U.S ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF AIR QUALITY PLANNING & STANDARDS

EMISSION STANDARDS DIVISION

RESEARCH TRIANGLE PARK, NC 27711

COVER SHEET

DATE:	3/26/98

Persons interested in the development of the Large Appliances Integrated Rule

FROM:	Dr. Mohamed Serageldin

VOICE PHONE:	919-541-2379

FAX PHONE:	919-541-5689

e-mail: serageldin.mohamed@ epamail.epa.gov

OFFICE:	U.S ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF AIR QUALITY PLANNING & STANDARDS

EMISSION STANDARDS DIVISION

RESEARCH TRIANGLE PARK, NC 27711

MESSAGE:

RE:	Large Appliances Integrated Rule

Development

Attached is a copy of the industry questionnaire sent to nine Large Appliance companies in June 1997. The questionnaire was an Enclosure to an official letter from EPA requesting the completion of this questionnaire.

LIST OF ENCLOSURES

Enclosure 1	P-MACT/P-BAC Section 114 Facility Questionnaire for Large Appliance Manufacturing Rule Development

Attachments:	Attachment A	Metric Conversion Factors

Attachment B	Figure 1: Example Process Flow Diagram

Attachment C	Example Unit Operation Systems (UOS): Figures 1, 2, 3

Attachment D	Definitions

Enclosure 2	US EPA's Information Gathering Authority

Enclosure 3	Disclosure of Emissions Data Claimed as Confidential Under Sections 110 and 114(c) of the Clean Air Act (CAA)

Enclosure 4	Designation of Authorized Representative

Enclosure 5	Summary of OAQPS Procedures for Safeguarding CAA Confidential Business Information (CBI)

Attachments:	Attachment A	CAA CBI Control Record

Attachment B	Authorization for Access to CAA CBI for Contractor Employees

Appendix A	Section 112 List of Hazardous Air Pollutants

Appendix B	OAQPS Definition of Volatile Organic Compound

ENCLOSURE 1

Includes:

Section 114 Questionnaire

List of conversions for metric units

Cleaning/Pretreatment UOS Figure 1

Coating Preparation UOS Figure 2

Coating Application/Drying UOS Figure 3

List of Definitions Revised 1/27/98

P-MACT/P-BAC Facility Questionnaire

Large Appliance Manufacturing Rule Development

U.S. Environmental Protection Agency

The following questions are intended to assist the U.S. EPA in assessing current practices to reduce emissions of hazardous air pollutant (HAP) and volatile organic compound (VOC) material in large appliance manufacturing operations. Please provide a separate response for each facility owned or operated by your company. For those companies with multiple facilities, data is requested for a minimum of three facilities. The EPA requests that Metric units be used for all data reporting. Attachment A contains factors for converting between English and Metric units. We request that you return the completed information request by July 10, 1997.

A.	General Facility Information

1)	Facility name

2)	Complete address/Contact/Phone number

3)	Name(s) of legal owner/operator

4)	Employment (a - cleaning/pretreatment/coating,

b - all production, c - facility total)

5)	Product(s) manufactured and applicable SIC code(s)

6)	Days/hours of operation

7)	Production rate for each product (average and maximum
completed assemblies per year)

8)	Date of facility construction

B.	Unit Operations

1)	Provide detailed process description and flow diagram of product flow through the plant, clearly indicating cleaning/pretreatment and coating operations and HAP/VOC emission points. Identify specific HAP and VOC where known. An example process flow diagram is included as Attachment B.

2)	Types of pieces coated and substrate material(s) (e.g., aluminum doors and lids, steel cases, etc.)

3)	List of all coatings used [manufacturer, ID number, type, color, density, solids and organic solvent content (% by mass), usage (kg/yr)]

4)	Coating application methods (cross-referenced to manufacturing flow diagram, pieces coated, and specific

coatings used as listed in items B1 through B3). Be	specific -- e.g., electrostatic spray, HVLP, etc.

5)	Are pre-coated blanks or coil used at the facility? If so, what percentage of all the sheet parts (in terms of surface area) are pre-coated?

