7 DE Admin Code 1124 "Control of Volatile Organic Compound Emissions" 

13.0 Automobile and Light-Duty Truck Coating Operations 

03/11/2011 

13.1 Applicability 

13.1.1	 The provisions of 13.0 of this regulation apply to the following coating operations in an 

automobile or light-duty truck assembly plant: each prime coat-operation, each electrodeposition (EDP) prime coat operation, each primer:surfacer operation, each topcoat 

operation, each combined primer-surfacer and topcoat operation, each final repair 

operation and each miscellaneous motor vehicle materials operation. 

13.1.2	 The requirements in 13.3.1, 13.6 and 13.9 of this regulation also apply to heavy-duty 

trucks that use EDP to apply prime coat 

13.1.3	 Anti-chip coatings, as applied to automobile and light-duty truck components such as, 

but not limited to, rocker panels, the bottom edge of doors and fenders, and the leading 

edge of the hood or roof, are considered primer:surfacers. 

13.1.4	 Application to metal parts of underbody anti-chip coatings (e.g., underbody plastisol) 

and coatings other than prime, primer-surfacer, topcoat, final repair and miscellaneous 

motor vehicle materials shall be subject to the requirements of 22.0 of this regulation 

(Miscellaneous Metal Parts). 

13.1.5	 The requirements in 13.3 of this regulation do not apply to automobile and light-duty 

truck assembly plants whose plant-wide, actual emissions without control devices are 

less than 6.8 kilograms (kg) (15 pounds [Ib]) of volatile organic compounds (VOCs) per 

day. 

13.1.6	 An owner or operator of a facility whose emissions are below the applicability threshold 

in 13.1.5 of this regulation shall comply with the certification, recordkeeping, and 

reporting requirements in 4.2 of this regulation. 

13.1.7	 Any facility that becomes or is currently subject to all of the provisions of 13.0 of this 

regulation by exceeding the applicability threshold in 13.1.5 of this regulation will 

remain subject to these provisions even if its emissions later fall below the applicability 

threshold. 

13.1.8	 Any facility that is currently subject to a slate or federal rule promulgated pursuant to 

the Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and 

will remain subject to these provisions, even if its throughput or emissions later fall 

below the applicability threshold. 

13.1.9	 Transition period for existing permitted sources. Every owner or operator of any 

automobile or light-duty truck assembly plant that has a permit issued pursuant to 7 DE 

Admin Code 1102 or 1130 containing all applicable conditions of 13.0 of this 

regulation, as that regulation existed on January 11, 1993, shall comply with those 

permit conditions for up to one year after the effective date of this revision of 13.0 of 

this regulation. On and after the date one year after the effective date of this revision of 

13.0 of this regulation, every such owner or operator shall comply with the provisions of 

13.0 of this regulation. 

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13.2	 Definitions. As used in 13.0 of this regulation, all terms not defined herein shall have the meaning 

given them in this regulation or in the Clean Air Act Amendments (CAAA) of November 15, 1990, 

or in 2.0 of this regulation. 

"Adhesive" means any chemical substance that is applied for the purpose of bonding two surfaces 

together other than by mechanical means. 

"Application area" means the area where a coating is applied by dipping or spraying. 

"Automobile" means a motor vehicle capable of carrying no more than 12 passengers. 

"Automobile and Iight-<luty truck adhesive" means an adhesive, including glass bonding adhesive, 

used at an automobile or light-duty truck assembly coating facility, applied for the purpose of 

bonding two vehicle surfaces together without regard to the substrates involved. 

"Automobile and Iight-<luty truck bedliner" means a multi-component coating, used at an 

automobile or Iight-duty truck assembly coating facility, applied to a cargo bed after the 

application of topcoat and outside of the topcoat operation to provide additional durability and 

chip resistance. 

"Automobile and Iight-<luty truck body" means the exterior and interior surfaces of an automobile 

or light-duty truck including, but not limited to, hoods, fenders, cargo boxes, doors, grill opening 

panels, engine compartment, all or portions of the passenger compartment, and trunk interior. 

