### 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 Em issions Forecast Emissions (7847.5 hrs./yr.) (260 Engines/Day) (July-11 to June-12) (Calendar Year 2012) Note: The operational maxi m um is theoretical and does not account for the time required to compl ete necessary routi ne m aintenance and cleaning. It al so d oes not represent PTE, since the calculation uses th e actual, and not the maxim um , 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 combin ation with a low-VOC waterborne paint formulation , has led to a sustainable, low environmental footprint paint process . The paint consumption efficiency and pa int 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 thi stime 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 minimi ze 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 en sures 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 Pa i nt

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 . Th is 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 Init ial

### ----------------------**-- ----------------** **~;~~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 Hage rstow n Su bmittal Date: July 1 8th , 2012 Page 5Month 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 bl 2 0 C a e 

# - ase Paint 

## voc 

# Appendix Alternative VOC RACT Proposal 8 

# c

y- ase 

## Alt f VOC RACT 

### An I . S erna 1ve a YSIS 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 .3 12 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 .2 16 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

Vo lvo 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 ofdocu me nt 

### Volvo Group Trucks, Powertrain Production Name of document Issue Reg No . Page 

### Engine Painting- Airless High Pressure Technology 1 (3) I ssue r (dept, name , phone , location) S i gn 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 Engino

Now Paint Llno (G · Month Current

Data) Full y Enclosed

Paint Booth Cyclone Collection

Paint Proces s Fully Enclo sed Pain t Booth Al r less HP Paint Proc ess 

### 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 (Airle ss HP)

# VOLVO

Company name Type of document 

### Volvo Group Trucks , Powertrain Production N ame of d ocument 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 .