6)	Describe solid and liquid waste handling procedures at the facility.

C.	Control Measures and Applicable Regulations

1)	What HAP or VOC emission limitations apply to the
facility?

2)	Describe all measures in use to reduce HAP/VOC emissions (coating substitution, process changes, control devices, etc.). For each, list the year implemented and describe the previous scenario and the emission reduction achieved by the measure. Provide the most recent source test results for any control devices. For any pollution prevention program or innovative emission reduction measures implemented (e.g., as part of EPA's 33/50 program or other toxic release reduction initiatives), please describe each measure using the UOS approach described in Section E of this questionnaire.

3)	Describe any measures in effect to minimize waste at the facility.

D.	Other Information

Provide any other information that could help EPA in determining HAP and VOC emissions from large appliance manufacturing facilities and in evaluating the emission reduction measures currently in effect. Although the focus of this survey is large appliances coating operations, indicate the type of collocated sources and estimate as closely as possible the relative overall emissions from any collocated source (e.g., 90 percent from Large Appliances operations and 10 percent from Wood Furniture operations).

For the purpose of identifying and quantifying the possible sources of pollution, a plant (or facility) is considered to consist of several levels of production activity, consisting of departments, which are divided into work areas, which in turn are composed of one or more unit operation systems. Please indicate the percentage of emissions that are covered by each response. A

responder may aggregate emissions from small operations. However, these operations should be identified.

E.	Unit Operation System Diagrams

Emissions and material use data are being collected using the unit operation system (UOS) approach.1 The term UOS refers to a formalized concept for performing a material balance. A unit operation system means the ensemble on which the material balance is performed. If the purpose of the material balance is to determine emissions due to the coating of metal parts, for example, it encompasses all possible points and sources leading to evaporative emission losses associated with each primary unit operation, including losses during coating application, flashoff from the part itself, and from the oven or final drying area.

Attached are examples of several potential UOS's (Attachment C). Figure 1 reflects a metal cleaning and pretreatment operation, Figure 2 shows coating preparation, and Figure 3 shows coating application and drying. We have developed these generic figures to the best of our ability, realizing that individual facilities have a range of production approaches. Please modify these example UOS diagrams (or create new diagrams as necessary) to reflect the actual HAP- or VOC-emitting processes at the facility. For each UOS, indicate the time rate of both HAP and VOC entering and leaving the UOS (e.g., kg/hr), as well as the coating coverage rate (e.g., m2/hr). In the examples, F and L reflect liquid or solid materials, while V indicates volatile emissions. For the purpose of responding to this questionnaire, please apportion the total emissions among the individual volatile emission points to the best of your ability.

Provide one diagram for each separate UOS at the facility. For the metal cleaning/pretreatment operation, prepare a separate HAP/VOC diagram for each tank or stage of the entire process (i.e., separate diagrams for cleaning, water rinse, surface etching, etc.). Operations or individual stages of an operation with no HAP or VOC emissions should be indicated on the overall facility process diagram, but they do not need a UOS diagram.

Definitions of several terms are included in Attachment D.

CONVERSION FACTORS FOR METRIC UNITS

In keeping with U.S. Environmental Protection Agency policy, metric units should be used in your response. These units may be converted to common English units by using the following conversion factors:

Metric Unit	Metric Name	Equivalent English Unit
1 m	meter	3.2808 ft (feet)
2.54 cm	centimeter	1 in. (inch)
0.0283 m3	cubic meter	1 ft3 (cubic foot)
liter	liter	0.0353 ft3
dscm	dry standard cubic meter	35.31 dry standard ft3
scmm	standard cubic meters per minute	35.31 ft3/min
kg	kilogram (103 grams)	2.2046 lb (pound)
Mg	megagram (106 grams)	2,204.6 lb
metric ton	metric ton (106 grams)	2,204.6 lb
1 m3	cubic meter	264.17 gallons
3.785 liters	liters	1 gallon
1.054 kJ	kilojoule	1 Btu (British Thermal Unit)
1.054 X 106 kJ	kilojoule	MMBtu
3514 J/s	Joules per second	1 ton (or 12,000 Btu/hr)
16.02 kg/m3	kilograms per cubic meter	1 lb/ft3 (pounds/cubic foot)

