From: Randy Mosier ‐MDE‐ [mailto:randy.mosier@maryland.gov]  

Sent: Tuesday, March 31, 2015 9:09 AM

To: Schmitt, Ellen

Cc: Diane Franks ‐MDE‐; Husain Waheed ‐MDE‐; Carolyn A Jones ‐MDE‐; powers, marilyn

Subject: Re: SIP Revision #14‐02 ‐ re: CTG for metal parts and products

Volvo documents for heavy duty engine coatings. 

RANDY E. MOSIER

Division Chief, Air Quality Regulations Division

MARYLAND DEPARTMENT OF THE ENVIRONMENT

1800 Washington Boulevard, STE 730

Baltimore, Maryland 21230-1720
VOLVO 

Alternative VOC RACT Proposal 

Innovative Robotic Paint System 

New Paint Line- Background Information 

As one of the world's premier Class 8 Heavy Duty diesel engine builders, Mack Trucks, Inc. (Volvo Group 

Hagerstown) embraces a continuous improvement culture, and always strives to improve our 

operational efficiencies, enhance our product quality, and reduce our environmental footprint. Volvo 

Group Hagerstown takes environmental care seriously, as it one of three AS Volvo core principles. 

Volvo Group Hagerstown strategically invested 4 million dollars to implement a dual line, automated 

engine paint system in 2011. The new paint system is fully enclosed and equipped with two robotic 

paint booths, each having a flash tunnel and an electric drying oven (ARMA registration #s 043-0006-6-

0694 and 043-0006-6-0695). ASS-manufactured paint robots are used with ECCO 70AS spray guns in 

each of the two paint booths. This investment was made to replace emission unit 002PS-1, which was a 

partially opened, less efficient robotic process, in order to vastly improve the paint process, reduce the 

manufacturing environmental footprint, and lower operating costs. These objectives are being met. 

Specifically, the paint line has produced beneficial results in the areas of paint consumption per engine, 

VOC emissions, and solid waste generation. 

The new paint system was designed to have a significantly lower environmental footprint than the Koch 

robotic spray booth previously used. This has resulted in much lower air emissions and solid waste per 

unit of production. This is accomplished through precise robotic programming, low-VOC, fast-dry 

waterborne paints, integral cartridge filtration and a cyclone technology that together achieve greater 

than 99.9% solids removal, and an air recirculation system that exhausts only 10% of the total1,000 

CFM airflow. Given this improvement, the site requested and received a 40 ton per 12-month rolling 

total VOC limitation, and is now considered a synthetic minor source of VOC emissions. 

Figure 1.0 visually depicts the synthetic minor VOC source status of the new paint line. 

Figure 1.0 New Paint line Alternative VOC RACT Analysis 

40.0 

Federally Enforcable VOC Emissions cap 

31.2 

30.0 

voc 

Emissions 

12-Month 20.0 

Rolling 

(tons) 

10.0 

Operational Max. Production Target Actual Emissions Forecast Emissions 

(7847.5 hrs./yr.) (260 Engines/Day) (July-11 to June-12) (Calendar Year 2012) 

Note: The operational maximum is theoretical and does not account for the time required to complete 

necessary routine maintenance and cleaning. It also does not represent PTE, since the calculation uses 

the actual, and not the maximum, coating application rate of the paint guns. 

Volvo Group Trucks Hagerstown Submittal Date: July 18th, 2012 Page 1 
VOLVO 

Alternative VOC RACT Proposal 

Innovative Robotic Paint System 

Based on potential to emit, Volvo Group Hagerstown accepted a federally enforceable 12-month rolling 

total 40 ton limitation for the new paint line. However, given the efficiency of the new paint line in 

gallons per engine, Figure 1.0 demonstrates that even at a theoretical operational maximum production 

rate of 469 engines per day (365 days a year), the VOC emissions would only be 31.2 tons in a 12-month 

period, which is 8.8 tons below our 40 ton federally enforceable cap. This product rate is based on a 

maximum painting rate of 5.5 minutes per engine for a maximum of 430 minutes per shift, which is set 

by the masking/de-masking operations (bottleneck) before and after the paint process and a 

contractually mandatory 30 minute lunch and two 10 minute employee breaks per shift. From a more 

realistic standpoint, the paint line has a daily production target of 260 engines. At the current efficiency 

of 0.52 gallons per engine, this equates to only 11.5 tons per 12-consecutive month total. The actual 

VOC emissions (12-month rolling total) which includes five months of data from the inefficient old paint 

line (0.802 gallons per engine), is now 10.3 tons. Finally, it is forecasted based on current product build 

rates of 205 to 215 engines per day, that the VOC emissions over the 2012 full calendar year will be 9.2 

tons. 

