April 2001

Draft RG-xxx

Air Permit Technical Guidance

for Coatings Sources:

Surface Coating Operations

printed on
recycled paper Air Permits Division

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

 Authorization for use or reproduction of any original material contained in this publication—that is, not
obtained from other sources—is freely granted. The commission would appreciate acknowledgment.

Copies of this publication are available for public use through the Texas State Library, other state
depository libraries, and the TCEQ Library, in compliance with state depository law. For more information
on TCEQ publications call (512) 239-0028 or visit our Web site at:

www.tceq.state.tx.us

Published and distributed by:

Texas Commission on Environmental Quality
P.O. Box 13087
Austin TX 78711-3087

The TCEQ is an equal opportunity/affirmative action employer. The agency does not allow discrimination on the
basis of race, color, religion, national origin, sex, disability, age, sexual orientation or veteran status. In compliance
with the Americans with Disabilities Act, this document may be requested in alternate formats by contacting the
TCEQ at (512)239-0028, Fax 239-4488, or 1-800-RELAY-TX (TDD), or by writing P.O. Box 13087, Austin, TX
78711-3087.
 Technical Disclaimer

This document is intended as guidance to explain the specific requirements for new source review permitting
of surface coating operations; it does not supersede or replace any state or federal law, regulation, or rule.
References to abatement equipment technologies are not intended to represent minimum or maximum levels
of Best Available Control Technology (BACT). Determinations of BACT are made on a case-by-case basis
as part of the New Source Review of permit applications. BACT determinations are always subject to
adjustment in consideration of specific process requirements, air quality concerns, and recent developments
in abatement technology. Additionally, specific health effects concerns may indicate stricter abatement than
required by the BACT determination.

The represented calculation methods are intended as an aid in the completion of acceptable submittals;
alternate calculation methods may be equally acceptable if they are based upon, and adequately demonstrate,
sound engineering assumptions or data.

These guidelines are applicable as of this document’s publication date but are subject to revision during the
permit application preparation and review period. It is the responsibility of the applicants to remain abreast of
any guideline or regulation developments that may affect their industries.
 Table of Contents

Chapter 1—Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Chapter 2—State and Federal Permitting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Preconstruction Authorization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
General Regulation Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Chapter 3—Best Available Control Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Source Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Add-On Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Chapter 4—Emission Factors, Efficiencies, and Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Spray Coating Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Dip Coating Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Products of Combustion From Natural Gas -- Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

ATTACHMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Table 1–Percent Overspray as a Function of Spraying Method and Sprayed Surface . . . . . . . . . 29
Table 2–Health Effects Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Figure 1–Solvent Loss . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Draft Permit Special Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Chapter 1: Overview

This document is intended to aid the permit applicant in identifying applicable federal and state regulations,
and to assist in calculating the emissions from surface coating operations. It is important to remember that all
representations made in a permit application become conditions upon which a permit is issued, amended, or
renewed. This document also includes example special conditions that can be expected when a permit is issued.

This document provides guidance for surface coating operations. Calculations for various forms of coatings
and application methods may vary, including emission calculations and transfer efficiency factors.

Call the TCEQ New Source Review Permits Division, Coatings & Combustion Section at (512) 239-1250 to
obtain further guidance regarding surface coating.

State and Federal Permitting Requirements of this document describes the applicable federal and state rules and
regulations that may affect a surface coating facility. These rules and regulations include the requirements for
obtaining an air permit and/or claiming an exemption from permitting. Additional rules and regulations limit
the volatile organic compound content of coatings as well as specify the controls that must be used in specific
counties.

Best Available Control Technology explains best available control technology (BACT) for the surface coating
industry, which is required in Title 30 Texas Administrative Code Section 116.111(2)(C) [30 TAC
Section 116.111(2)(C)]. BACT are defined as the best available control technology with consideration given to
the technical practicability and the economic reasonableness of reducing or eliminating emissions from a
facility. For surface coating facilities, BACT includes both source reductions and emissions controls.

Emission Factors, Efficiencies, and Calculations provide sample calculation methods for the following:

Spray painting operations

Dip coating operations
Combustion sources (drying ovens and heaters)

These methods provide sample calculations to determine emissions from these facilities on an hourly and
annual basis.