T (°F) = temperature in degrees Fahrenheit

T (°C) = temperature in degrees Celsius or degrees Centigrade

Temperature in degrees Celsius (C°) can be converted to temperature in degrees Fahrenheit (°F) by the following formula:

T (°F)	=	1.8 T (°C) + 32

Temperature in degrees Fahrenheit (°F) can be converted to temperature in degrees Celsius (C°) by the following formula:

T (°C)	=	[T (°F) - 32]/1.8

The following definitions (Revised 1/27/98) are provided for many of the key terms used within the Industry Description Memorandum and other memoranda to follow, as well as P-MACT/P- BAC:

Abatement or recovery device--See Add-on control device.

Add-on control device--An air pollution control device installed at the end of a process vent exhaust stack or stacks that reduces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent recovery. Examples are incinerators, condensers, carbon adsorbers, and bioreactor units which reduce the pollution in an exhaust gas. Transfer equipment and ductwork are not considered in and of themselves add-on air pollution control devices. The control device usually does not affect the process being controlled and thus is "add-on" technology as opposed to a scheme to control pollution through making some alteration to the basic process.

Add-on control device efficiency--The ratio of the emissions collected or destroyed by an add-on air pollution control device to the total emissions that are introduced to the control device, expressed as a percentage.

Administrator--The Administrator of the United States Environmental Protection Agency (U.S. EPA) or his or her authorized representative.

Affected facility--With reference to a stationary source, any apparatus to which a standard is applicable. Any operation or process line that is subject to a regulation or standard.

Alternative method--Any method of sampling and analyzing for an air pollutant that is not a reference or equivalent method but has been demonstrated to the Administrator's satisfaction to, in specific cases, produce results adequate for a determination of compliance.

As applied--The condition of a coating at the time of application to the substrate, including any thinning solvent.

As supplied--The condition of a coating before any thinning, as sold and delivered by the coating manufacturer to the user.

BAC--Best Available Controls.

Baseline conditions--The conditions that exist prior to an affected source implementing controls, such as a control system.

Batch--The product of an individual production run of a coating manufacturer's process. A batch may vary in composition from other batches of the same product.

Capture--The containment or recovery of emissions from a process for direction into a duct, which may be exhausted through a stack or sent to an abatement or recovery device before exiting through a stack.

Capture efficiency--The fraction of all organic vapors, HAP emissions, or other pollutants generated by a process that are directed to an add-on air pollution control device expressed as a percentage.

Captured emissions--All emissions that are delivered to a control device.

Capture system--A hood, enclosed room, or other means of collecting organic HAP emissions into a closed-vent system that exhausts to a control device.

Clean Air Act--The Clean Air Act, as amended, provides the foundation for EPA's efforts to improve air quality. The Clean Air Act, building on earlier legislation, was passed in 1970, and was most recently amended in 1990.

Cleaning activity--Physical removal of foreign material from substrate being cleaned. Includes actions such as wiping, brushing, flushing, or spraying applied within an operation.

Cleaning of parts--Solvent engulfs the entire surface of the item (part) as it is dipped in a container of solvent, or the part is cleaned above the container by a cleaning activity such as spraying or wiping. Equipment, the "unit operation," where this might take place, includes part washers, batch-loaded cold cleaners, ultrasonic cleaners, and spray gun washers.

Cleaning operations--Operations, such as, spray-gun, and flush cleaning operations, in which organic solvent is used to remove coating materials or adhesives from equipment used in coating manufacturing operations.

Cleaning solvent--A liquid material used for hand-wipe, spray gun, or flush cleaning. This definition does not include solutions that contain no VOC.