Alternative VOC RACT Proposal 

Volvo Group Trucks Hagerstown concurs with MOE's proposed VOC coating formulation limits proposed 

for CO MAR 26.11.19.08. The waterborne paints used in our painting process have a VOC content, on 

average of 1.66 lbs. VOC per gallon, minus water. This composition is 41% lower than the VOC content 

allowed by the regulation. 

However, with respect to coating application technologies, Volvo Group Hagerstown strongly believes 

that the recently installed paint system is a more effective technology, with a lower environmental 

footprint, as compared to conventional HVLP, for painting large heavy duty diesel engines, and is 

therefore requesting a case-by-case Alternative VOC RACT determination for the new paint system. 

Table 1.0 summarizes the key performance indicators, and dramatic improvements of the new paint line 

versus the old paint line. As shown the improvements realized over the first seven months of operation 

for the new paint system, demonstrate a highly efficient process with very low VOC emissions and waste 

generation. The data in Table 1.0 comes from paint usage and VOC emissions certified for calendar 

years 2009, 2010, and 2011. It is enclosed in the appendices of this document. 

Table 1.0 Key Environmental Performance Indicators 

Environmental Footprint Old Paint Line New Paint Line % Improvement 

Paint Consumption 0.802 0.524 34.6% (gallons sprayed /engine) 

Paint VOC Emissions 0.716 0.362 49.4% (lbs. VOC emitted/engine) 

Av. Paint VOC Formulation 0.871 0.625 28.2% 

(lbs. VOC/gallon, with exempts) 

Non-Hazardous Solid Waste 2.998 0.657 78.1% (lbs. waste generated/engine) 

Volvo Group Trucks Hagerstown Submittal Date: July 18th, 2012 Page 2 
VOLVO 

Alternative VOC RACT Proposal 

Innovative Robotic Paint System 

As shown, the application technology selected in combination with a low-VOC waterborne paint 

formulation, has led to a sustainable, low environmental footprint paint process. The paint 

consumption efficiency and paint VOC emissions improvements shown (34.6% and 49.4%, respectfully) 

were calculated by comparing thirty-one months of run time on the old paint line back to January 2011, 

versus the first full six months of production on the new paint line. Data excluded to ensure the study 

was representative of normal operating condition includes February-2010, since it was an abnormally 

high paint consumption rate per engine for the old paint line, and September-2011, October-2011, and 

November-2011 since this time frame was shared by both paint lines, with the new paint line in a testing 

and optimization phase. 

There are multiple factors that led to dramatic efficiency improvements on the new paint line as 

compared to the old paint line, that Volvo Group Hagerstown believe make it an alternative VOC RACT. 

The new paint line is fully enclosed, with automated control of humidity and temperature, which allows 

for operation within a specified control range to reduce quality issues and re-painting. Specialized robot 

programming allows for the optimization of robot movement and spray fan patterns. Within each 

program, the paint spray fan can be varied on an engine-by-engine basis as engine sizes and styles 

change throughout the daily production run. There are actually twenty three programs tailored to each 

engine variant. Depending upon the order information for the production unit, the appropriate 

programs are assigned for that day's production run of engines. Programming can be modified offline 

very quickly as needed to help minimize paint overconsumption. This allows Volvo Group to only apply 

the paint coverage needed to meet the Volvo quality specification with little additional paint 

consumption. A recirculation house and integral paint overspray solids collection process called the 

cyclone ensures that the air quality in the paint booth is free of particulate contaminants; this reduces 

scrap and repainting. An innovative fast dry paint formulation produces overspray that rapidly converts 

to a solids entering into the cyclone where centrifugal forces turn the material into a low volume, fine 

powder waste. It is these paint technology choices and application methods that make the new paint 

line an alternative VOC RACT for the Volvo Group Hagerstown site. 

