideline manual. This calculation guide assumes that the solids used or applied in a specific process remain constant for a given example (solids equivalency). 1.2 DESCRIPTION OF VOC CALCULATIONS This document presents sample calculations typical of those used to determine compliance or to evaluate control strategies. These step-by-step calculations are accompanied by explanations that are useful to persons unfamiliar with surface coating operations. Basic calculations are included along with calculations to determine compliance and equivalency (necessary for evaluating bubbles, offsets, netting, etc.). Transfer efficiency problems requiring a series of calculations are included. The basis for most of the sample calculations is the information and procedures discussed in Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings , EPA-450/3-84-019, Decem¬ ber 1984, which is reprinted as Appendix B of this report and referred to as the "VOC Data Sheets". The first VOC Data Sheet provides information on the VOCs present in a coating when it is sold by the manufacturer to the coater. This is referred to as the VOC content of the coating "as supplied by the coating manufacturer to the user." The second VOC Data Sheet provides infor¬ mation on the VOCs present in the coating as it is used by the coater and in¬ cludes the effect of dilution solvent added before application. This is re- ferrea to as the VOC content "as applied to the substrate by the user." For 2 dip or flow coating operations, this should include any make-up solvent which is added to a coating to replace evaporated solvent and therefore maintain a specific viscosity of the coating being applied. The calculations in this document assume that the inspector has obtained the coating data from the VOC Data Sheets. However, it is up to the inspector to verify this data. EPA Reference Method 24 or individual ASTM methods are the final judge in deter¬ mining compliance. Appendix C contains a copy of Reference Method 24. Some confusion may exist regarding the meanings and proper uses of terms. As defined in Appendix B, the term "as applied" means the condition of a coat¬ ing after dilution by the user just prior to application to the substrate. However, the term "solids applied" means the amount coating solids that actually adheres to the object being coated, not the amount of solids leaving the applicator. In contrast, the term "solids used" refers to the total amount of solids used in an application, not the amount of solids that act¬ ually adheres to substrate. Care should be taken when using these terms to avoid confusion. 1.3 NEGLIGIBLY PHOTOCHEMICALLY REACTIVE MATERIALS A volatile organic compound is defined in 40 CFR Subpart A, General Pro¬ visions, §60.2, as any organic compound which participates in atmospheric pho¬ tochemical reactions; or which is measured by a reference method, an equiva¬ lent method, or an alternative method; or which is determined by procedures specified under any subpart. The EPA considers the following organic solvents to have negligible photochemical reactivity, and therefore does not consider them to be VOCs: Methane 1 Ethane 1 1,1,1-trichloroethane (methyl chloroform) 1 Methylene chloride 2 Trichlorofluoromethane (CFC-11) 3 Dichlorodifluoromethane (CFC-12) 3 Chlorodifluoromethane (CFC-22) 3 Trifluoromethane (CFC-23) 3 Trichlorotrifluoroethane (CFC-113) 1 3 Dichlorotetrafluoroethane (CFC-1I4) 3 Chioropentafluoroethane (CFC-115) 3 Many states also do not consider some or all of these materials to be VOCs. Two of these compounds, 1,1,1-trichloroethane and methylene chloride, are used as solvents in some coatings. These materials should not be counted as VOCs if they are "exempt" from the applicable regulation. The method for discounting these materials is described in some of the examples and in Appendix B. Generally, these materials, when "exempt" from the applicable regulation, are treated in the same manner as water in emission calculations. Only the compounds listed above and any compounds given the status of "negligibly photochemically reactive" by the U.S. EPA in a future Federal Re¬ gister may be considered as exempt from Federal enforcement of applicable State SIP VOC regulations. Also, Rule 66 should not be referenced for exempt¬ ing compounds as per 42 FR 35314, July 8, 1977. : 42 FR 36314, July 8,' 1977 2 45 FR 32042, June 4, 1979 3 45 FR 48941, July 22, 1980 4 SECTION 2 BASIC CALCULATIONS This section presents examples of basic types of calculations. The examples closely follow the VOC Data Sheets (Appendix B). 2.1 DETERMINING THE MASS OF VOC EMITTED PER VOLUME OF SOLIDS Example 1 - Determine the mass of VOC emitted per volume of solids for a solvent-borne coating. The following data are given: = 10.0 Ib/gal = 60 percent by weight = 0 A. Coating Density B. Total Volatiles C. Water Content D. Organic* Volatiles Content E. Nonvolatiles Content (Sol ids) = 60 percent by weight = 35 percent by volume Mass of VOC emitted per volume of solids is: 10.0 lb coating 0.60 lb VOC 1 gal coating _ 17.1 1b VOC gal coating lb coating x 0.35 gal so)ids gal solids Example 2 - Determine the mass of VOC emitted per volume of solids for a waterborne coating. The following data are given: A. Coating Density B. Total Volatiles C. Water Content D. Organic* Volatiles = 9.0 lb/gal = 70 percent by weight = 30 percent by weight Content E. Nonvolatiles Content = 70-30=40 percent by weight = 19.6 percent by volume (Sol ids) *Photochemically reactive materials only. 5 Mass of VOC emitted per volume of solids is: 9.0 lb coating 0.40 lb VOC 1 gal coating _ 18.4 lb VOC gal coating x lb coating x 0.196 gal solids ~ gal solids Example 3 - Determine the mass of VOC emitted per volume of solids for a coating that contains some negligibly photochemically reactive (NPR) solvents. The following data are given: A. Coating Density B. Total Volatiles C. NPR Solvent Content D. Organic* Volatiles Content E. Nonvolatiles Content (Sol ids) Mass of VOC emitted per volume of solids is: 11.0 lb coating 0.40 lb VOC 1 gal coating _ 29.3 lb VOC gal coating x lb coating x 0.15 gal solids gal solids = 11.0 lb/gal = 80 percent by weight = 40 percent by weight = 40 percent by weight = 15 percent by volume 2.2 DETERMINING THE MASS OF VOC EMITTED PER VOLUME OF COATING LESS WATER Example 4 - Determine the mass of VOC emitted per volume of coating less water for a solvent-borne coating. The following data are given: A. Coating Density B. Total Volatiles C. Water Content D. Organic* Volatiles Content = 10 Ib/gal = 60 percent weight = 0 = 60 percent weight Mass of VOC per volume of coating less water is: 10 lb coating 0.60 lb VOC 1 gal coating _ gal coating x lb coating (1-0) gal coating less water = _ 6 lb VOC _ gal coating less water *Photochemically reactive materials only. 6 Example 5 - Determine the mass of VOC emitted per volume of coating less water for a water-borne coating. The following data are given: A. Coating Density B. Total Volatiles C. Water Content D. Organic* Volatiles Content = 9.0 Ib/gal = 70 percent by weight = 30 percent by weight = 70-30=40 percent by weight The mass of water in the coating is: 9.0 lb coating 0.3 lb water _ 2.7 lb water gal coating lb coating gal coating The volume of water in the coating is: 2.7 lb water _1_ _ 0.32 gal water gal coating x 8.33 lb water ~ gal coating gal water The mass of VOC in the coating is: 9.0 lb coating 0.4 lb VOC = 3.6 lb VOC gal coating x lb coating ~ gal coating The mass of VOC emitted per volume of coating less water is: 3.6 1b VOC _ gal coating _ _ _ 5.3 lb VOC _ 1 gal coating - 0.32 gal water gal coating less water gal coating Example 6 - Determine the mass of VOC emitted per gallon of coating less negligibly photo- chemically reactive material for a coating that contains some negligibly