Closed-loop recycling--Reuse or recirculation of a chemical material within the boundaries used to develop a material balance round a "unit operation system." A recovery or reclamation (R or R) unit operation may be within the boundaries selected for the primary unit operation system if it is:

1.	Solely dedicated. The chemical is reused only for cleaning the primary unit operation.

2.	Physically integrated. The R or R operation is connected to the primary unit operation by means of piping, so that it is not possible to perform the

material balance around the primary unit operation system without including it.

Coater or coating applicator--The apparatus used to apply a coating to a continuous base substrate.

Coating--A protective, decorative, or functional film applied as a thin layer to a substrate or surface and which cures to form a continuous solid film (see Primer, Topcoat). This	term often applies to paints such as lacquers or enamels, but also is used to refer to films applied to paper, plastics, or foil.

Coating application--The process by which the coating mix is applied to the base substrate.

Coating application station--The part of a coating operation where the coating is applied. In a spray operation it is the spray booth and is distinguished from the flash off area and oven.

Coating line--Any number or combination of coating applicators, flashoff areas, and ovens which coat a substrate.

Coating operation--Any coater, flash off area, and drying oven located between a base substrate unwind station and a base substrate rewind station that coats a continuous base substrate.

Coating solids--The part of the coating which remains after the coating is dried or cured; solids (nonvolatile) content is determined using data from the EPA Method 24, or an equivalent or alternative method.

Coating station--A work station on which a coating operation is conducted.

Compliant coating--A coating whose volatile organic compound content does not exceed that allowed by regulation. Compliant coatings may be water borne, low solvent (higher solids), or powder.

Continuous coater--A coating system that continuously applies coating materials onto metal parts moving along a conveyor. Coating materials that are not transferred to the part are recycled to a reservoir. Several types of application methods can be used with a continuous coater including spraying, curtain coating, roll coating, dip coating, and flow coating.

Control--In the air pollution field, this means the abatement of pollutants which might be exhausted into the atmosphere. It often refers to the collection or destruction efficiency using various technologies, including incinerators or carbon adsorbers as opposed to capture of the pollutants into the device.

Control device--See Add-on Control Device.

Control Efficiency--See Add-on Control Device Efficiency.

Control system--The combination of capture systems and add-on control devices used to reduce emissions to the atmosphere. For example, 100% capture efficiency and 95% destruction efficiency amounts to 95% control.

Criteria pollutant--A pollutant for which a criteria document has been issued as described by Section 108 of the Clean Air Act. Criteria pollutants are nitrogen oxides,	sulfur dioxides, ozone, particulate matter, and carbon monoxide. A National Ambient Air Quality Standard (NAAQS) exists for each criteria pollutant.

CTG--Control Techniques Guidelines. A series of documents prepared by EPA to assist States in defining reasonable available control technology (RACT) for major sources of volatile organic compounds (VOC) material. The documents provide information on the economic and technological feasibility of available techniques; and, in some cases, suggest limits on VOC emissions.

Cure volatiles--Reaction products which are emitted during the chemical reaction which takes place in some coating films at the cure temperature. These emissions are other than those from the solvents in the coating and may, in some cases, comprise a significant portion of total VOC and/or volatile HAP emissions.

Dip coating--A method of applying a coating in which the substrate is dipped into a tank of coating and then withdrawn.

Electrodeposition--A dip coating method in which an electric field is used to promote the deposition of the coating onto the part. The part being painted acts as the electrode which is oppositely charged from the coating particles in the dip tank.

Electrostatic spray--This is produced when opposite electrical charges are applied to the substrate and the coating. The coating is attracted to the object by the electrostatic potential between them. The coating may be applied by either a spray gun (nonrotational method) or a gun with a rotating bell or disk applicator (rotational method).

Emission control system--A combination of capture system and add-on control device used to reduce emission to the atmosphere. System efficiency is the product of capture efficiency and destruction efficiency (e.g., 95% capture efficiency X 95% destruction efficiency = 90% overall efficiency).

Emission reduction--The decrease in HAP or VOC material emitted when (1) a low solvent containing coating is used in place of a higher solvent containing coating or (2) an add-on control device (such as carbon adsorber or incinerator) is used. Emission reduction is often expressed as a percentage.