"Automobile and light-<luty truck cavity wax" means a coating, used at an automobile or light-duty 

truck assembly coating facility, applied into the cavities of the vehicle primarily for the purpose of 

enhancing corrosion protection. 

"Automobile and Iight-<luty truck deadener" means a coating, used at an automobile or light-duty 

truck assembly coating facility, applied to selected vehicle surfaces primarily for the purpose of 

reducing the sound of road noise in the passenger compartment. 

"Automobile and Iight-<luty truck gasket/gasket sealing material" means a fluid, used at an 

automobile or light-duty truck assembly coating facility, applied to coat a gasket or replace and 

perform the same function as a gasket. Automobile and light-duty truck gasket/gasket sealing 

material includes room temperature vulcanization (RTV) seal material. 

"Automobile and Iight-<luty truck glass bonding primer" means a primer, used at an automobile 

or light-duty truck assembly coating facility, applied to windshield or other glass, or to body 

openings, to prepare the glass or body opening for the application of glass bonding adhesives or 

the installation of adhesive bonded glass. Automobile and light-<luty truck glass bonding primer 

includes glass bonding/cleaning primers that perfonm both functions (cleaning and priming of the 

windshield and other glass, or body openings) prior to the application of adhesive or the 

installation of adhesive bonded glass. 

"Automobile and Iight-<luty truck lubricating wax/compound" means a protective lubricating 

material, used at an automobile or Iight-duty truck assembly coating facility, applied to vehicle 

hubs and hinges. 

"Automobile and Iight-<luty truck sealer" means a high viscosity material, used at an automobile or 

light-duty truck assembly coating facility, generally, but not always, applied in the paint shop after 

the body has received an electrodeposition primer coating and before the application of 

subsequent coatings (e.g. primer-surfacer). The primary purpose of the automobile and light-duty 

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truck sealer is to fill body joints completely so that there is no intrusion of water, gases or 

corrosive materials into the passenger area of the compartment. Such materials are also referred 

to as sealant or caUlk. 

"Automobile and light-duty truck trunk interior coating" means a coating, used at an automobile 

or light-duty truck assembly coating facility outside of the primer-surfacer and topcoat operations, 

applied to the trunk interior to provide chip protection. 

"Automobile and Iight-duty truck underbody coating" means a coating, used at an automobile or 

light-duty truck assembly coating facility, applied to the undercarriage or firewall to prevent 

corrosion and/or provide chip protection. 

"Automobile and Iight-duty truck weatherstrip adhesive" means an adhesive, used at an 

automobile or light-duty truck assembly coating facility, applied to weatherstripping materials for 

the purpose of bonding the weatherstrip material to the surface of the vehicle. 

"Electro-deposition (EDP)" means a process of applying a protective, corrosion resistant waterborne 

prime coat by which the automobile or 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. 

Also referred to as E-Coat, Uni-Prime, and ELPO Primer. 

"EDP prime coat operation" means the application area or areas, fiashoff area or areas, and oven or 

ovens that are used to apply and dry or cure the EDP prime coat on components of automobile 

and truck bodies on a single assembly line. 

"Final repair operation" means the operations performed and coating applied to completely 

assembled motor vehicles or to parts that are not yet on a completely assembled vehicle to 

correct damage or imperfections in the coating. The curing of the coatings applied in these 

operations is accomplished at a lower temperature than used for curing primer-surfacer and 

topcoat. This lower temperature cure avoids the need to send parts that are not yet on a 

completely assembled vehicle through the same type of curing process used,for primer-surfacer 

and topcoat and is necessary to protect heat sensitive components on completely assembled 

vehicles. 

"In-line Repair" means the operation performed and coating used to correct damage or imperfections 

in the topcoat on parts that are on a completely assembled vehicle. The curing of the coatings 

applied in these operations is accomplished at essentially the same temperature as that used for 

curing the previously applied topcoat. Also referred to as high bake repair or high bake 

reprocess. In-line repair is considered part of the topcoat operation. 