photochemically reactive material. The following data are given: A. Coating Density B. Total Volatiles C. NPR Solvent Content D. Organic* Volatiles Content E. NPR Solvent Density = 10.5 Ib/gallon = 80 percent by weight = 40 percent by weight = 40 percent by weight = 11.0 lb/gal *Photochemically reactive materials only. 7 The mass of VOC per volume of coating is: 10.5 lb coating 0.4 1b VOC _ 4.2 lb VOC gal coating x lb coating gal coating The mass of NPR solvent in the coating is: 10.5 lb coating 0.4 1b NPR solvent _ 4.2 lb NPR solvent gal coating x lb coating gal coating The volume of NPR solvent in the coating is: 4.2 lb NPR solvent 1 _ _ 0.38 gal NPR solvent gal coating 11.0 1b NPR solvent ~ gal coating gal NPR solvent The mass of VOC per gallon of coating less NPR solvent is: 4.2 lb VOC _ gal coating _ _ _ 6.8 lb VOC _ 1 gal coating - 0.38 gal NPR solvent gal coating less NPR solvent 1 gal coating 8 SECTION 3 TRANSFER EFFICIENCY When spray guns are used to apply coatings, much of the coating material either bounces off the surface being coated or misses it altogether. Transfer efficiency (TE) is the ratio of the amount of coating solids deposited on the coated part to the amount of coating solids used. Regardless of the TE, all of the VOCs in the dispensed coating are emitted whether or not the coating actually reaches and adheres to the surface. Consequently, improved TE can reduce VOC emissions because less coating is used. EPA has defined baseline transfer efficiencies of 60 percent for RACT in metal furniture and appliance coating and 30 percent for RACT waterborne equivalence in the automobile in¬ dustry (for both primer-surfacer and topcoat applications). If a base TE has not been documented by EPA, then the company must satisfactorily document their base TE prior to equivalency calculations/demonstrations. To obtain TE credits, a company must prove its baseline TE with documentation, and document the new TE. 3.1 DETERMINING THE MASS OF VOC EMITTED PER VOLUME OF SOLIDS APPLIED Example 1 - Determine the mass of VOC emitted per volume of solids applied given the fol¬ lowing data: A. VOC content of coating = 4.0 lb VOC gal solids B. Transfer efficiency = 40 percent Mass of VOC emitted per volume of solids applied is: 4.0 lb VOC 1 gal solids used = 10.0 1b VOC gal solids x 0.4 gal solids applied gal solids applied 9 Example 2 - Determine the mass of VOC emitted per volume of solids applied given the fol¬ lowing data: A. VOC content of coating B. Nonvolatiles content C. Transfer efficiency D. Water Content = 3.0 lb VOC/gal coating less water = 55 percent by volume = 60 percent = None 3.0 lb VOC _ 1 gal coating less water 1 gal solids used gal coating less water x 0.55 gal solids x 0.60 gal solids applied = _ 9.1 1b VOC 1 gallon solids applied Note: For a waterborne coating, be careful of using pounds of VOC per gallon of coating less water and volume nonvolatiles content as a fraction of the total coating including water. These two items cannot simply be combined to get pounds of VOC per gallon of solids. The best method is to follow Example 2 in Section 2 and then factor in transfer effi¬ ciency. A1ternatively, the volume nonvolatiles content could be de¬ termined for the coating less water if the volume fraction water is known or calculated as follows: . Volume fraction nonvolatiles in coating less water volume fraction nonvolatiles in coating including water 1 - volume fraction water 3.2 CALCULATING AVERAGE TRANSFER EFFICIENCY Example 3 - A plant operates two coating lines. Each line uses both manual electrostatic spray guns (TE = 60 percent) and rotating-head electrostatic spray guns (TE = 80 percent). Table 1 contains the applicable data. What is the average transfer efficiency? Average TE = total liters of solids deposited _ 38.4 + 36.8 total liters of solids used ~ 64+46 x 100 75.2 " 110 x 100 = 68 percent 10 TABLE 1. EXAMPLE CALCULATION OF AVERAGE TE WHEN SEVERAL DIFFERENT COATING APPLICATION METHODS ARE USED * 1 o o s- 00 4-> O II QJ r— UJ 0) t— Liters of solids deposited 00 00 • CO CVJ 36.8 i/i to ra >, u *3 -o QJ ID QJ 4— »r- QJ o ID CO JZ u -U 1 3 t— to t—t CO ■cr 1 Cl O 3 3» to to c •*- o +-> . r~ to en ♦D U c *3 4-> ID QJ 4- *p- QJ o o O +-> +-» < D v> in C\J ID cc •r* ID 3 O O *o to in to QJ i~ U -O 4-> *3- c. QJ 4- *f- •*— • • CO 4-> ( 3 r— to <3- 00 O C CVJ *—l cr> u _J to Cl ■f- + QJ 4-> - —. -o to ■*-> o to to 40 to o U *o *o U II QJ 4- *r- Q) © M3* ** ■*-> 4J I 3 f— to CVJ CO U UJ O 3 oj i— to o> CO CD u c *3 ID QJ 4- *»- Qj © O 3 4-> < 3 V to 00 «3- c >r- ID 3 ID O 51 o CO to ID u *3 *3 QJ 4- •*- QJ o O O -*-» I 3 r- to ID iD •r* O 3 to QJ 4-> CO 1 E c *3 < 3 0)*^ o o r— y r— in CO i DUO > QJ tO O. ■ to o> • U C *3 ID QJ 4— •»- Qj o o uu o Via o © o •<- ID 3 «—1 rH h- O O 3 C •r* 31 •a: CO C •f— _J 4-> ID 1— O o <_> 1— 11 ♦These TE values are Illustrative values only. Actual TE must be determined to calculate actual emissions. SECTION 4 COMPLIANCE DETERMINATIONS 4.1 CALCULATING COATING COMPLIANCE WITH A STANDARD Example 1 - « A coater is required to meet an emission limit of 3.5 pounds of VOC per gallon of coating less water. Does a coating with a density of 12 pounds per gallon that contains 25 weight percent VOC comply? The coating contains no water or negligibly photochemically reactive solvents. 12 lb coating 0.25 1b VOC 1 gal coating _ gal coating x lb coating (1-0) gal coating less water = _ 3 lb VOC _ gal coating less water So, the coating complies with the regulation. Example 2 - A coater is required to meet an emission limit of 4.0 pounds VOC per gallon of solids. Does a coating with a density of 10 pounds per gallon that contains 60 weight percent volatiles, 45 weight percent water, and 30 volume percent solids comply? The weight percent organic volatiles is 60-45=15. The VOC content of the coating is: 10 lb coating 0.15 lb VOC 1 gal coating _ 5 lb VOC gal coating lb coating x 0.30 gal solids ~ gal solids So, the coating does not comply with the regulation. 12 Example 3 - A coater is required to meet an emission limit of 10 pounds VOC per gallon of solids applied. Does the coating in Example 2 comply if it is applied at a transfer efficiency of 80 percent? 5 lb VOC 1 gal solids used _ 6.3 1b VOC gal solids x 0.80 gallon solids applied “ gal solids applied So, the coating meets the regulation. Example 4 - A metal furniture coater uses a coating containing 0.40 kg VOC/liter of coat¬ ing (less water and exempt solvents). The coating contains 55 volume percent solids. The transfer efficiency is 87 percent. Is the plant in compliance if the maximum allowable emissions are 1.0 kg VOC/liter solids applied? The solution is found by using the following basic equation: mass of VOC used _ 1 _ _ mass of VOC used volume of coating solids used x TF ” volume of coating solids applied Emissions are: 1 liter of coating less water _ 0.40 kg VOC _ and exempt solvents _ 1 liter of coating less water x 0.55 liter solids and exempt solvents 1 liter solids = 0.84 kg VOC 6.87 liter solids “ 1 liter solids applied applied Since 0.84 is less than 1.0, the coating operation is in compliance. Note: This example is similar to Example 2 in Section 3.1. Therefore, the note mentioned after Example 2 applies to this example too. 4.2 CALCULATING COMPLIANCE WHEN ADD-ON CONTROLS ARE USED ♦ Example 5 - A coater is required to meet an emission limit of 6 pounds of VOC per gallon of solids. What percent emission reduction is needed if the coater uses a coating with 22 pounds of VOC per gallon of solids? 