Equivalent method--Any method of sampling and analyzing for an air pollutant that has been demonstrated to the Administrator's satisfaction to have a consistent and quantitatively known relationship to the reference method, under specific conditions.

Exempt compounds--Specific organic compounds that are not considered volatile organic compounds due to negligible photochemical reactivity. Exempt compounds are specified in 40 CFR 51.100(s).

Existing source--Any stationary source of air pollution other than a new source.

Face velocity--The velocity of air through a paint spray booth. Where people are working, health regulations usually require this velocity to be at least 30.5 meters per minute (100 feet per minute). When electrostatic spraying is used a face velocity of 18 meters per minute (60 feet per minute) is permitted.

Faraday Cage Effect--A condition that may exist on a substrate due to its geometric configuration that may inhibit the electrostatic application of powder particles at that specific localized area, such as cavities or recesses.

Facility--All contiguous or adjoining property that is under common ownership or control, including properties that are separated only by a road or other public right- of-way.

Film former--The part of a coating that remains on the substrate after the cure (nonvolatiles). Some film formers may be liquid but polymerize to form a solid when coating is baked to the requisite curing temperature.

Film thickness--The thickness of the dry cured coating on the substrate.

Flashoff area--The portion of a coating operation between the coater and the drying oven where solvent begins to evaporate from the coated base substrate.

Floor sweep--A vapor collection duct designed to capture vapors which are heavier than air and which collect along the floor.

Flow coating--A method of applying coating in which the coating is poured onto the part.

Fugitive emissions--Traditionally defined as emissions that do not pass through a stack or duct that allows for their measurement.

Hazardous air pollutant--Any air pollutant listed in or pursuant to Section 112(b) of the Clean Air Act.

Higher-nonvolatiles (solids) coating--Coatings containing a considerably higher solids content than conventional coatings. These coatings typically contain greater than 60 percent solids by volume.

High volume-low pressure (HVLP) spray--Spray equipment that is used to apply
coating by means of a spray gun that operates at 69.0 kPa (10.0 psig) or less of atomizing	air pressure at the air cap.

Hood or enclosure--Devices used to capture emissions and direct them to an abatement or recovery device.

Large appliance--Any product, or part thereof, that is listed under Standard Industrial Classification (SIC) code 3631, 3632, 3633, 3639, 3585, or 3589.

Lower Explosive Limit (LEL)--The concentration of a compound in air below which a flame will not propagate if the mixture is ignited.

LEL meter--A device used to measure the concentration of combustible vapors in an air sample.

Major source--Any source that emits or has the potential to emit, in the aggregate, 9.1 megagrams (10 tons) per year of more of any HAP or 22.7 megagrams (25 tons) per year or more of any combination of HAP material.

Manufacturer's formulation--A list of substances or component parts of coatings as described by the maker of the coatings.

Mass percent solids--The portion of a coating which remains as part of the cured film expressed as percent by weight. This contrasts to another convention of expressing content by volume percent.

Material balance--A calculation based on conservation of mass, i.e., the mass of material going into a process is equal to the mass of material which leaves the process. This relationship is often used to estimate solvent losses from coating operations.

New source--Any stationary source the construction or reconstruction of which commences after a specified date, usually the proposal or promulgation of an applicable standard of performance.

Nonvolatiles (or volume solids)--This term refers to the film-forming material of a coating; also termed solids.

Normally closed container--A container that is closed unless an operator is actively engaged in activities such as emptying or filling the container.

NSPS--New source performance standards, i.e., standards for emission of air pollutants from new, modified or reconstructed stationary emission sources which reflects the	degree of emission limitation achievable through the application of the best system of emission reduction which (taking into account the cost of achieving such reduction) the administrator determines has been adequately demonstrated. The Clean Air Act usually refers to these as standards of performance for new stationary sources.

Permanent total enclosure--A permanently installed enclosure that completely surrounds a source of emissions such that all emissions are captured and contained for discharge through a control device. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-10, Item No. IV-B-1).

Photochemical reactivity--Measure of the rate at which an organic compound reacts in the presence of ultraviolet radiation to form photochemical oxidants.