"Light-duty truck" means any motor vehicle rated at 3,864 kg (8,500 Ib) gross weight or less 

designed primarily to transport property. 

"Prime coat operation" means the application area or areas, flashoff area or areas, and oven or 

ovens that are used to apply and dry or cure the prime coat on components of automobile and 

light-duty truck bodies on a single assembly line. 

"Primer-surfacer operation" means the application area or areas, flashoff area or areas, and oven 

or ovens that are used to apply and dry or cure primer-SUrfacer between the prime coat and the 

topcoat operations on components of automobile and light-duty truck bodies on a single assembly 

line. 

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"Primer-surfacer" means an intermediate protective coating applied over the electrodeposition 

primer and under the topcoat. Primer-surfacer provides adhesion, protection and appearance 

properties to the total finish. Primer-surfacer may also be called guide coat or surfacer. Primersurfacer operations may include other coatings (e.g., anti-chip, lower-body anti-chip, chip 

resistant edge primer, spot primer, blackout, deadener, interior color, basecoat replacement 

coating, etc) that are applied in the same spray booth. 

"Primer-surfacer and topcoat protocol" means the EPA document "Protocol for Determining the 

Daily Volatile Organic Compound Emission Rate of Automobile and Light-Duty Truck PrimerSurfacer and Topcoat Operations", EPA 453/R-08-002, September 2008. 

"Solids turnover ratio (RT)" means the ratio of total volume of coating solids that is added to the 

EDP system in a calendar month divided by the total volume design capacity of the EDP system. 

"Topcoat" means the final coating applied to provide the final color andlor a protective finish. The 

topcoat may be a monocoat color or basecoaUclearcoat system. In-line repair and two-tone are 

part of topcoat. Topcoat operations may include other coatings (e.g., blackout, interior color, etc.) 

that are applied in the same spray booth. 

"Topcoat operation" means the application area or areas, flashoff area or areas, and oven or ovens 

used to apply and dry or cure topcoat on components of automobile and Iight-duty truck bodies 

on a single assembly line. 

"Volume design capacity" means for the EDP system the total liquid volume that is contained in the 

EDP system (tanks, pumps, recirculating lines, filters, etc.) at the system's designed liquid 

operating level. The EDP system volume design capacity is designated LE. 

13.3 Standards 

13.3.1 NO'owner or operator of an EDP prime coat operation subject to 13.0 of this regulation 

shall cause or allow on any day the application of any coating on that operation with VOC 

content, as applied, that exceeds either of the following: 

13.3.1.1	 0.084 kgA (0.7 Ib/gal) of coating solids from any EDP prime coat operation 

when the solids turnover ratio (RT) is 0.16 or greater. RT shall be calculated 

as follows: 

R = Tv 

T L 

E 

(13-1) 

where:
 

Tv =Total volume of coating solids that is added to the EDP system in a calendar
 

month (liters).
 

LE = Volume design capacity of the EDP system (liters).
 

13.3.1.2	 0.084 x 350 (0.160-RT) kg VOCII of applied coating solids from any EDP 

prime coat operation when RT, calculated according to Equation 13-1 of this 

regUlation, is greater than or equal to 0.040 and less than 0.160. 

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13.3.1.3	 When RT, calculated according to Equation 13-1 of this regulation, is less 

than 0.040 for any EDP prime coat operation, there is no emission limit. 

13.3.2	 No owner or operator of an automobile or light-duty truck primer surface operation 

subject to 13.0 of this regulation shall cause or allow vac emissions which do not 

comply with 1.44 kg VaClliter of deposited solids (12.0 Ib VaC/gal deposited solids) on 

a daily weighted average basis as determined by 13.7.2 of this regulation. 

13.3.3	 No owner or operator of an automobile or Iight-duty truck topcoating operation subject 

to 13.0 of this regulation shall cause or allow vac emissions that do not comply with 

1.44 kg VaC/liter of deposited solids (12.0 Ib VaC/gal deposited solids) on a daily 

weighted average basis as determined by 13.7.2 of this regUlation. 