13 22-6 16 =$ 2 — x 100 = x 100 * 73 percent emission reduction Example 6 - A coater is required to meet an emission limit of 3.7 pounds of YOC per gallon of coating less water. What percent emission reduction is needed if the coat¬ er uses a solvent-borne coating with 5.0 pounds of V0C per gallon of coating less water and a volume solids content of 25 percent? This calculation must be done on a solids basis. First, the emission limit must be converted to pounds of V0C per gallon of solids. To do this, an as¬ sumed V0C density of 7.36 pounds per gallon is used to calculate the volume solids content of the "presumptive" RACT coating. gal boatings water x o f T FWt x 100 * 50 volume P ercent voc 100-50 = 50 volume percent solids 3.7 lb-YOC 1 gal coating = 7.4 lb VOC gal coating x 0.50 gal solids ~ gal solids Next, the VOC content of the coating used must also be calculated on a solids basis. 5.0 lb VOC 1 gal coating _ 20 lb VOC gal coating x 0.25 gal solids “ gal solids Now the required percent reduction can be calculated. x 100 * 63 percent emission reduction Notes: 1. An erroneous result is obtained if this calculation is not done on a solids basis. Using pounds of VOC per gallon of coating less water the result would be: — x 100 = 26 percent emission reduction This would not give equivalent emissions as it does not take into account that the "presumptive" RACT coating not only has lower VOC content, but higher solids content as well. 14 2. An assumed VOC density of 7.36 pounds per gallon is used to calculate the volume solids content of the “presumptive" RACT coating because this same value was used to determine the "presumptive" recommended RACT emission limits from volume solids data. 3. The volume solids content of actual coatings should be determined directly from coating formulation data as described in the VOC Data Sheets. Ocassion- ally, it may be useful to back calculate volume solids from VOC content and actual solvent or VOC density, but this must be done with extreme caution. When an inspector gathers data on the actual coatings used at a facility, the volume solids content should be obtained from coating formulation data from the facility or the coating manufacturer. The volume solids content should not be back calculated. 15 SECTION 5 EQUIVALENCY DETERMINATIONS Equivalency calculations are required when compliance decisions must be made for replacement coatings, bubbles, offsets, netting, etc. This type of calculation relates primarily to the CTG source categories. This section pre¬ sents example equivalency calculations. VOC equivalency calculations must be made on a solids basis. The amount of solids needed to coat a surface to a particular film thickness is the same regardless of the coating composition used. Reducing the solids content of an organic solvent-borne coating increases the quantity of coating required and increases VOC emissions because more coating is used and the coating has a higher VOC content. 5.1 CALCULATING ALLOWABLE HOURLY EMISSIONS FOR A SOLVENT-BORNE COATING* Example 1 - A surface coater uses 10 gallons per hour of a coating that contains 5.5 1b VOC per gallon of coating and 25 volume percent solids. New regulations indicate that the coating formulation must meet an emission limit of 3.0 1b of VOC per gallon of coating (with a solvent density of 7.36 1b per gallon) or the coater must control VOC emissions to an equivalent level. Assuming that the production rate (solids usage rate), transfer efficiency, and film thickness stay constant, what are the coater's "allowable" hourly VOC emissions? For the existing coating, the actual VOC emissions are: 10 gal coating 5.5 1b VOC = 55 1b VOC h x gal coating R ♦This example presents a method for determining hourly VOC mass emissions for offset calculations; however, RACT limitations should normally be based on either applicable coating formulations or control efficiency requirements. An hourly cap would normally only be used in addition to these RACT limitations. 16 The solids usage rate is: 10 gal coatinq „ 0.25 gal solids _ 2.5 gal solids —- x gal 'coatTng" -- For the complying coating, the VOC (solvent) volume fraction is: 3.0 1b VOC 1 gal VOC _ 0.41 gal VOC gal coating x 7.3b lb VOC gal coating The complying coating solids volume fraction is: 1.0 - 0.41 0.59 gal solids gal coating Using the solids usage rate calculated above, the gallons of complying coating required are: 2.5 gal solids gal coating _ 4.24 gal complying coating FP x 0.59 gal solids “ h The emissions rate at the existing solids applied rate is: 3.0 1b VOC 4.24 gal coating s 12.72 1b VOC gal coating x FT” Fi 5.2 EQUIVALENCY CALCULATIONS FOR A CAN COATING OPERATION Example 2 - The RACT equivalence requirements for can coating operations are tabulated in 45 FR 80825, dated Oecember 8, 1980. An analysis of two coatings used in an actual plant is: Coating No. 1 Coating No. 2 (1) Actual pounds of VOC per gallon of coating less water and exempt solvents as applied 5.42 1.09 (2) Gallons of each coating applied 110 240 (3) Control efficiency, percent 0.81 — (4) Volume percent water and exempt solvents in coatings 41.3 (continued) 17 (5) Volume percent solids (6) Allowable emission limit, 1b VOC/gal coating less water and exempt solvents Calculate the following: (1) Gallons of solids applied. (2) Pounds of VOC per gallon of solids. (3) Pounds of VOC emitted. (4) Allowable VOC emissions. Answers: (1) The gallons of solids applied can be calculated as follows: Gallons of solids applied * (gallons of coating used) x (volume percent solids) * 100% (Since the quantity of solids used in the equation appears as a percentage it is necessary to divide by.100%.) Coating No. 1: no totting x Coating No. 2: oj*n _u „ 50 gal solids _ 120 gal solids 240 gal coating applied x m coating " applied (2) As noted on Page 10, the pounds of VOC per gallon of solids can be calculated as follows: 1b VOC c 1b VOC/gal coating less water gal of solids ^volume percent solids 100-volume percent water Coating Coating No. 1 No. 2 26.4 50.0 2.8 2.8 18 Coating No. 1: 5.42 1b VOC 100 gal coating 100 - 0 gal coating less water gal coating x 26.4 gal solids x lob gal coating less water , 20.53 lb VOC gal solids Coating No. 2: 1.09 lb VOC 100 gal coating 100 - 41.3 gal coating less water gal coating x 50.0 gal solids x 100 gal coating less water = 1.28 lb VOC gal solids (3) The pounds of VOC emitted can be calculated as follows: ga| b Q fSolids x ^ so ^ ds x ” overall control efficiency*) Coating No. 1: ~ gaf 3 so 1 > ids C x 29 *° 9al so1ids x (1 * 0,81) * H3.1 1b V0C Coating No. 2: ga f ' VoTTd s^ x 120 9a1 solids x U * 0) = 153.6 lb VOC (4) The allowable VOC emissions can be calculated as follows: As calculated in Item (2), the gallons of solids applied for coatings No. 1 and No. 2 were 29 and 120, respectively. Assume that the coater will apply the same volume of solids with a RACT complying coating. Given: (1) Emission limit: 2.8 lb VOC/gal coating (2) VOC density: 7.36 lb VOC/gal ♦The overall control efficiency is equal to the fraction of total VOC used that is destroyed or recovered by the control system. Overall control effi ciency = capture device efficiency x control device efficiency. 19 Allowable pounds of VOC = gallons of complying coating applied x allow¬ able emission limit, * gal solids applied (per unit of time) 2.8 lb VOC _ volume fraction solids in complying coating gal coating less water and exempt solvents Volume fraction VOC: 2.8 lb VOC 1 gal VOC 0.38 gal VOC gal coating ?.3b lb VOC gal coating Volume fraction solids: > - 0.38 CO.,,8, ■ °-g , ■£.“»« Allowable pounds of VOC for Coating No. 1: ^ „ 1 gal coating .. 2.8 lb VOC 29 gal solids x oTgirtonls x gal coating = 131 It VOC Allowable pounds of VOC for Coating No. 2: 190 nai cniiHc v gal coating v 2.8 lb VOC 120 gal solids x 0 .62 gal solids x gal coating * 542 lb VOC Table 2 shows the calculation sequence. 