Tenn. Comp. R. & Regs. 1200-03-16-.34 - AUTOMOBILE AND LIGHT DUTY TRUCK SURFACE COATING OPERATIONS

(1) Applicability.
(a) The provisions of this rule apply to the following affected facilities in an automobile or light-duty truck assembly plant: each prime coat operation, each guide coat operation, and each topcoat operation.
(b) Exempted from the provisions of this rule are operations used to coat plastic body components or all-plastic automobile or light-duty truck bodies on separate coating lines. The attachment of plastic body parts to a metal body before the body is coated does not cause the metal body coating operation to be exempted.
(c) The provisions of this rule apply to any affected facility identified in subparagraph (a) of this paragraph that begins construction, reconstruction, or modification after November 6, 1988.
(2) Definitions and Abbreviations
(a) Definitions:
1. "Applied coating solids" means the volume of dried or cured coating solids which is deposited and remains on the surface of the automobile or light-duty truck body.
2. "Automobile" means a motor vehicle capable of carrying no more than 12 passengers. "Motor vehicle" for the purposes of this rule means every vehicle which is self propelled excluding motorized bicycles and every vehicle which is not propelled by electric power obtained from overhead trolley wires. The words "motor vehicle" shall not mean any mobile home or house trailer.
3. "Automobile and light-duty truck body" means the exterior surface of an automobile or light-duty truck including hoods, fenders, cargo boxes, doors, and grill opening panels.
4. "Bake oven" means a device that uses heat to dry or cure coatings.
5. "Electrodeposition (EDP)" means a method of applying a prime coat by which the automobile or light-duty truck body is submerged in a tank filled with coating material and an electrical field is used to effect the deposition of the coating material on the body.
6. "Electrostatic spray application" means a spray application method that uses an electrical potential to increase the transfer efficiency of the coating solids. Electrostatic spray application can be used for prime coat, guide coat, or topcoat operations.
7. "Flash-off area" means the structure on automobile and light-duty truck assembly lines between the coating application system (dip tank or spray booth) and the bake oven.
8. "Guide coat operation" means the guide coat spray booth, flash-off area and bake oven(s) which are used to apply and dry or cure a surface coating between the prime coat and topcoat operation on the components of automobile and light-duty truck bodies.
9. "Light-duty truck" means any motor vehicle rated at 3,850 kilograms gross vehicle weight or less, designed mainly to transport property.
10. "Plastic body" means an automobile or light-duty truck body constructed of synthetic organic material.
11. "Plastic body component" means any component of an automobile or light-duty truck exterior surface constructed of synthetic organic material.
12. "Prime coat operation" means the prime coat spray booth or dip tank, flash-off area, and bake oven(s) which are used to apply and dry or cure the initial coating on components of automobile or light-duty truck bodies.
13. "Purge" or "line purge" means the coating material expelled from the spray system when clearing it.
14. "Solvent-borne" means a coating which contains five percent or less water by weight in its volatile fraction.
15. "Spray application" means a method of applying coatings by atomizing the coating material and directing the atomized material toward the part to be coated. Spray applications can be used for prime coat, guide coat, and topcoat operations.
16. "Spray booth" means a structure housing automatic or manual spray application equipment where prime coat, guide coat, or topcoat is applied to components of automobile or light-duty truck bodies.
17. "Surface coating operation" means any prime coat, guide coat, or topcoat operation on an automobile or light-duty truck surface coating line.
18. "Topcoat operation" means the topcoat spray booth, flash-off area, and bake oven(s) which are used to apply and dry or cure the final coating(s) on components of automobile and light-duty truck bodies.
19. "Transfer efficiency" means the ratio of the amount of coating solids transferred onto the surface of a part or product to the total amount of coating solids used.
20. "VOC content" means all volatile organic compounds that are in a coating expressed as kilograms of VOC per liter (pounds per gallon) of coating solids.
21. "Waterborne" or "water reducible" means a coating which contains more than five weight percent water in its volatile fraction.
(b) Abbreviations:
1. Caj = concentration of VOC (as carbon) in the effluent gas flowing through stack (j) leaving the control device (parts per million by volume).
2. Cbi = concentration of VOC (as carbon) in the effluent gas flowing through stack (i ) entering the control device (parts per million by volume).
3. Cfk = concentration of VOC (as carbon) in the effluent gas flowing through exhaust stack (k) not entering the control device (parts per million by volume).
4. Dci = density of each coating (i) as received (kilograms per liter) (pounds per

gallon).