Pigmented--Containing finely ground insoluble powder dispersed to give a characteristic color.

Pollution prevention--Practices of process changes that decrease or eliminate the creation of emissions (or waste) at the source of pollution (e.g., a paint spray booth). Such prevention techniques include use of new materials, modification of equipment, and changes in work practices that result in emission reductions at the source.

Powder coating--A coating applied as a dry powder which, when baked at sufficiently high temperature, flows out to form a continuous film. Powder coatings may emit VOC/HAP cure volatiles.

Primer--The first layer or layers of identically formulated coating applied to a surface, usually prior to the subsequent application of a topcoat.

Primary heat recovery--A method of conserving energy by using heat from incinerator exhaust gases to preheat the inlet gases to the incinerator.

Process Line--The sum of unit operations that result in the production of individual or groups of products.

Product substitution--Replacement of any product or raw material intended for an intermediate or final use with another. This substitution is a source reduction activity if either the VOC emissions or the quantity of waste generated at the source is reduced.

R or R--Recovery or regeneration unit operation. A device for purifying solvent that may use any of a variety of techniques, including extraction, distillation, filtration, adsorption, or absorption.

RACT--Reasonably Available Control Technology, i.e., the lowest emission limit that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. RACT is usually applied to existing sources in nonattainment areas and in most cases is less stringent than new source performance standards.

Reclaim--A material is processed or regenerated to recover a usable product. (See recycle).

Recovered solvent--Solvent which is extracted from a process or exhaust stream usually by adsorption or condensation.

Recycle--Used, reused, or reclaimed (40 CFR 261.1(b)(7)). A material is "used or reused" if it is employed as an ingredient (including its use as an intermediate) to make a product. For example, when solvent recovered by distillation is reused in the plant.

Reinforce--Touch-up (See Touch-up and repair operation) that is performed prior to
curing of the coating.

Rework--Touch-up (See Touch-up and repair operation) that is performed after the
coated part has been cured.

Secondary heat recovery--Use of heat from an incinerator exhaust for uses within a plant such as heating an oven or a room. This is distinguished from primary heat recovery which is the use of the hot incinerator exhaust gases to heat the inlet gases to the incinerator.

SIC code--Standard Industrial Classification, a numerical identification system developed by the U.S. Government for statistical purposes and widely used by business firms. Industries are grouped into similar categories and each category is given a number representing the category.

Solids--See nonvolatiles or coating solids.

Solvent--A liquid used in a coating to dissolve or disperse constituents and/or to adjust viscosity. It generally evaporates during drying and therefore, does not become a part of the dried film.

Solvent borne coating--Coatings that contain only organic solvents. If water is present, it is only in trace quantities.

Solvent borne coating--Coatings which contains only organic solvents. If water is present, it is only in trace quantifies.

Solvent recovery device--For the purposes of this subpart, an add-on control device in which HAP material is captured rather than destroyed. Examples include carbon adsorption systems and condensers.

Source reduction (or pollution prevention)--Any activity or treatment that reduces or
eliminates the generation of VOC/HAP emissions (or waste) at the source of pollution,	including product substitution or elimination.

Stack--A contained air stream (excluding storage tanks), which is a point through which emissions exit the facility.

Surface coating operation--The application of a film which covers the surface of an object. Painting and varnishing are common surface coating operations as are coatings applied to large appliance, metal furniture, fabric, paper, plastic film and metallic foil.

Surface preparation--The removal of contaminants from the surface of a substrate or component or the activation or reactivation of the surface in preparation for the application of a coating.

Temporary total enclosure--An enclosure that meets the requirements of §63.805(e)(1)(I) through (iv) and is not permanent, but constructed only to measure the capture efficiency of pollutants emitted from a given source. Additionally, any exhaust point from the enclosure shall be at least four equivalent duct or hood diameters from each natural draft opening. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-10, Item No. IV-B-1).

Thermal incinerator--A device for oxidizing waste material via flame and heat. This contrasts with a catalytic incinerator which incorporates a catalyst to aid the combustion.