20 TABLE 2. SUGGESTED FORMAT FOR DETERMINING COMPLIANCE FOR CAN COATING OPERATIONS OOOOONO to OOOSCMIO SO 91 C o — ! • • C «> —» ^CvioONoW *o vnaDO ^ 91 c —J X 1 «in n rs. if> o O «*- — — — CM — CM — o -nnn ri — in ^2 o o> — • • ♦A 91 c N «pB >* 9 • u a 1 1 1 —— c« mm k — T3 c c o**- «>—» U 2-5 O O k > CD 00 c U W V UW • 1 *111 o o o TO sn 8 . k w o a> * «« U Ol ■ 0300BNV 0) -C • >— "9 — *—* ooooKv k. VO D oioVndin oiovndin ** to O Q. MPMfs <•> — CM CM n* PO —« C 4-» •ft — X —* 40 40 ^ o 0 A Q. ~ - O E O S S» OITJ k C Ol O* 91 k- 01 ^ 22 J= « **- X£ oooi'tuio -MB "9 — u O AS Ol 3 01 1 V* "O'* c O k n »a —• v co — —• Ss .A W 30 —■ —■ o> ~o ■ C k 3w CM CM — CM CM CM CM — CM CM k. Ol 3 0.9 m a QJ U * 0 — x o C 5 w i c o u ■—• a. © ^. -a •9— (A *— — a* IA Cl c Ol *< « m U« IA c o e ftj Ol** 3—1 tf> in v-OOOn U w — 9 «— E • • t/l • ••••• 40 iA — c o^» LU CM O O — CD — oi oo io 3 no — in 3 •— oi a o 21 4-» *«B u iA « -o D • ••••• IU «o oi oi— — O — OlAOOOl ■a 3 — CM — —■ a CM k —1 o 01 Ol B «/> 3 TO k ■ E k« i a X H no oi 5 D 5 m ai —> • • •o •— *> 3 O — O O uo o mm • 1 1 1 1 • B O "0 —• SO < •9 m X TJ C fl c • 3 C a«—* • ••••• Ol 5m > u 1 1 • 1 1 1 xeoavrso m ’-- nnnNinm • 40 O O «*» <013 > V) (A • c • o 1 TO E TJ V O CM Ol O 91 ooonow' a 8 5 • ••••• «o o »■* M — *0«- 3 so o — no so cm CM CM CM SO CM oi u — — O O'— Minn«««T ««lOCM W • 9 > %« to c ■ •» IA Ol (A N Ol CO m C m Ol 3C as E <-> » c CM Ol s© » — o voonoiN o 9 CO com CM N o a >o (A > IBM M *»^ — 3 1 a 4-> OMB « « « • ••••• CO • • B • • B CO O 1 AS A O — S'— AMlAlOnv .m n cm m v cn vo u o -J o mm MW • 4^ u c w o UJ — c 0 Ol o> cn o> 91 Ol 91 QJ J C C C >s9 —) C = = >1-0 mJ to > — — — — c •*- «o c C 4-4 *— 0mm >1 «-»•*->«-> k 3 i— 4-> 4-> *4 L 3 I— n> o V « « ig E aa 3 g ig g E a c 3 O VI 3 Q. o o o « vi a 1— O O 9 9 m o I— 4-> E U U U tl = U U U Ol E J c u vi Ol S in oi e • • o u 44 4J t3 U l « «4 44 "O U •t 0) 41 41 Ol ai — O 41 41 3-- 3 4-4 k &• n 01 01 01 *0 VI 3 j »— J 41 41 T) IA T H- o 9 o 1 £££«:: 1 s_> •C .C .= — C C <_> u. Ll. | m y) m m •« uj 1 * «/H/> (/)* j» t X "O I 3 M • . « « JC O b •pw MW ig (i —- au O — 41 C © — «J <4 MO M« w «■»—»>»— o M MC Q. II MW E ^9 o 8 *o • acu Ol XJ — Wl V W « M£ 8 M Ol W 3 41 Ol IMO) © p«o >%— JC U U U (1 • C MW • MW < ■© — <• c ■— 4) u <4 b MW w m u a MW **- u — o •b" c a. Wl •— E 01*4 V C o <4 — © o b b M3 *b w «o at Wl c a. >% 6 £ Wl o e S b. o E 9 at s S ■© S 3 mw 41 • M C Wl b Wl Wl 41 m >* <4 *4 C — Wl O jO v at e •b •— Wl S mw b x: MW •b Cl. MW MW « S — c • 5 <4 u « e S X — b © "O 5 <4 II M — — 3 a. wi mw >, «— MW 41 9 V 4 O 41 W b C <4 jc o mw at •© h b MW C b • as u <4 O b> • e E <*- 9 *o © 3 o u ^ Wl mW MW -b> A 3 C > 1 — o — ■w U O 9 o. wi « c b a. to « 8 4* MW Ol 9 «•» u — c c • *• M U O ■b Wl • > > 1 — u b 3 * 4b <4 v g* 3 X«b b — 4) O — m ^ Is «b e b- >o u *» b mw e c <*- • « mw wi b <« b o 3 e 3 «w o e u o K c 3 *b — o U Ob <4 Ot • 03 — Ol *» c C U MW <4 m obva o. at b t b u GJC 3 C a. C H* MW • © \ b JC C4 OIMW o MW to c ■— Wl lb b • U 11 -b c W X M Ml X 3 8 5 •— L. s Of C — at •b MW b MW © A u «b b 4> 3*wi b- o e 9 « — 3 w "b > b 6 • at ■o >» wo 8 at a >l Wi 41 MW b 4* 3 «b U 41 4 U a. « C Wl C MW JC b c cl 4# e II MW 3 O <4 4/1 4-* m — ^ O c TJ U 41 C Wl *3 Wl o — > «b 41 TJ W u •« «b O 41 Wl -b 4> *b b ^ J£ 9b. 8 II O. 41 mw mO o 5 CL. Wl • Wl «A • M b 4 3 “ >» MW O CM • O Wl MW ©.*b 4p» b bRIlbw 41 O 9"» tei a. mw e wi 4i b u a _i C -b O MW o C — E CD ■ O M£ U£ O <4 3 « U 3 W s W u o> u b« 1 o N n 22 SECTION 6 COMPLEX CALCULATIONS This section presents example calculations demonstrating situations that may require a series of calculations. 6.1 COMPLIANCE DETERMINATION FOR AUTO PLANT PRIMER-SURFACER (GUIDE COAT) OPERATION Example 1 - An auto primer-surfacer operation uses a coating that contains 3.58 lb VOC/gal of coating with a transfer efficiency of 50 percent. The RACT emission limit is 2.8 lb VOC/gal of coating less water at 30 percent transfer efficiency (waterborne equivalence). Is the operation in compliance? Given: (1) The manufacturer's data show that the undiluted coating has 50.0 volume percent solids. (2) The plant adds 0.05 gal of thinner blend per gallon of un¬ diluted coating: (a) 0.02 gallon of thinner No. 1/gallon undiluted coating (thinner density 7.36 lb/gal). (b) 0.02 gallon of thinner No. 2/gallon undiluted coating (thinner density 5.43 lb/gal). (c) 0.01 gallon of thinner No. 3/gallon undiluted coating (thinner density 9.52 lb/gal). (3) The density of the undiluted coating is 10.25 lb/gal. (4) Weight fraction of VOC in undiluted coating = 0.333 lb VOC solvent lb undiluted coating 23 First, verify the VOC content of the coating. In order to do this, the VOC content of the undiluted coating and the thinners must be calculated. The mass of VOC in the undiluted coating is: 0.333 lb VOC 10.25 lb undiluted coating = 3.41 lb VOC lb undiluted coating gal undiluted coating “ gal undiluted coating The mass of thinner added per gallon of undiluted coating is: 0.02 gal thinner No. 1 7,36 lb thinner No. 1 + 0.02 gal thinner No. 2 gal undiluted coating gal thinner No. 1 gal undiluted coating 5.43 lb thinner No.‘2 + 0.01 gal thinner No. 3 9.52 lb thinner No. 3 gal thinner No. 2 gal undiluted coating x gal thinner No. 3 = 0.147 + 0.109 + 0.095 0.351 lb thinner gal undiluted coating The mass VOC per volume coating at application is: 3.41 lb VOC/gal undiluted coating + 0.351 lb thinner/gal undiluted coating 1.05 gal coating/gal undiluted coating = 3.58 lb VOC/gal coating The undiluted coating has 50.0 volume percent solids. After the coating is diluted with 0.05 gallon of thinner per gallon of coating, the volume percent solids is: 0.50 _ 0.48 gal solid s 1 + 0.05 ~ volume coating The equivalency calculations must be made on a solids basis. The formula for determining the maximum allowable emissions on a solids basis is: Allowable emissions _ allowable mass of VOC per volume coating (baseline TE) (baseline volume solids) As noted in earlier examples, an assumed VOC density of 7.36 gal is used to calculate the volume solids content of the “presumptive" RACT coating. The volume of VOC in the “presumptive" RACT coating is: 2.8 lb VOC 1 gal VOC _ 0.38 gal VOC gal coating x TTSTTErvOC gal coating 24 Therefore, the baseline volume of solids is: 1 - 0.38 0.62 gal solids gal coating Allowable emissions are: 2.8 lb VOC 1 gal coating _ 1 gal solids _ 15.1 lb VOC gal coating 0.62 gal sol ids x 0.30 gal solids applied ” gal solids applied The formula for actual emissions is: •» • Actual emissions actual mass VOC per volume coating (actual % TE) / actual volume sol ids x ' gal coating ' The actual mass of VOC per volume coating is 3.58 lb VOC/gallon coating. The actual transfer efficiency is 50 percent. The actual volume of solids in the sprayed coating is 48 percent. Actual emissions are: 3.58 lb VOC 1 gal coating _ 1 gal solids _ 14.9 lb VOC gal coating x 0.48 gal solids x 0.50 gal solids applied " gal solids applied Actual emissions (14.9 lb VOC per gallon of solids applied) are less than the maximum allowable emissions (15.1 lb VOC per gallon of solids applied); therefore, the operation is in compliance. 25 6.2 DETERMINING COMPLIANCE FOR A LARGE APPLIANCE COATING LINE USING SEVERAL TYPES OF SPRAY EQUIPMENT Example 2 A large appliance manufacturer has a coating operation that employs electro¬ static spray coating equipment and manual spray coating equipment. The following data are available regarding the operation. Determine the compliance status. If the large appliance manufacturer is out of compliance, what percent reduction is required to achieve compliance? (A) (B) Electrostatic Manual coating coating Transfer efficiency, percent Average volume percent of solids in coating VOC content, lb VOC/gal coating less water 90 40 39 39 4.5 4.5 Gallons of coating used per day 30.4 47.1 Emission limit, lb/gallon less 2.8 2.8 water Baseline transfer efficiency for 60 60 large appliances, percent The baseline transfer efficiency is 60 percent for a large appliance coater. Table 3 is a tabulation of the available data and calculation results. The actual calculations follow. 