5. Ddj = density of each type VOC dilution solvent (j) added to the coatings, as received (kilograms per liter or pounds per gallon).
6. Dr = density of VOC recovered from an affected facility (kilograms per liter or pounds per gallon).
7. E = VOC destruction efficiency of the control device.
8. F = fraction of total VOC which is emitted by an affected facility that enters the control device.
9. G = volume weighted average mass of VOC per volume of applied solids (kilograms per liter or pounds per gallon) .
10. Lci = volume of each coating (i) consumed, as received (liters or gallons).
11. Lcil = volume of each coating (i) consumed by each application method (l), as received (liters or gallons).
12. Ldj = volume of each type VOC dilution solvent (j) added to the coatings, as received (liters or gallons).
13. Lr = volume of VOC recovered from an affected facility (liters or gallons).
14. Ls = volume of solids in coatings consumed (liters or gallons).
15. Md = total mass of VOC in dilution solvent (kilograms or pounds).
16. Mo = total mass of VOC in coatings as received (kilograms or pounds).
17. Mr = total mass of VOC recovered from an affected facility (kilograms or pounds).
18. N = volume weighted average mass of VOC per volume of applied coating solids after the control device kilograms of VOC or pounds of VOC liter of applied solids(gallon of applied solids)
19. Qaj = volumetric flow rate of the effluent gas flowing through stack (j) leaving the control device (dry standard cubic meters (feet) per hour).
20. Qbi = volumetric flow rate of the effluent gas flowing through stack (i) entering the control device (dry standard cubic meters (feet) per hour).
21. Qfk = volumetric flow rate of the effluent gas flowing through exhaust stack (k) not entering the control device (dry standard cubic meters (feet) per hour).
22. T = overall transfer efficiency.
23. Tl = transfer efficiency for application method (l).
24. Vsi = proportion of solids by volume in each coating (i) as received liter solids or gallons of solids liter coating gallons of coating , and
25. Woi = proportion of VOC by weight in each coating (i), as received kilograms VOC or pounds VOC kilograms coating pounds coating
(3) Standards for volatile organic compounds.

On and after the date on which the initial performance test required by 1200-3-16-.01(5) is completed, no owner or operator subject to the provisions of this rule shall discharge or cause the discharge into the atmosphere from any affected facility VOC emissions in excess of:

(a) 0.16 kilograms of VOC per liter (1.34 pounds of VOC per gallon) of applied coating solids of each prime coat operation.
(b) 1.40 kilograms of VOC per liter (11.69 pounds of VOC per gallon) of applied coating solids from each guide coat operation.
(c) 1.47 kilograms of VOC per liter (12.28 pounds of VOC per gallon) of applied coating solids from each topcoat operation.
(4) Performance test and compliance provisions.
(a) Subparagraphs 1200-3-16-.01(5)(d) and (f) do not apply to the performance test procedures required by this paragraph.
(b) The owner or operator of an affected facility shall conduct an initial performance test in accordance with 1200-3-16-.01(5)(a) and thereafter for each calendar month for each affected facility according to the procedures in this paragraph.
(c) The owner or operator shall use the following procedures for determining the monthly volume weighted average mass of VOC emitted per volume of applied coating solids.
1. The owner or operator shall use the following procedures for each affected facility which does not use a capture system and a control device to comply with the applicable emission limit specified under paragraph (3) of this rule.
(i) Calculate the volume weighted average mass of VOC per volume of applied coating solids for each calendar month for each affected facility. The owner or operator shall determine the composition of the coatings by formulation data supplied by the manufacturer of the coating or from data determined by an analysis of each coating, as received, by Reference Method 24, as specified in 1200-3-16-.01(5)(g) 24. The Technical Secretary may require the owner or operator who uses formulation data supplied by the manufacturer of the coating to determine data used in the calculation of the VOC content of coatings by Reference Method 24, as specified in 1200-3- 16-.01(5)(g)24 or an equivalent or alternative method. The owner or operator shall determine from company records on a monthly basis the volume of coating consumed, as received, and the mass of solvent used for thinning purposes. The volume weighted average of the total mass of VOC per volume of coating solids used each calendar month will be determined by the following procedures.
(I) Calculate the mass of VOC used in each calendar month for each affected facility by the following equation where "n" is the total number of coatings used and "m" is the total number of VOC solvents used:

Click to view Image

(SUM LdjDdj will be zero if no VOC solvent is added to the coatings, as received).

(II) Calculate the total volume of coating solids used in each calendar month for each affected facility by the following equation where "n" is the total number of coatings used:

Click to view Image

(III) Select the appropriate transfer efficiency (T) from the following tables for each surface coating operation:

Application Method Transfer efficiency
Air Atomized Spray (waterborne coating). 0.39
Air Atomized Spray (solvent-borne coating). 0.50
Manual Electrostatic Spray. 0.75
Automatic Electrostatic Spray. 0.95
Electrodeposition. 1.00

The values in the table above represent an overall system efficiency which includes a total capture of purge. If a spray system uses line purging after each vehicle and does not collect any of the purge material, the following table shall be used:

Application Method Transfer efficiency
Air Atomized Spray (waterborne coating). 0.30
Air Atomized Spray (solvent-borne coating). 0.40
Manual Electrostatic Spray. 0.62
Automatic Electrostatic Spray. 0.75

In lieu of using the values listed above for transfer efficiencies, any owner or operator may petition the Board for use of a different transfer efficiency based on scientific evidence that the proposed values are more correct than those listed above for their sources. Prior to any approval by the Board, a public hearing shall be held to allow input from the public. If the petition is granted, the approved values shall be included on any permit issued to the source and shall serve in lieu of those listed above.

I. When more than one application method (l) is used on an individual surface coating operation, the owner or operator shall perform an analysis to determine an average transfer efficiency by the following equation where "n" is the total number of coatings used and "p" is the total number of application methods:

Click to view Image

(IV) Calculate the volume solids weighted average mass of VOC per volume of applied coating solids (G) during each calendar month for each affected facility by the following procedures:
I. For prime coat operations, use the following procedure: G is equal to the sum of (Mo + Md) for 6 out of 7 most recent calendar months of normal operation divided by the respective sum of (LsT).
II. For guide coat and topcoat operations, use the following equation:

Click to view Image

(ii) If the volume weighted average mass of VOC per volume of applied coating solids (G), calculated on a calendar month basis, is less than or equal to the applicable emission limit specified in paragraph (3) of this rule, the affected facility is in compliance. Each monthly calculation is a performance test for the purpose of this rule.
2. The owner or operator shall use the following procedures for each affected facility which uses a capture system and a control device that destroys VOC (e.g., incinerator) to comply with the applicable emission limits specified under paragraph (3) of this rule.
(i) Calculate the volume weighted average mass of VOC per volume of applied coating solids (G) during each calendar month for each affected facility as described under subpart (4)(c)1(i) of this rule.
(ii) Calculate the volume weighted average mass of VOC per volume of applied solids emitted after the control device, by the following equation:

N=G(1-FE)

(I) Determine the fraction of total VOC which is emitted by an affected facility that enters the control device by using the following equation where "n" is the total number of stacks entering the control device and "p" is the total number of stacks not connected to the control device:

Click to view Image

In lieu of using the method above, any owner or operator may petition the Board for use of a different method based on scientific evidence that the proposed method is more correct than that method above for their sources. Prior to any approval by the Board, a public hearing shall be held to allow input from the public. If the petition is granted, the approved method shall be included on any permit issued to the source and shall serve in lieu of the method above.