13.3.4	 No owner or operator of an automobile or Iight-duty truck prime coat operation-or final 

repair operation subject to 13.0 of this regulation shall cause or allow the application of 

any coating on that operation with vac content, as applied, that does not comply with 

one of the following: 

13.3.4.1	 0.14 kilograms per liter (kg/I) (1.2 pounds per gallon [Ib/gal)) of coating, 

excluding water and exempt compounds, as applied, from any prime coat 

operation. 

13.3.4.2	 0.58 kgll (4.8 Ib/gal) of coating, excluding water and exempt compounds, 

as applied, from any final repair operation. 

13.3.4.3	 4.10 kgll (34.2 Ib/gal) of solids deposited from any final repair operation. 

13.3.5	 No owner or operator of an automobile or light-duty truck combined primer-SUrfacer and 

topcoat operation subjeclto 13.0 of this regUlation shall cause of allow vac emissions 

that do not comply with 1.44 kg VaC/liter of deposited solids (12.0 Ib VaC/gai 

deposited solids) on a daily weighted average basis as determined by 13.7.2 of this 

regulation. 

13.3.6	 Additional vac content limits for miscellaneous motor vehicle materials used at 

automotive and light-duty truck assembly facilities (grams of vac per liter of coating 

excluding water and exempt compounds, as applied) are shown in Table 13-1 of this 

regulation. 

Table 13-1 

Coating Category VOC REGULATORY AS 

APPLIED la/I) 

Automobile and liaht-dutv truck adhesive 250 

Automotive and liaht-dutv truck bedliner 200 

Automotive and Iight-dutv truck cavitv wax 650 

Automotive and liaht-dutv truck deadener 650 

Automotive and Iiaht-dutv truck aasket/aasket sealina material 200 

Automotive and Iight-duty truck glass bondina orimer 900 

Automotive and light-duty truck lUbricating wax/compound 700 

Automotive and Ii!lht-dutv truck sealer 650 

Automotive and li!lht-dutv truck trunk interior coatina 650 

Automotive and liaht-dutv truck underbodv coatina 430 

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IAutomotive and light-duty truck weatherstrip adhesive	 750 

13.3.7	 The vac emission limits in 13.3 of this regulation do not apply to materials supplied in 

containers with a net volume of 16 ounces or less or a net weight of one pound or less. 

13.3.8	 As an altemative to compliance with the emission limits of this regulation, an owner or 

operator may meet the requirements of 13.4 or 13.5 of this regUlation. 

13.4	 Daily-weighted average limitation. No owner or operator subject to 13.0 of this regulation shall 

apply, during any day, coatings in any non-eJectro-deposition (non-EDP) prime coat, final repair, 

or miscellaneous motor vehicle materials operation whose daily-weighted average vac content, 

calculated in accordance with the procedure specified in Appendix C of this regulation, exceeds 

the applicable emission limits in 13.3.4, and 13.3.6 of this regUlation. 

13.5	 Control devices 

13.5.1	 An owner or operator subject to 13.0 of this regulation may comply with the applicable 

emission limits for any coating operation by: 

13.5.1.1	 Installing and operating a capture system on that operation. 

13.5.1.2	 Installing and operating a control device on that operation. 

13.5.1.3	 Determining for each day the overall emission reduction efficiency needed 

to demonstrate compliance. The overall emission reduction needed for a 

day is the lesser of the value calculated according to the procedure in 3.1 

and 3.2 of Appendix C of this regulation for that day or 95%. 

13.5.1.4	 Demonstrating each day that the overall emission reduction efficiency 

achieved for that day, as determined in Appendix D of this regulation, is 

greater than or equal to the overall emission reduction efficiency required 

for that day. 