26 TABLE 3. LARGE APPLIANCE MULTITRANSFER EFFICIENCY CALCULATION. m >» X> to 00 o 00 VO os VO C 4- *© • • • • • • 3 0^. Vo CSJ 00 o VO o o ro *—t 00 VO ro Cl. O *—« CSJ ro r—1 • >> LT> re m *0 10 C *p- ^ o*o r*. ro ro r- O O) • • • • r— US »r- o o r^» <0 r— 0 4- a rH *—1 O Cl re 1 F— US re t5 "O V r- a> CO 00 in vo to o o •*- m • • c • • O Wr- c csj 00 o r-* > Q. o «—t csj •P* C Cl •r- in ^ o re in m -J r— in •r* E E 0) a> V* UJ o o *o o o I- p—* os re- o c in U © 0*0 ID vo vn VO ^ «p* • • • • r* p* «—i «9" X) re o __i cn us *—• i—i ^ a> o c c O O *r- LO IT) 00 00 > r- +J • • • • f— re CSJ CSJ £1 to O J DU * V) • -O r— o> OS CSJ CSJ T OW f— > o i/s co CO VO VO i in *-> >» c re re »—1 00 VO 0 0*0 • • • • »— u— o 00 Os •— ai re M- c o o •*- CO «3- CSJ 1—< >> 4-> Q.+J o o i n ►- »— 27 Under the actual emissions category, the following calculations can be made. For A and B, the mass of VOC per volume of solids is: 4.5 lb VOC 1 gal coating _ 11.5 lb VOC gal coating x 0.39 gal solids ” gal solids For A, the mass of VOC per volume of solids applied is: 4.5 lb VOC 1 gal coating _ 1 gal solids _ _ 12.82 lb VOC gal coating x 0.39 gal solids x 0.90 gal solids applied ~ gal solids applied For B, the mass of VOC per volume of solids applied is: 4.5 1b VOC 1 gal coating _ 1 gal solids _ 28.85 1b VOC gal coating x 0.39 gal solids x 0.40 gal solids applied " gal solios applied For A, the volume of solids applied per day is: 0.90 gal 30.4 gal coating 0.39 gal solids solids applied _ 10.7 gal solids applied day x gal coating gal solids used ~ day For B, the volume of solids applied per day is: 0.40 gal 47.1 gal coating 0.39 gal solids solids applied _ 7.3 gal solids applied day x gal coating x gal solids used ” day For A, the mass of VOC emissions per day is: 4.5 lb VOC 30.4 gal coating _ 136.8 1b VOC gal coating x day " day For B, the mass of VOC emissions per day is: 4.5 lb VOC 47.1 gal coating = 212.0 1b VOC gal coating day ~ day Under the allowed emissions category, the following calculations can be made. For A and B, the volume fraction of VOC in the baseline coating is: 2.8 lb VOC 1 gal VOC = 0.38 gal VOC gal coating x 7.36 lb VOC gal coating 28 The volume fraction solids in the coating is: i . 0.38 gal VOC _ 0.62 gal solids gal coating " gal coating The baseline mass of VOC per volume solids is: 2.8 lb VOC 1 gal coating _ 4.5 lb VOC gal coating C.62 gal solids " gal solids For A and B, the maximum allowable emissions are: 2.8 lb VOC 1 gal coating 1 gal solids used _ 7.5 lb VOC gal coating x 0.62 gal sol ids x 0.60 gal solids applied " gal solids applied The volume of solids applied remains the same. Therefore, for A, the gallons of complying coating used per day would be: 10.7 gal solids applied 1 gal coating 1 gal solids used day x 0.62 gal solids x 0.6 gal solids applied 28.8 gal coating day For B, the gallons of complying coating used per day would be: 7.3 gal solids 1 gal coating 1 gal solids used _ 19.6 gal coating day x 0.62 gal solids x 0.6 gal solids ” day applied For A, the mass of VOC emissions allowed per day is: 2.8 lb VOC 28.8 gal coating = 80.6 1b VOC gal coating day ” day For B, the mass of VOC emissions allowed per day is: 2.8 lb VOC 19.6 gal coating = 54.9 lb VOC gal coating day ~ day The total actual VOC emissions from A and B are 348.8 lb VOC per day. The total allowable VOC emissions are 135.5 lb VOC per day. Therefore, the opera tion is out of compliance. To achieve compliance, the required reduction in emissions is: 348.8 - 135.5 348.8 x 100 = 61 percent 29 SECTION 7 GRAPHS AND TABLES USEFUL IN APPROXIMATING AND DOUBLE-CHECKING SURFACE COATING CALCULATIONS Figure I can be used to evaluate compliance alternatives for waterborne and organic-borne coatings. This can be done by drawing a horizontal line from the required VOC content of coating (less water and exempt solvents) to the appropriate curve (depending on ratio of water to organic solvent in coat¬ ing). A vertical line is then drawn from the point of intersection to the x-axis which yields the volume percent solids. All of the coatings represent¬ ed by the horizontal line have the same pounds of VOC solvent per gallon of coating (less water and exempt solvents). A vertical line in Figure 1 from the volume percent solids to the organic-borne line represents all of the coatings with the same volume percent solids. Horizontal lines drawn from the appropriate waterborne curves yield the VOC contents of the coatings less wa¬ ter and exempt solvents. Note that these values are considerably different for coatings with the same solids contents. Figures 2 and 3 are the same graph, only Figure 2 is drawn to a larger scale. If the pounds of VOC solvent per gallon of coating (less water and exempt solvents) is known, these figures can be used to approximate the pounds of VOC solvent per gallon of coating solids, assuming a solvent density of 7.36 pounds per gallon. Table 4 presents volume percent solids equivalency data for different coating operations. Table 5 presents CTG Equivalency Data. A VOC density of 7.36 pounds per gallon is assumed in these tables. Table 6 provides equiva¬ lent solids deposited limits. Table 7 presents some useful conversion fac¬ tors. 30 POUNDS OF VOC (SOLVENT) PER GALLON OF COATING (MINUS WATER AND EXEMPT SOLVENTS) (ASSUMED VOC DENSITY « 7.36 #/gal) Figure 1. Graph for determining equivalent solids/VOC (solvent) contents of waterborne and organic-borne coatings. 31 POUNDS OF VOC (SOLVENT) PER GALLON OF COATING SOLIDS 32 POUNDS OF VOC (SOLVENT) PER GALLON OF COATING SOLIDS Figure 3. Smaller-scale graph for determining pounds of VOC (solvent) per gallon of coating solids. 33 TABLE 4. CTG VOLUME PERCENT SOLIDS EQUIVALENCY DATA Industrial finishing categories Kg VOC per liter of coating less water Lb VOC per gallon of coating less water Solvent-borne coating equivalent volume % solids CAN INDUSTRY Sheet basecoat (exterior and interior) and over-varnish; two-piece can exterior (basecoat and over-varnish) 0.34 2.8 62.0 Two- and three-piece can interior body spray, two-piece can exteri¬ or end (spray or roll coat) 0.51 4.2 42.9 Three-piece can side-seam spray 0.66 5.5 25.3 End sealing compound 0.44 3.7 49.7 COIL COATING Prime and topcoat or single coat operation 0.31 2.6 64.7 FABRIC COATING Fabric coating line 0.35 2.9 60.6 Vinyl coating line 0.45 3.8 48.4 PAPER COATING Coating line 0.35 2.9 60.6 AUTOMOTIVE AND LIGHT-DUTY TRUCK ASSEMBLY PLANT Primer (electrodeposited) applica¬ tion, flashoff area and oven 0.14 1.2 83.7 Surfacer (guide-coat) application, flashoff area and oven 0.34 2.8 62.0 Topcoat application, flashoff area and oven 0.34 2.8 62.0 (continued) 34 TABLE 4. (continued) Industrial finishing categories Kg VOC per liter of coating less water Lb VOC per gallon of coating less water Solvent-borne coating equivalent volume % solids AUTOMOTIVE AND LIGHT-DUTY TRUCK ASSEMBLY PLANT (continued) Final repair application, flashoff area and oven 0.58 4.8 34.8 METAL FURNITURE Coating line 0.36 3.0 59.2 MAGNET WIRE INSULATION Wire coating oven 0.20 1.7 76.9 LARGE APPLIANCES Prime, single, or topcoat application area, flashoff area and oven 0.34 2.8 62.0 MISCELLANEOUS METAL PARTS Air-dried items 0.42 3.5 52.4 Clear-coated items 0.52 4.3 41.6 Frequent-color-change items 0.36 3.0 59.2 Powder-coated items 0.05 0.4 94.6 Extreme performance coatings 0.42 3.5 52.4 35 TABLE 5. CTG EQUIVALENCY DATA (VOC DENSITY = 7.36 LB/GAL) in OJ *0 O 4-> f- o **— f- in cn «—1 00 00 00 ro > *— © ID 9—4 to 00 in t- ^ OlV o CVJ o o o o o. o O to o *— "O > fO r— in 00 c-. 