Thinning solvent--A solvent added to thin a coating for the purpose of lowering the coating's viscosity and that evaporates before or during the cure of a film.

Thinning ratio--The volumetric ratio of thinner to coating.

Threshold Limit Values (TLV)--TLV represent the air concentrations of chemical substances to which it is believed that workers may be daily exposed without adverse effect.

Topcoat--A coating applied to a bare substrate or over a primer to provide protective and/or decorative properties to a part.

Total enclosure--An enclosure around the coating head of a wet coating line or other coating application device so that all HAP and VOC from the coating application and flash off operations are collected and ducted through a stack or into the oven. With a total enclosure on a coating line there will be no fugitive emissions, only stack emissions. Some air pollution regulations may require a total enclosure so that all HAP or VOC emitted by the process can be measured. The only openings in a total enclosure are forced makeup air and exhaust ducts and any natural draft openings such as those that allow raw materials to enter and exit the enclosure for processing. All access doors or windows are closed during routine operation of the enclosed source. Brief, occasional openings of such doors or windows to accommodate process equipment adjustments are acceptable, but if such openings are routine or if an access door remains open during the entire operation, the access door must be considered a natural draft opening. The average inward face velocity across the natural draft openings of the enclosure must be calculated including the area of such access doors. The drying oven itself may be part of the total enclosure. An enclosure that meets the requirements found in § 63.750(g)(4) is a permanent total enclosure.

Touch-up and repair operation--That portion of the coating operation that is the incidental application of coating used to cover minor imperfections in the coating finish or to achieve complete coverage. This definition includes out-of-sequence or out-of- cycle coating.

Transfer efficiency--The ratio of the amount of coating solids (nonvolatiles) deposited onto the surface of the coated part to the total amount of coating solids used.

Treatment--Any method, technology, or process designed to remove solids and/or pollutants from solid or liquid wastes, waste streams, effluents, or air emissions.

Unit operation--An industrial operation, classified or grouped according to its function in an operating environment (i.e., a paint mixing vessel, a spray booth, etc.).

Unit operation system--The ensemble on which the material balance is performed.

Vacuum injection system--A system in which a vacuum draws particulate from a storage container into a closed system that transfers particulate into the mix preparation equipment.

Viscosity--A measure of a coating's resistance to flow.

Volatile organic compound (VOC)--Any compound defined as VOC in 40 CFR 51.100. This includes any organic compound other than those determined by the EPA to be an exempt solvent.

Volume percent solids--The portion of a coating which remains as part of the cured film expressed as percent by volume. This contrasts to another convention of expressing solids content by mass percent. Often a percentage is given without specifying whether volume or mass. This is confusing and leads to errors in coating calculations.

Waste handling--Processing or treatment of waste (liquid or solid) that is generated as a by-product of either the coating process or cleaning activities/operations.

Waste handling device--Equipment that is used to separate solvent from solid waste (e.g., filter dryers) or liquid waste (e.g., pot stills and thin film evaporators). The solvents are recovered by heating, condensing, and collection.

Wastewater discharge--The water phase that is discharged from the separator in a wastewater treatment system.

Waterborne coating--A coating that contains more than 5 percent by mass water in its volatile fraction.

Work practice--Specific human activities within industry that lead to a reduction in VOC emissions (or waste). The activities include increased operator training, management directives, segregation of the waste solvent, and practices that lead to a reduction in cleaning frequency. It does not include the use of specialized equipment, such as solvent dispensers.

ENCLOSURE 2

United States

Environmental Protection Agency's

Information Gathering Authority

(Not currently available electronically,

to be added later)

ENCLOSURE 3

Disclosure of Emissions Data

Claimed as Confidential Under

Sections 110 and 114(c)

of the

Clean Air Act (CAA)

(Not currently available electronically,

to be added later)

ENCLOSURE 4

Designation of Authorized Representative

(Not currently available electronically,

to be added later)

ENCLOSURE 5

Summary of OAQPS Procedures for Safeguarding

CAA Confidential Business Information (CBI)

(Not currently available electronically,

to be added later)