13.5.2	 An owner or operator sUbject to 13.0 of this regulation shall ensure that: 

13.521	 A capture system and control device are operated at all times the coating 

operation is in use, and the owner or operator demonstrates compliance 

with 13.0 of this regUlation through the applicable coating analysis and 

capture system and control device efficiency test methods specified in 

Appendix B, Appendix D and Appendix E of this regulation and in 

accordance with the capture efficiency test methods in Appendix D of this 

regulation. 

13.5.2.2	 The control device is eqUipped with the applicable monitoring equipment 

specified in Appendix D of this regulation, and the monitoring equipment is 

installed, calibrated, operated, and maintained according to the vendor's 

specifications at all times the control device is in use. 

13.6	 Compliance procedures for EDP prime coat operations 

13.6.1	 The owner or operator of an EDP prime coat operation subject to 13.0 of this regulation 

shall use the procedures in 40 CFR 60.393(c)(1) (July 1, 2009) to determine 

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compliance. if a capture system and a control device are not used to comply with the 

emission limits in 13.3.1.1 or 13.3.1.2 of this regulation. 

13.6.2	 The owner or operator of an EDP prime coat operation subject to 13.0 of this regulation 

shall use the procedures in 40 CFR 60.393(c)(2) (July 1, 2009) to determine 

compliance if a capture system and a control device that destroys VOC (e.g., 

incinerator) are used to comply with the emission limits in 13.3.1.1 or 13.3.1.2 of this 

regulation. 

13.6.3	 The owner or operator of an EDP prime coat operation subject to 13.0 of this regulation 

shall use the procedures in 40 CFR 60.393(c)(3) (July 1, 2009) to determine 

compliance if a capture system and a control device that recovers the VOC (e.g., 

carbon adSOrber) are used to comply with the emission limits in 13.3.1.1 or 13.3.1.2 of 

this regulation. 

13.7	 Test methods 

13.7.1 The test methods found	 in AppendiX A through AppendiX 0 of this regulation shall be 

used to detennine compliance with 13.3.4.1, 13.3.4.2, 13.3.6 and 13.3.8 of this 

regulation. 

13.7.2	 An owner or operator shall use the primer-surfacer and topcoat protocol to detennine 

compliance with 13.3.2, 13.3.3 and 13.3.5 of this regulation. This protOCOl "Protocol for 

Determining the Daily Volatile Organic compound Emission Rate of Automobile and 

Light-duty Truck Primer-5urfacer and Topcoat Operations" EPA453/R-08-Q02, 

September 2008 can be found at 

www.epa.gov/ttn/oarpgIt1/ctg/autotruck primer topcoat protocol 093008.OOf. 

13.8	 Recordkeeping and reporting for non-EDP prime coat, final repair and miscellaneous motor 

vehicle materials coating operations. 

13.8.1	 An owner or operator of an automobile or Iight-duty truck coating operation that is 

exempt from the emission limitations in 13.3.4.1, 13.3.4.2 and 133.6 of this regulation 

shall comply with the certification, recordkeeping, and reporting requirements in 4.2 of 

this regulation. 

13.8.2	 An owner or operator of an automobile or light-duty truck coating operation subject to 

13.0 of this regulation and complying with 13.3.4.1, 13.3.4.2 and 13.3.6 of this 

regulation by the use of complying coatings shall comply with the certification, 

recordkeeping, and reporting requirements in 4.3 of this regulation. 

13.8.3	 An owner or operator of an automobile or Iight-duty truck coating operation SUbject to 

13.0 of this regulation and compiying with 13.3.4.1, 13.3.4.2 and 13.3.6 of this 

regulation by daily-weighted averaging shall comply with the certification, 

recordkeeping, and reporting requirements in 4.4 of this regulation. 

13.8.4	 An owner or operator of an automobile or light-duty truck coating operation subject 13.0 

of this regUlation and complying with 13.3.4.1, 13.3.4.2 and 13.3.6 of this regulation by 

the use of control devices Shall comply with the testing, reporting, and recordkeeping 

requirements in 4.5 of this regulation. 