43- o 00 cn cn o • • • • • • • x to *tr o> «-4 r- 4J- _j s- CVJ 0) 4- Q- O ©> i- i- C O) O Ol-r+J 43- r-4 to uo in O 4-> 4-> ro ro in to 43- CO CO 4J- >f AJ J • • • • • • • *— o o o o O o o © cn o to J- to OJ 4- 0) CL O 1— C oil. O C OJ O 1— 1- 4-> Or- V (O 00 CVJ ID r— to cn 00 > « ra J • • • • • • • cn o CVJ in CO CVJ cvj ro x o to X L. to a; 4- oj Q. O i— 4-5 1 c ** 4J CD (L (O o cn ro CO to C 01 Cr- 0JT3 • • • • • • • S- +■> > 3 r- O (C-r r- O O X O 3 O tO CO O O' > to 43- CVJ in to to OJ >> *o o o 1 9 X a. S- X X 07 0) to i~ *o o 4-> f- o c 4-5 to c c c 4- 0) >> to CL) -r- ro i- s. to o •r— tj ro 0) S- s- u s- ■o > 4J o Q o c a: i c to • a; cn ID o i~ f- L. a> a) a> OJ E cn 4-» i- •»- > C 4-5 to d to 0 0.0 4-> to u to c o 0J X OJ u 4-> 25 c OJ 0) •» 4-» to to o 4-5 •r» c to '— x ro Cl a> o CL to r— T» to o 1 V o c E o r— sz 4-> *r- U 07 0) to o u cr ©> •r- to c 1 0) •r- r— o CJ 4- >1 o i- QJ i- X cr i- u to to 1 o 0J cn F* r-* 4-> 0J > to 4-5 o s- u r- •F- to to to 1 X 3; 07 4-5 to t- *o 4-5 t- to w *CJ X 07 c o X to O 4-> c > S- to • 1 OJ o to t—t 4-5 o o 50 >> 0J to 3 0J •r— 1 to to 0J r— *o c 0J *o J- o j- J- &. -o •T— C to X c 07 s CL X c o o to to X 1 — to to »— LU o CL o 4-> ■cj c 1C c o OJ -r- E 4-» *t“ ID t- CL. O) 4J tO o o i- XI fO (D O U fc. Xl (O CD c to o u 36 (continued) TABLE 5. (continued) 4 37 (continued) TABLE 5. (continued) 38 TABLE 6. EQUIVALENT CTG SOLIDS DEPOSITED LIMITS 39 TABLE 7. METRIC CONVERSION FACTORS A. Metric abbrevation Equivalent Metric unit English unit kg kilogram (10 3 grams) 2.2046 lb 1 i ter liter 0.2642 gal, 0.353 ft 3 Mg megagram (10 6 grams) 2,204.6 lb MT metric ton (10 6 grams) 2,204.6 lb dscm dry standard cubic meters 35.31 dry st. ft 3 scran standard cubic meter per min 35.31 ft 3 /min B. Multiply Ib/gal x 0.12 to get kg/liter C. Multiply kg/liter x 8.34 to get lb/gal D. Temperature: Degrees Celsius or centigrade (°C) can be converted to degrees Fahrenheit (°F) by the following forumla: t°F = 1.8 (t°C) + 32 40 REFERENCES 1. "Compliance with VOC Emission Limitations for Can Coating Operations," 45 FR 80824, dated December 8, 1980. 2. "Glossary for Air Pollution Control of Industrial Coating Operations." Second Edition. Emission Standards and Engineering Division, U.S. Envi¬ ronmental Protection Agency. EPA-450/3-83-013R. December 1983. 3. Memorandum entitled "Appropriate Transfer Efficiencies for Metal Furni¬ ture and Large Appliace Coating," from G.T. Helms, Chief, Control Pro¬ grams Operations Branch, to Chief, Air Programs Branch, Regions I-X, dated November 28, 1980. 4. Memorandum entitled "Appropriate Transfer Efficiency for Water-Borne Equivalence," from R.G. Rhoads, Director, Control Programs Development Division to Director, Air and Hazardous Materials Division, Regions I-X, dated July 3, 1979. 5. Memorandum entitled "Determination of Capture Efficiency," from J. Berry, Chief, Chemical Analysis Section, to D. Cook, EPA Region IV, dated July 7, 1980. 6. Memorandum entitled "Equivalency Calculations with the CTG Recommenda¬ tions for Surface Coating," from R.G. Rhoads, Director, Control Programs Development Division, to David Kee, Director, Air and Hazardous Materials Division, Region V, dated October 17, 1980. 7. Memorandum entitled "Procedure to Calculate Equivalency with the CTG Recommendations for Surface Coating, from R.G. Rhoads, Director, Control Programs Development Division, to Chief, Air Programs Branch, Regions I-X, dated May 5, 1980. 8. Memorandum entitled "RACT Options for Can Coating Operations," from R.G. Rhoads, Director, Control Programs Development Division to Director, Air and Hazardous Materials Division, Regions I-X, dated November 21, 1978. 9. Memorandum entitled "Role of Improved Transfer Efficiency in Demonstrat¬ ing Compliance with the CTG Recommendations for Surface Coating", from G.T. Helms, Chief, Control Programs Operations Branch, to W.S. Baker, Chief, Air Programs Branch, Region II, dated December 2, 1980. 41 J. "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings." Emission Standards and Engineering Division, LI.S. Environmental Protection Agency. EPA-450/3-84-019. De¬ cember 1984. 42 APPENDIX A GLOSSARY OF TERMS USED IN AIR POLLUTION CONTROL OF EMISSIONS FROM INDUSTRIAL COATING OPERATION EPA PUBLICATION NO. 450/3-83-013R, PAGES 26-29 ■ . ■ ■ A-2 44 AS CD ca •C X3 4 -> H- o X3 01 .n c ro U J* u o * A 3 -C cn O LO 01 ■o 03 03 c OJ • *s n- ^•n UJ CD DC c < £ « Ol. 3E O o u 4, u -C in IA 4-> o TD zz ■0~ O *—i — -o *— o < 4A O o ♦-> €_> c ^ »— 5 e zz. UJ cc 2.0 UJ u. ““ u u. £ •* CNJ X3 o :e 4- •— o o o cc iA u. 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T. Helms, Chief, Control Programs Operations Branch, EPA, to Chief, Air Programs Branch, EPA Regions I-X, "Appropriate Transfer Efficiencies for Metal Furniture and Large Appliance Coating", November 28, 1980. APPENDIX B PROCEDURES FOR CERTIFYING QUANTITY OF VOLATILE ORGANIC COMPOUNDS EMITTED BY PAINT, INK, AND OTHER COATINGS t . . B^2 United States Environmental Protection Agency Office of Air Quality Planning and Standards Researcn Triangle Park NC 27711 EPA-450/3-84-019 December 1984 . Air Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Coatings NOTICE THIS EDITION INCLUDES PAGES III-4 AND III-9 AS REVISED JUNE 19,1986 48 ' ■ EPA-450/3-84-019 Procedure for Certifying Quantity of Volatile Organic Compounds Emitted By Paint, Ink, and Other Coatings Emission Standards and Engineering Division U.S. ENVIRONMENTAL PROTECTION AGENCY Office of Air and Radiation Office of Air Quality Planning and Standards Research Triangle Park. North Carolina 27711 December 1984 49 This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. Copies of this report are available through the Library Services Office (MD-35). U.S. Environmental Protection Agency, Research Triangle Park, N.C. 27711, or from the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161. PREFACE This manual was conceived as a way to provide simple step-by-step instructions for certifying the quantity of volatile organic compounds (VOC) that will be released by a coating. It has not turned out that way. The guidance is here, but in spite of great diligence, the instructions remain imposing. The manual was prepared for several reasons. First, the coatings industry, as represented by the National Paint and Coatings Association, had requested a certification procedure which would relieve their custom¬ ers the expense of analysis. Second, the complexity of the calculations necessary to determine compliance, for example, when dilution solvent is added to a coating, continue to confound Federal, State and Local enforce¬ ment personnel. Finally, results of a recent review of the Agency's reference method for determining VOC reemphasized the importance of analytical procedures to verify VOC content. In response to the results of the review of the test methods, this manual reaffirms that Reference Method 24 or its constituent methods developed by the American Society for Testing and Materials (ASTM), are the procedures by which the VOC content of a coating will be deter¬ mined for compliance with Federal regulations. The earliest guidance was not so specific. In 1977, the first report*, written to assist States in developing regulations for sources of VOC emissions, provided recommendations for the maximum allowable VOC content for complying coatings in a variety of industries. These values were expressed in mass of VOC per unit volume of coating. In deriving the recommended limitation, the VOC content of a coating was calculated based on the solids content provided by the coating manufacturer. The Agency calcu¬ lated the mass of VOC in the coating by assuming the VOC had a density of 7.36 pounds per gallon. Solvent and VOC were used somewhat interchangedy even though it was recognized that organics such as resin monomer, oligimers, and reaction by-products could be released by a coating during the cure. There was no accepted analytical method available for measuring the total VOC which would be released by a coating. The initial guidance* provided an analytical method for use only for air-dry coatings, those where all VOC emissions would be expected to come as a result of evapor¬ ation of solvent. On a volume basis, air dry coatings constituted the largest catagory of coatings then in use. The Agency subsequently developed a more general analytical proce¬ dure that could be used to determine the total VOC in a coating. On October 3, 1980, the Agency published "Reference Method 24 (RM-24) - *Control of Volatile Organic Emissions from Stationary Sources - Volume II: Surface Caoting of Cans, Coils, Paper, Fabrics, Automobiles, and Light-duty Trucks, Document No. EPA-450/2-77-008. 