April 25, 1988 LAER Emission Limits
for Automobile and Light-Duty Truck Topcoat Operations 26.4

26.4

MEMORANDUM
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SUBJECT: LAER Emission Limits for Automobile and Light-Duty Truck Topcoat Operations

FROM: Jack R. Farmer, Director Emission Standards Division (MD-13)

TO: See Below

At the March Air Directors' meeting in Seattle, Washington, some questions were raised concerning the Agency's current position regarding Lowest Achievable Emission Rate (LAER) emission limits for automobile and light-duty truck topcoat operations. This memorandum describes our position on this issue.

The LAER emission limit for automobile and light-duty truck topcoat operations should be at least as stringent as 12.26 pounds of volatile organic compound (VOC) per gallon of solids deposited with compliance on a daily basis using actual measured transfer efficiency values. This limit should apply regardless of the material of construction (substrate) of the vehicles being coated (e.g. metal, plastic or combination.)

The basis for citing this emission limit as LAER is the permit (see attachment) for Subaru/Isuzu in Lafayette, Indiana. The permit for Toyota in Georgetown, Kentucky, may also be used to support this limit.

When the industry has argued for less stringent emission limits because of the type of coating or the type of substrate planned, we have maintained that "painting cars is painting cars," and these factors do not justify less stringent emission limits. We have taken this position because technology and manufacturing processes constantly change and evolve; the manufacturer is responsible for ensuring that any new process meets environmental as well as product requirements.

The procedure which we feel is most appropriate for determining compliance with this LAER limit is the protocol which we have been developing in conjunction with the Motor Vehicle Manufacturers Association (MVMA). We met with the MVMA on March 22, 1988, to discuss the draft

protocol. We are making some changes in the protocol based upon the discussion at this meeting. We expect to have the final protocol ready soon. If you have an immediate need to provide a compliance procedure for a topcoat LAER determination, please contact Dave Salman at FTS-629-5417.

Attachment

Addressees:
Irwin Dickstein, Reg VIII
Louis Gitto, Reg I
William Hathaway, Reg VI
David Howekamp, Reg IX
David Kee, Reg V
Thomas Maslany, Reg III
Gary O'Neal, Reg X
Conrad Simon, Reg II
Winston Smith, Reg IV
William Spratlin, Reg VII

cc: Mike Alushin, LE-134A
John Calcagni, MD-15
Jerry Emison, MD-10
Joan LaRock, A-101
John Seitz, EN-341

bcc:
Wayne Aronson, Reg IV
Tom Helms, MD-15
Lars Johnson/Brent Marable, Reg V
Paul Kahn, Reg II
Vishnu Katari, EN-341
Floyd Ledbetter, Reg IV
Nancy Mayer, MD-15
Gary McCutchen, MD-15
Mindy Moore/Lee Hanley, Reg VIII
Bob O'Meara/Tom Elter, Reg I
Bill Repsher, LE-134A
Steve Rosenthal, Region V
Cynthia Stahl, Reg III
David Sullivan/Willie Kelly, Reg VI
Jean Thompson, Reg III
Mary Tietjen, Reg VII
Tim Williamson, Reg I
Bill Wruble/Dennis Beauregard, Reg IX

a new automobile and light duty truck assembly plant at the above location southeast of Lafayette, Indiana, consisting of a stamping shop, body shop, paint shop, and trim and final assembly shop. Emission of air pollutants will occur primarily from metal working operations, surface coating operations and combustion of natural gas.

This permit is issued under provisions of Rule 325 IAC 2-1.1, with findings and conditions listed on the attached pages.

Identification No. PSD (79) 1651

Date Issued July 30, 1989

Expiration Date N/A

Issued by Nancy A. Mobley

[signed]
Commissioner