I. In subsequent months, the owner or operator shall use the most recently determined capture fraction for the performance test.
(II) Determines the destruction efficiency of the control device using values of the volumetric flow rate of the gas streams and the VOC content (as carbon) of each of the gas streams in and out of the device by the following equation where "n" is the total number of stacks entering the control device and "m" is the total number of stacks leaving the control device:

Click to view Image

I. In subsequent months, the owner or operator shall use the most recently determined VOC destruction efficiency for the performance test.
(III) If an emission control device controls the emissions from more than one affected facility, the owner or operator shall measure the VOC concentration (Cbi) in the effluent gas entering the control device (in parts per million by volume) and the volumetric flow rate (Qbi) of the effluent gas (in dry standard cubic meters per hour) entering the device through each stack. The destruction or removal efficiency determined using these data shall be applied to each affected facility served by the control device.
(iii) If the volume weighted average mass of VOC per volume of applied solids emitted after the control device (N) calculated on a calendar month basis is less than or equal to the applicable emission limit specified in paragraph (3) of this rule, the affected facility is in compliance. Each monthly calculation is a performance test for the purposes of this rule.
3. The owner or operator shall use the following procedures for each affected facility which uses a capture system and a control device that recovers the VOC (e.g., carbon adsorber) to comply with the applicable emission limit specified under paragraph (3) of this rule.
(i) Calculate the mass of VOC (Mo+ Md) used during each calendar month for each affected facility as described under subpart (4)(c)1(i) of this rule.
(ii) Calculate the total volume of coating solids (Ls) used in each calendar month for each affected facility as described under subpart (4)(c)1(i) of this rule.
(iii) Calculate the mass of VOC recovered (Mr) each calendar month for each affected facility by the following equation: Mr = LrDr
(iv) Calculate the volume weighted average mass of VOC per volume of applied coating solids emitted after the control device during a calendar month by the following equation:

Click to view Image

(v) If the volume weighted average mass of VOC per volume of applied solids emitted after the control device (N) calculated on a calendar month basis is less than or equal to the applicable emission limit specified in paragraph (3) of this rule, the affected facility is in compliance. Each monthly calculation is a performance test for the purposes of this rule.
(5) Monitoring of emissions and operations.

The owner or operator of an affected facility which uses an incinerator to comply with the emission limits specified under paragraph (3) of this rule shall install, calibrate, maintain, and operate temperature measurement devices as prescribed below:

(a) Where thermal incineration is used, a temperature measurement device shall be installed in the firebox. Where catalytic incineration is used, a temperature measurement device shall be installed in the gas stream immediately before and after the catalyst bed.
(b) Each temperature measurement device shall be installed, calibrated, and maintained according to accepted practice and the manufacturer's specifications. The device shall have an accuracy of the greater of ± 0.75 percent of the temperature being measured expressed in degrees Celsius or ±2.5°C.
(c) Each temperature measurement device shall be equipped with a recording device so that a permanent record is produced.
(6) Reporting and recordkeeping requirements.
(a) Each owner or operator of an affected facility shall include the data outlined in parts 1. and 2. of this subparagraph in the initial compliance report required by 1200-3-16 - .01(5).
1. The owner or operator shall report the volume weighted average mass of VOC per volume of applied coating solids for each affected facility.
2. Where compliance is achieved through the use of incineration, the owner or operator shall include the following additional data in the control device initial performance test required by 1200-3-16-.01(5)(a) or subsequent performance tests at which destruction efficiency is determined: the combustion temperature (or the gas temperature upstream and downstream of the catalyst bed), the total mass of VOC per volume of applied coating solids before and after the incinerator, capture efficiency, the destruction efficiency of the incinerator used to attain compliance with the applicable emission limit specified in paragraph (3) of this rule and a description of the method used to establish the fraction of the VOC captured and sent to the control device.
(b) Following the initial report, each owner or operator shall report the volume weighted average mass of VOC per volume of applied coating solids for each affected facility during each calendar month in which the affected facility is not in compliance with the applicable emission limit specified in paragraph (3) of this rule. This report shall be postmarked not later than ten days after the end of the calendar month that the affected facility is not in compliance. Where compliance is achieved through the use of a capture system and control device, the volume weighted average after the control device should be reported.
(c) Where compliance with paragraph (3) of this rule is achieved through the use of incineration, the owner or operator shall continuously record the incinerator combustion temperature during coating operations for thermal incineration or the gas temperature upstream and downstream of the incinerator catalyst bed during coating operations for catalytic incineration. The owner or operator shall report quarterly as defined below.
1. For thermal incinerators, every three-hour period shall be reported during which the average temperature measured is more than 28°C less than the average temperature during the most recent control device performance test at which the destruction efficiency was determined as specified under paragraph (3) of this rule. Readings should be taken a minimum of one (1) every fifteen (15) minutes within the specified three-hour period.
2. For catalytic incinerators, every three-hour period shall be reported during which the average temperature immediately before the catalyst bed, when the coating system is operational, is more than 28°C less than the average temperature immediately before the catalyst bed during the most recent control device performance test at which destruction efficiency was determined as specified under paragraph (4) of this rule. In addition, every three-hour period shall be reported each quarter during which the average temperature difference across the catalyst bed when the coating system is operational is less than 80 percent of the average temperature difference of the device during the most recent control device performance test at which destruction efficiency was determined as specified under paragraph (4) of this rule. Readings should be taken a minimum of one (1) every fifteen (15) minutes within the specified three-hour period.
3. For thermal and catalytic incinerators, if no such periods occur, the owner or operator shall submit a negative report.
(d) The owner or operator shall notify the Technical Secretary 30 days in advance of any test by Reference Method 25 as specified in 1200-3-16-.01(5)(g) 25.
(7) Reference methods and procedures.
(a) The reference methods in 1200-3-16-.01(5)(g) shall be used to conduct performance tests.
1. Reference Method 24 as specified 1200-3-16-.01(5)(g) 24. or an equivalent or an alternative method approved by the Technical Secretary shall be used for the determination of the data used in the calculation of the VOC content of the coatings used for each affected facility. Manufacturers' formulation data is approved by the Technical Secretary as an alternative method to Method 24. In the event of dispute, Reference Method 24 shall be the referee method.
2. Reference Method 25 as specified in 1200-3-16-.01(5)(g) 25 or an equivalent or alternative method approved by the Technical Secretary shall be used for the determination of the VOC concentration in the effluent gas entering and leaving the emission control device for each stack equipped with an emission control device and in the effluent gas leaving each stack not equipped with a control device.
3. The following methods shall be used to determine the volumetric flow rate in the effluent gas in a stack:
(i) Method 1 as specified in 1200-3-16-.01(5)(g) 1. for sample and velocity traverses.
(ii) Method 2 as specified in 1200-3-16-.01(5)(g) 2. for velocity and volumetric flow rate.
(iii) Method 3 as specified in 1200-3-16-.01(5)(g) 3. for gas analysis, and
(iv) Method 4 as specified in 1200-3-16-.01(5)(g) 4 for stack gas moisture.
(b) For reference Method 24, the coating sample must be a 1-liter sample taken in a 1-liter container.
(c) For Reference Method 25, the sampling time for each of three runs must be at least one hour. The minimum sample volume must be 0.003 dscm except that shorter sampling times or smaller volumes, when necessitated by process variables or other factors, may be approved by the Technical Secretary. The Technical Secretary will approve the sampling of representative stacks on a case-by-case basis if the owner or operator can demonstrate to the satisfaction of the Technical Secretary that the testing of representative stacks would yield results comparable to those that would be obtained by testing all stacks.
(8) Modifications.

The following physical or operational changes are not by themselves, considered modifications of existing facilities:

(a) Changes as a result of model year changeovers or switches to larger cars.
(b) Changes in the application of the coatings to increase coating film thickness.

Notes

Tenn. Comp. R. & Regs. 1200-03-16-.34
Original rule filed September 21, 1988; effective November 6, 1988.

Authority: T.C.A. §§ 68-25-105 and 4-5-202.

State regulations are updated quarterly; we currently have two versions available. Below is a comparison between our most recent version and the prior quarterly release. More comparison features will be added as we have more versions to compare.


No prior version found.