1 1 i 51 Determination of Volatile Matter Content, Density, Volume Solids, and Weight Solids of Surface Coatings," in the Federal Register (45 FR 65958). For the first time the Agency formally specified an analytical method for the VOC content of those coatings that cure by chemical reaction. Even then, the announcement continued to allow the manufacturer's formu¬ lation to be used to calculate the VOC content but specified that the analytical technique, RM-24, would be the reference in any conflict betveen the two. During 1981 and 1982, as more State and Federal regulations were established, the demand for low-solvent coatings began a continuing increase in the sales volume of reaction-cure coatings. There was some concern voiced by the industry in how appropriate the reference method was for these type coatings. To find out, the Agency began a review of RM-24 to determine the effect of temperature and exposure time on the indicated VOC "content". It was concluded that the maximum effect of those time-temperature combinations that were examined amounted to only about a 10 percent variation. Somewhat more surprising was that the solvent sometimes accounted for only 50 to 70 percent of the total VOC measured by the reference method. The obvious conclusion was that RM-24 is a better measure of the total organics freed by a coating than is the solvent. This manual implements a policy based on that conclusion. Certification of VOC content on the attached Data Sheets must be based on an analysis using RM-24. No longer will solvent content be permitted as a surrogate for VOC unless a showing is first made that its use is a reasonable alter¬ native or equivalent method of determining the VOC content of that particular coating. One final comment. Since VOC is not always synonomous with solvent, it follows that the amount of solids in a coating cannot be obtained by subtracting the solvent from the total volume of coating. The original Federal Register proposal for RM-24, published on October 3, 1980, recom¬ mended the American Society of Test Materials test Number D2697 as the appropriate method of determining solids content. Subsequent comments from the industry maintained that this test is unreliable. As a result, when promulgated in 1980, RM-24 specified that the solids content of a coating can be obtained only from the manufacturer's formulation of the coating. Dennis Crumpler December 14, 1984 IV TABLE OF CONTENTS CHAPTER Page PREFACE.iii GLOSSARY OF TERMS AND SYMBOLS.vi 1 INTRODUCTION . 1-1 2 -VOC CONTENT OF PAINT, INK, AND OTHER COATINGS "AS SUPPLIED" BY THE COATING MANUFACTURER . II-l 2.1 VOC DATA SHEET FOR “AS SUPPLIED" COATINGS .... 11-2 2.2 IMPLEMENTING INSTRUCTIONS . II-3 3 VOC CONTENT OF PAINT, INK AND OTHER COATINGS “AS APPLIED" TO THE SUBSTRATE BY THE USER.III-l 3.1 VOC DATA SHEET FOR “AS APPLIED" COATINGS.II1-2 3.2 IMPLEMENTING INSTRUCTIONS.. . III-4 v 53 ' ■ ■ ■ * ■ . GLOSSARY OF TERMS "As Applied" the condition of a coating after dilution by the user just prior to application to the substrate. "As Supplied" the condition of a coating before dilution, as sold ana delivered by the coating manufacturer to the user. (D c )a coating density "as applied" •* • coating density, "as supplied" t>d density of dilution solvent V density of organic solvent/water mixture “w density of water (8.33 Ib/gal) ^d dilution solvent ratio, equals the volume of VOC added per unit volume of coating "as supplied" R ^ K d equals the volume of premixed water and VUC added per unit volume of coating "as supplied" ( v n^a Volume percent solids of coating "as applied" ^n^s Volume percent solids of coating "as supplied" (VOC) a VOC content of "as applied" coating, expressed as mass of VOC per unit volume of coating less water or as mass of VUC per unit volume of solids (VOC) s VOC content of "as supplied" coating, expressed as mass of VOC per unit volume of coating less water or as mass of VOC per unit volume of solids (V w )a tne water content, in volume percent, of coating "as applied" the water content, in volume percent, of the dilution solvent added to the "as supplied" coating (V w ) s the water content, in volume percent, of the coating "as supplied" ( w o^a the organic volatile content, in weight percent, of the coating "as applied" (w 0 ) s the organic volatile content, in weight percent, of the coating "as supplied" vi 54 (w v ) a (W v )s ^w)a (V/ W )d (^w^s the weight percent of total volatiles in the coating "as applied" the weight percent of total volatiles in the coating "as supplied" the weight percent water in the coating "as applied" the weight percent water in the dilution solvent the weight percent water in the coating "as supplied" vn 1. INTRODUCTION This Manual provides step-by-step instruction for preparation of two data sheets developed by the Environmental Protection Agency which may be used by coating manufacturers and users to present information on the quantity of volatile organic compounds* (VOC) emitted from a coating. One of the data sheets may be prepared by the manufacturer of the coating; the second would be used by the company that applies the coating to a substrate. The first VOC data sheet, which would be prepared by the manufacturer, provides information on the volatile organic content of a coating as it is delivered to a customer. This is referred to as the VOC content of the coating "as supplied" (by the manufacturer to the user). The second VOC data sheet, which would be prepared by the user or coater, provides information on the quantity of volatile organic compounds present as the coating is used or applied to the substrate and includes the effect of any dilution solvent added before application. This is referred to as the VOC content of the coating "as applied" (to the substrate). The coating user may submit, and the Agency enforcing a regulation may accept, these data sheets as prima facie evidence of the actual VOC content of a coating. The referee method for ultimate determination of compliance, however, will continue to be the method specified in the applicable regula¬ tion (for example, LPA Reference Method 24 or individual AbTM methods). ^Volatile Organic Compound (VOC) - Any organic compound which participates in atmospheric photochemical reactions; that is, any organic compound other than those which the Administrator designates as having negligible photochemical reactivity. VOC may be measured by a reference method, an equivalent method, an alternative method, or by procedures specified under any regulation. 1-1 * 56 v .(1-a J 5 i C t. UZ 06 • t' a 1 00 . ■ . 