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13.9	 Recordkeeping and reporting for EDP prime coat operations. An owner or operator of an EDP 

prime coat operation subject to 13.0 of this regulation and complying with the requirements in 

13.3.1.1, 13.3.1.2 and 13.3.1.3 of this regulation shall comply with the following: 

13.9.1	 Certification. By November 15, 1993 or upon startup of a new EDP prime coat 

operation, the owner or operator shall certify to the Department that the coating 

operation is and will be in compliance with the requirements in 13.3.1.1 or 13.3.1.2 of 

this regulation on and after November 15, 1993, or on and after the initial startup date. 

Such certification shall include: 

13.9.1.1	 The name and location of the facility. 

13.9.1.2	 The address and telephone number of the person responsible for the 

facility. 

13.9.1.3	 Identification of subject sources. 

13.9.1.4	 A copy of the calculations performed to determine RT and the calculations 

performed pursuant to 13.6 of this regulation to demonstrate compliance 

for the EDP prime coat operation for the month prior to submittal of the 

certification. 

13.9.2	 Recordkeeping. On and after November 15,1993 or on and after the initial startup date 

of a new EDP prime coat operation, the owner or operator shall collect and record the 

following information for each EDP prime coat operation. These records shall be 

maintained at the facility for at least five years and shall be made available to the 

Department upon verbal or written request: 

139.2.1	 For each day, the total daily volume of coating solids that is added to the 

EDP system. 

13.9.2.2	 For each month, calculation of RT using the equation in 13.3.1.1 of this 

regulation. 

13.9.2.3 For each	 month, the calculations used in the compliance determinations 

specified in 13.6 of this regulation. 

13.9.3	 Reporting. On and after November 15, 1993, the owner or operator of an EDP prime 

coat operation subject to 13.0 of this regUlation shall notify the Department in either of 

the following instances: 

13.9.3.1	 Any record showing noncompliance with the appropriate emission limit for 

the EDP prime coat operation. 

13.9.3.2	 At least 30 calendar days before changing the method of compliance from 

one of the procedures in 13.6 of this regulation to another of the 

procedures in 13.6 of this regulation, the owner or operator shall comply 

with the certification requirements in 13.9.1 of this regulation. 

13.10	 Reporting and recordkeeping for topcoat and primer surfacer operations. 

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13.10.1 An owner or operator of an automobile or light-duty truck coaling operation subject to 

13.0 of this regulation and complying with 13.3.2, 13.3.3 or 13.3.5 of this regulation 

shall comply with the fOllowing: 

13.10.1.1	 Certification. At least 120 days prior to the initial compliance date, the 

owner or operator of a coating operation subject to the topcoat and primer 

surfacer limit in 13.3.2, 13.3.3 or 13.3.5 of this regulation shall submit to 

the Department a detailed proposal specifying the method of 

demonstrating how the compliance test will be conducted according to 

13.7.2 of this regulation. The proposai shall include a comprehensive plan 

(including a rationale) for determining the transfer efficiency at each booth 

through the use of in-plant or pilot testing; the selection of coatings to be 

tested (for the purpose of determining transfer efficiency), including the 

rationale for coating groupings; and a method for tracking coaling usage 

during the transfer efficiency test. Upon approval by the Department, the 

owner or operator may proceed with the compliance demonstration. 

13.10.1.2 Recordkeeping 

13.10.1.2.1	 The owner or operator shall maintain at the facility for a period of 5 

years all test results, data, and calculations used to determine vac 

emissions from each topcoat and each primer surfacer operation 

according to the topcoat protocol. 

13.10.1.2.2	 If control devices are used to control emissions from an automobile 

or light-duty truck topcoat or primer surfacer operation, the owner or 

operator shall maintain records according to 4.5.2.6 through 4.5.2.11 

of this regulation. 

13.10.1.2.3	 Reporting. Any instance of noncompliance with the emission limit in 

13.3.2, 13.3.3 or 13.3.5 of this regulation shall be reported to the 

Department within 45 calendar days. 

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