Figure 2.0 Paint Formulation VOC Content (with water) 

1 .------------------------------------

(LBS/ 

GAL) 

0.859 

Volvo Green Paint 

Volvo Group Trucks Hagerstown 

0.886 

Mack Red Paint 

Submittal Date: July 18th, 2012 Page 3 
VOLVO 

Alternative VOC RACT Proposal 

Innovative Robotic Paint System 

As shown in Figure 2.0, the paint VOC formulation across the two colors used (green and red) was also 

reduced strategically by 28%, to lower emissions per engine to prevent emission increases as the daily 

production was targeted to increase up to 260 engines painted per day. Finally, the old paint line utilized 

a water wash curtain to collect and remove overspray solids from the booth. This was very inefficient 

from a solid waste generation standpoint, leading to large volumes of sludge requiring disposal. The new 

paint line was designed to generate very little solid waste. A reduction of 234.11bs. of solid waste per 

100 engines painted has been achieved over the first seven full months of operation. 

HVLP Technology Limitations 

Volvo Group Hagerstown would not be averse to implementing High Volume Low Pressure (HVLP) paint 

application guns, if it were the optimum and correct technology for painting llliter and 13 liter heavy 

duty diesel engines. However, HVLP is not recommended by the Global Paint Project Manager for use in 

Hagerstown as it may cause paint consumption to increase rather than decrease for this application. As 

will be explained in more detail within the enclosed paint technology document from Volvo Group 

Trucks, Global Paint Process Manager, Johan Bergman, HVLP by design will not be able to coat the many 

recessed areas inherent to the Class 8 diesel engine design as efficiently as the current paint process 

used at Volvo Group Hagerstown or in the future, even more efficient paint process for large engines, 

high pressure, airless systems. 

It is believed that HVLP could lead to increased passes of the robot, which means greater gallons of paint 

sprayed per engine to achieve the 50 micron thickness quality specification on 100% of the engine's 

painted surface area. Furthermore, additional robot passes to provide the correct paint coverage on 

recessed areas will lead to excess paint applied in other areas. From an environmental standpoint, this 

will mean an increase of VOC lbs. per engine towards the old paint line efficiency, and therefore an 

increase in our 12-month rolling total VOC emissions. For this reason, Volvo Group Hagerstown believes 

the environmental, quality and operational performance of the current installed paint process exceeds 

that of HVLP, and should be considered VOC RACT for painting heavy duty diesel engines at our facility 

In conclusion, Volvo Group Hagerstown strongly believes that the current paint process in Hagerstown is 

VOC RACT and will outperform HVLP for painting heavy duty engines in terms of total paint consumed 

and VOC emissions per engine painted. A four million dollar investment to a new paint process has thus 

far led to nearly a 50% reduction in paint emissions. There is cause for concern that installing HVLP may 

very well cause a 10-15% regression and higher pollutant emissions. Increased paint consumption and 

reversal of the current downward trend in VOC emissions is not desired by Volvo Group Hagerstown, the 

MOE, or the EPA, and this is why the current paint process installed should be considered as VOC RACT. 

Volvo Group Trucks Hagerstown Submittal Date: July 18th, 2012 Page4 
Appendix 

Alternative VOC RACT Proposal 

Figure 3.0 VOC Emissions per Engine Painted 

1.2 ~---------------------------------------------------- --r---------~ 

1.0 

0.8 

voc 

(lbs./ 0.6 

Enalne) 

0.4 

New Paint Line Initial 

---------------------------------------- ~;~~611 

Old Paint Line: 

0.721bs./Enllne 

0.2 -·--------

Figure 4.0 Paint Consumption per Engine ---------------

1.4 

1.2 

1.0 -

Pa int 

(Gal./ 

Enalnel o.a 

0.6 

0.2 

Old Paint Line: 

0 .80 Gai./Enalne 

New Paint Line: 

0.36 lbs./Enalne 

New Pa int Line: 

0.52 Gai./Englne 

l 

0.0 ~ ................... ...---.--........ ---_..,-............ --.....-.-----...... - ...... ...-+-.-IO...,.-.--...,.... ....... ,......,., 