2. YOC CONTENT OF PAINT, INK AND OTHER COATINGS “AS SUPPLIED" BY THE COATING MANUFACTURER TO THE USER II-l 57 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY VOC DATA SHEET : PROPERTIES OF THE COATING "AS SUPPLIED" BY THE MANUFACTURER Coating Manufacturer:_ Coating Identification: Batch Identification:_ Supplied To:_ Properties of the coating as supplied! to the customer: A. Coating Density (D c ) s : _lb/gal / 7 ASTM D147b / J 0ther2 F. kg/1 B. Total Volatiles (W v ) s : _ / J A3TM D2359 / J 0tner2 C. Water Content: 1. (W w ) s / 7 ASTM D3792 / ASTM D4017 ’Weight Percent Weight Percent / 7 0ther2 2. (V w ) s _ / / Calculated / / 0ther2 u. Organic Volatiles (w 0 ) s : _ Volume Percent Nonvolatiles Content (V n ) s : VOC Content (VOC) s : 1. _ JWeight Percent Volume Percent lb/gal coating less water or kg/1 coating less water 2 . lb/gal solids Remarks: (use reverse side) or kg/1 solids lThe subscript "s" denotes each value is for the coating "as supplied" by the manufacturer. ^Explain the other method used under "Remarks". Signed:_ 4 _Date_ 58 11-2 ' 2.2 IMPLEMENTING INSTRUCTIONS FOR THE VOC DATA SHEET FOR "AS SUPPLIED" COATINGS This DATA SHEET is normally completed by the coating manufacturer and provided to the userj It will henceforth be referred to as the "AS SUPPLIED" VUC DATA SHEET. A. The "as supplied" coating density, (D c ) s ^, is determined using "ASTM D1475 - Standard Test Method for Density of Paint, Lacquer, and Related Products." B. The weight percent of total volatiles in a coating, (W v ) s , is determined by "aSTM u23b9 - 81 Standard Method for Volatile Content of Coatings." drying conditions to be used are 110°C for 1 hour^. C. Water Content 1. The weight percent water, (W w ) s , is determined by "ASTM D3792 - Standard Test Method for Water Content of Water-Reducible Paints by Direct Injection Into a Gas Chromatograph," or "aSTM U4017 - Standard Test Metnod for Water in Paints and Paint Materials by the Karl Fischer Method."^>4 acceptable alternative to these procedures for purposes of preparing the data sheet would be to calculate the weight percent water from the manufacturer 1 s coating formulation. lEPA's Reference Method 24 (40 C.F.R. Part 60, App. A), contains the ASTM methods referenced in these instructions. ^The subscript "s" denotes those parameters of a coating when measured in the "as supplied" condition, before dilution by the user. 3lf the manufacturer believes a specified method does not give results that are representative of the actual cure mechanism, he may petition the enforcement authority for approval of an alternate analytical method. Any alternate method or alteration to the methods and procedures in these instruc¬ tions or in any applicable regulation would be subject to review and approval by the appropriate State and Federal enforcement agency. ^Volatile compounds classified by EPA as having negligible photochemical reactivity such as 1,1,1-trichloroethane and methylene chloride, etc., and listed as exempt in the applicable Federal and State VOC regulation should be treated in the same manner as water. The weight percent.of negligibly reactive compounds in a coating should be determined from the manufacturer's formulation. The volume percent can then oe calculated using equation II-l when the weight percent and density of the negligibly reactive compounds are substituted for those of water. The weight dnd volume percent can be used in Equations 11-2 and 11-6, respectively, in place of (W w ) s and (V w ) s . 11-3 * 59 II-l 2 . The water content, in volume percent, (V w ) s , can be calculated by the equation: (V w ) s = where D w < w wWs, is the density of water, 8.33 Ibs/gal. D. The organic volatiles content, (W 0 ) s , i.e., the VOC content expressed as a percent by weight, is determined by the following equation^: (W 0 ) s = (W v ) s - (W w ) s II-2 & If the coating contains no water the weight percent of organic volatiles is equal to the weight percent of total volatiles. In other words: (W w ) s = 0 and (W 0 >s = (w v ) s I1-3 E. The volume percent solids (nonvolatiles), (V n ) s , should be derived from the coating formulation using the following equation: P (Y n )s = L (Y n ) s 1-1 1 11-4 where (V n ) 5 denotes the volume percent of each 1 nonvolatile component in an "as supplied" coating, and "p" is the number of nonvolatile components in that coating. (Also see Footnote 1, Pg. I1-3.) 5 The precision limit adjustments permitted by Reference Method 24 for exDerimentally determined mean W w and W v values may be made only by enrorcement agencies ror determination of compliance. The adjustment is not to De used for the purposes of completing the "AS SUPPLIED" WcTData SHEET. 11-4 t 60 F. The VOC content of the "as supplied" coating (YOC) s can now be calculated and thereby expressed in terms used by most State or Federal regulations. 1. The mass of VOC per unit volume of coating less water: a. If the coating contains no water, the equation is calculated as follows: , % (WJ- (D r )_ vnr = 0 s c s lYUU s —runs— 11-5 b. If the coating contains water. Equation 11-5 becomes: , . (VL). (D r ). rvnM - o s c 5 1 UUs im - rv w ) s 11-6 2. The VOC content may also be calculated in terms of mass of VOC per unit volume of solids (nonvolatiles). For both solvent-borne and waterborne coatings, the equation is: (Wj. {VOC) s = _ 0 s (°c>s 11-7 The subscript "a" denotes each value is for the coating "as applied" to the substrate. ^Explain the other method used under "Remarks" on reverse side ^The subscript "d" denotes values are for the dilution solvent 111-2 63 E. F. G. H. Dilution Solvent Ratio (R 3792 - Standard Test Method for Water Content of Water-Reducible Paints by Direct Injection Into a Gas Chromatograph," or "ASTM D4017 - Standard Test Method for Water in Paints and Paint Materials by the Karl Fischer Method." (Also see Footnote 3, Pg. III-4.) The water content, in volume percent, (V w ) a , can be calculated by the equation*. (V w >. ^w^a < D c>a u w I1I-1 where u w is the density of water, 8.33 lb/gal. ^Volatile compounds'classified by EPA as having negligible photochemical reactivity such as 1,1,1-trichloroethane and methylene chloride, etc., and listed as exempt in the applicable Federal and State VuC regulation, should be treated in the same manner as water. The weight percent of negligibly reactive compounds in the dilution’solvent must be known either from the coater's mixing records or the. dilution solvent supplier's formulation. The volume percent can then be calculated using Equations 1II—1 or II1-5 when the weight percent and density of the negligibly reactive organics are suostituted for those of water. The weight and volume percent of the negligibly reactive compounds can be substituted in all equations where the weight and volume percent water, (W w ) and (V w ), respectively, are used. ^The precision limit adjustments permitted by Reference Method 24 for experimentally determined mean weight percent water and total volatiles, W w and w v respectively, may be maoe only by enforcement agencies for determination of compliance. The adjustment is not to be used for the purposes of completing the "AS APPLIED" VUC DATA SntET. . 111-5 D. If the dilution solvent consists of a single compound the density may be obtained from the literature. If the dilution solvent is a mixture of organic compounds, the density, D d b , can be determined analytically via ASTM ul475, or an average density can be estimated from the solvent formulation as shown oelow. This estimation assumes that volumes are additive. 100% E j=i or m i E v j u j Tuuto j = i 111-2 111-3 where: 0j, Wj, and Vj denote the density, weight percent, and volume percent ot each solvent in the dilution solvent mixture and "m" is the number of organic solvents in the dilution solvent mixture. If the dilution solvent is a mixture of photocnemically reactive organics and water, the coater must know the weight percent, (W w )^, or volume percent, (V w ), of water from his mixing records or the supplier's formulation, or .he must analytically determine the weight fraction of water in the dilution solvent using aSTH D3792 or AS I'M D4017. The density, Ua l“c'a * “V 111-6 R d = b. When the dilution solvent is a mixture of water and photochemically reactive organic solvent. Equation Ii1-6 may be expressed as: (D c ) s - ^c^a