Volvo Group Trucks Hagerstown Submittal Date: July 18th, 2012 Page 5 
Month 

Jan-09 

Feb-09 

Mar-09 

Apr-09 

May-09 

Jun-09 

Jul-09 

Aug-09 

Sep-09 

Oct-09 

Nov-09 

Dec-09 

Jan-10 

Feb-10 

Mar-10 

Apr-10 

May-10 

Jun-1 0 

Jul-1 0 

Aug-1 0 

Sep-10 

Oct-10 

Nov-10 

Dec-10 

Jan-11 

Feb-11 

Mar-11 

Apr-11 

May-11 

Jun-11 

Jul-11 

Aug-11 

Sep-11 

Oct-11 

Nov-11 

Dec-11 

Jan-12 

Feb-12 

Mar-12 

Apr-12 

May-12 

Jun-12 

T a e bl 2 0 -C asePaint voc 

Appendix 

Alternative VOC RACT Proposal 

8 y-c ase Alt erna f 1ve VOC RACT An a I YSIS . S 

Actual Paint Paint VOC 

upportmg 

Total VOC 

Sprayed Emissions Engines Sprayed Emissions Emissions 

(gal) (tons) Painted (gal/engine) (lbs/engine) 12-Mn (tons) 

1,036.50 0.407 1371 0.756 0.593 

1,207.40 0.475 1699 0.711 0.559 

486.90 0.1 92 580 0.839 0.661 

713.80 0.281 880 0.811 0.640 

819.66 0.393 952 0.861 0.825 

1,261 .05 0.598 1458 0.865 0.820 

840.55 0.400 990 0.849 0.808 

798.05 0.382 948 0.842 0.806 

1,455.15 0.696 1758 0.828 0.792 

1,424.95 0.691 1770 0.805 0.781 

1,422.05 0.664 2020 0.704 0.657 

1,516.05 0.708 1802 0.841 0.786 

1,753.60 0.886 2015 0.870 0.880 6.367 

748.40 0.279 585 1.279 0.953 6.170 

957.30 0.369 928 1.032 0.796 6.348 

1,280.50 0.508 1380 0.928 0.736 6.574 

1,009.35 0.481 1241 0.813 0.776 6.663 

1,871 .30 0.786 1963 0.953 0.801 6.851 

1,602.00 0.726 1843 0.869 0.788 7.177 

1,429.60 0.656 1794 0.797 0.731 7.451 

2,032.70 0.928 2473 0.822 0.750 7.682 

2,277.50 1.034 2602 0.875 0.795 8.025 

1,983.10 0.899 2631 0.754 0.684 8.260 

1,586.70 0.694 2078 0.764 0.668 8.246 

1,600.25 0.733 2684 0.596 0.546 8.094 

1,886.75 0.856 2565 0.736 0.667 8.671 

2,461 .50 1.119 3048 0.808 0.734 9.421 

2,100.00 0.955 2984 0.704 0.640 9.868 

2,080.00 0.940 3583 0.581 0.525 10.327 

3,138.00 1.407 4354 0.721 0.646 10.948 

2,434.00 1.090 2953 0.824 0.738 11 .312 

2,437.00 1.015 3526 0.691 0.575 11.671 

2,445.00 1.104 3898 0.627 0.567 11 .847 

:l,fbb.OO 1.153 4387 U.b28 0.526 11.966 

2,075.00 0.852 3726 0.557 0.458 11 .920 

1,400.00 0.467 2652 0.528 0.352 11 .692 

1,968.75 0.662 3499 0.563 0.378 11.620 

2,310.00 0.781 4270 0.541 0.366 11 .546 

2,336.50 0.790 4386 0.533 0.360 11 .216 

2,235.00 0.759 4253 0.526 0.357 11.020 

2,222.50 0.813 4419 0.503 0.368 10.893 

2,126.50 0.797 4479 0.475 0.356 10.282 

Volvo Group Trucks Hagerstown Submittal Date: July 18th, 2012 

D at a 

Theoretica I 

Max. Eng./ 

Month 

14,539 

13,132 

14,539 

14,070 

14,539 

14,070 

14,539 

14,539 

14,070 

14,539 

14,070 

14,539 

14,539 

13,132 

14,539 

14,070 

14,539 

14,070 

Page 6 
VOLVO 

Company name Type of document 

Volvo Group Trucks, Powertrain Production 

Name of document Issue Reg No. Page 

Engine Painting- Airless High Pressure Technology 1 (3) 

Issuer (dept, name, phone, location) Sign Date Info class 

Johan Bergman, Global Process Manager, Engine Paint 2012-07-13 

Volvo Group Trucks (Volvo) must apply a coating to its engines to provide corrosion 

protection. For many years Volvo has worked diligently to find the most efficient way 

possible to paint our engines. In this work we have tested several paint spraying 

technologies such as Conventional Low Pressure, High Volume Low Pressure (HVLP), air 

assisted High Pressure (HP), and airless HP. The objective was to identify the most effective 

coating application for our engines, with the lowest environmental footprint. 

Each coating technology has an optimum application where the benefits and efficiencies are 

maximized. For painting heavy duty diesel engines Volvo has found that airless HP is the 

ideal paint technology because of its ability to deliver paint quickly and efficiently to large 

surface areas and complex geometries characteristic of 11 liter and 13 liter diesel engines. 

Using HP airless technology allows Volvo to meet high production rates with low 

environmental impacts. This technology is in use at our Skovde plant in Sweden, and is 

scheduled to be installed in manufacturing plants in France, Japan, and India. 

HP airless is thought to be the recognized painting application standard for large parts such 

as steel structures, ships, large engines and bulk containers. Airless HP technology uses 

high fluid pressure applied by hydraulic pumps to atomize the coating. It acts to push the 

paint into otherwise extremely difficult to reach pits and crevices on a part. Conventional low 

pressure and HVLP technology struggle to apply paint in these areas, and can actually 

cause an increase in paint consumption. Figure 1 .0 shows the areas of concern when using 

HVLP, and the advantage of using airless HP to ensure that the minimum coating thickness 

(50 microns) is achieved, without over-applying paint in other engine areas. 

Higher viscosity, thixotropic fast dry coatings are needed for efficient operation of the 

cyclone solids collection process integral to the paint line. Airless HP is the ideal technology 

for applying these types of coatings since it is capable of delivering the paint to the engine 

rapidly in a "wet" state, helping to ensure proper adhesion and paint thickness. 
VOLVO 

Company name Type of document 

Volvo Group Trucks, Powertrain Production 

Name of document Issue Reg. No Page 

Engine Painting - Airless High Pressure Technology 2 (3) 

By using airless HP painting technology Volvo is able to reduce VOC emissions by reducing 

the number of paint layers applied to the engine, as compared to conventional Low Pressure 

or HVLP. Figure 2.0 shows a comparison of application efficiency of the old paint system 

used in Hagerstown, the new paint system used in Hagerstown, and the Airless HP system 

used in Skovde, Sweden. The gallons per engine range given for Airless HP efficiency is 

from the paint system in use at the Volvo Group Trucks facility in Skovde, Sweden. 

Figure 2.0 Paint Spray Technology Analyses 

Partially Closed 

Paint Booth 

Water Curtain 

Paint Process 

0 .62 

Gall 

En gino 

Now 

Paint 

Llno 

(G·Month 

Current 

Data) 

Fully Enclosed 

Paint Booth 

Cyclone Collection 

Paint Process 

Fully Enclosed 

Paint Booth 

Alrless HP 

Paint Process 

Figure 3.0 shows the projected 12-month rolling total VOC emissions 

following installation of airless HP. Based on converting to the global specification at 

Hagerstown, using the engine production rate over the last 12 months and assuming 0.35 

gallons per engine at the current average VOC content of 0.625 lbs. per gallon, there is 

potential to achieve an additional 50% reduction in VOC emissions. 

Figure 3.0 Paint System Comparison Current vs. Airless HP 

40.0 

voc 30.0 

Emissions 

12-Month 20.

0 

Rolling 

(tons) 

10.0 

0 .0 

Federally Enforcable VOC Emissions 

10.3 

Actual Emissions 

(July-11 t o June-12) 

Projected Emissions 

(Airless HP) 
VOLVO 

Company name Type of document 

Volvo Group Trucks, Powertrain Production 

Name of document Issue Reg. No. Page 

Engine Painting - Airless High Pressure Technology 3 (3) 

In conclusion, Volvo has determined that Airless HP is the optimum paint application method 

for painting large diesel engines, leading to better paint use efficiencies and lower 

environmental impacts when compare to HVLP. Therefore, Volvo Group Trucks is 

requesting that Airless HP be added to the approved list of paint application technologies as 

VOC RACT within COMAR rule 26.11 .19.08.