In addition, this packet contains several attachments including a set of sample special conditions, a transfer
efficiency table, and a coating flash off figures.

Draft Page 1 of 33
Chapter 2: State and Federal Permitting Requirements
Two types of surface coating facilities are regulated by the TCEQ: existing facilities and new facilities.
Facilities that were in existence before September 1, 1971, and have not undergone modification are considered
grandfathered and are not subject to TCEQ permitting requirements. Facilities that were built or modified after
September 1, 1971 are subject to TCEQ permitting requirements.

PRECONSTRUCTION AUTHORIZATION

Title 30 TAC Section 116.110 requires that any person who plans to construct any new facility or to engage in
the modification of any existing facility which may emit air contaminants into the air of this state shall either
satisfy an exemption from permitting (30 TAC Chapter 106) or obtain an air permit (30 TAC Chapter 116).

Exemptions
Certain new and modified facilities may qualify for an exemption from permitting because their contributions
of air contaminants into the atmosphere are considered insignificant. Surface coating facilities do not need a
permit if they meet the requirements for one of the following exemptions:

• 30 TAC Section 106.231 Manufacturing, Refinishing, and Restoring Wood Products

• 30 TAC Section 106.331 Cosmetics Packaging and Pharmaceutical Packaging and Coating
• 30 TAC Section 106.433 Surface Coat Facility
• 30 TAC Section 106.434 Powder Coating Facility
• 30 TAC Section 106.435 Classic or Antique Automobile Restoration Facility
• 30 TAC Section 106.436 Auto Body Refinishing Facility

Some exemptions require registration, and/or site approval before any construction may begin. Most do not.
Regardless of whether registration is required, any claim of exemption must meet all applicable federal, state,
and local rules and regulations. Form PI-7 Registration Form for Exemptions is a registration of the exemption
and must be submitted when required by the claimed exemption. Additionally, supporting materials are also
useful to document how each requirement of 30 TAC Section 106.4 and each condition of the exemption(s)
claimed will be met. Processing time for the start to finish review of an exemption claim varies; however, the
typical processing time for exemptions is approximately four to six weeks. Shorter processing times can be
promoted by submitting a complete initial registration and supplying any subsequent information in a timely
manner.

Draft Page 2 of 33
Permit Options

This guidance document focuses on requirements for a preconstruction permit as required by 30 TAC
Chapter 116, Subchapter B. The required information is also very similar for authorization through a flexible
permit, as required by 30 TAC Chapter 116, Subchapter G. Normally, it takes six to nine months for issuance
of a construction and operation permit (air quality permit), and three to six months for approval of an
amendment to an existing permit.

Synopsis of permit review

The first step to obtaining a permit is sending a complete application and all subsequent correspondence to the
TCEQ Central Office in Austin, the appropriate TCEQ Regional Office, and any local air pollution control
program(s). Once the TCEQ receives the permit application, it will be assigned to a permit engineer to review
for both administrative and technical completeness of the application. The administrative review is an initial
check to ensure that all the requirements of Form PI-1 (the application) have been addressed in order for the
technical review to be performed.

The first part of the technical review verifies identification of all emission sources and calculation of emission
rates. The permit engineer uses the following information to complete this part of the review: a process
description, a process flow chart, Table 1(a) data, a material usage rate table, Material Safety Data Sheets, and
emission calculations.

After the emission sources have been identified and evaluated, the permit engineer begins reviewing the
proposed control technology. Title 30 TAC Section 116.111 requires the application of the best available
control technology (BACT) for all permitted emission sources. BACT determination is made on a
case-by-case basis, with consideration given to technical practicability and economic reasonableness. Further
discussion of BACT for surface coating is provided in the following chapter (See Chapter 3 “Best Available
Control Technology”).

Also, other requirements of 30 TAC Section 116.111 include: New Source Performance Standards (NSPS),
National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control
Technology (MACT), Prevention of Significant Deterioration (PSD), Nonattainment review, and a review of
the protection of public heath and welfare must be met before permit issuance.

In order to ensure there will be no adverse impacts on the public health and welfare, an off-property air quality
impact (ground-level concentration analysis) is performed for all emission sources. A computer-based
mathematical model (air dispersion modeling) is used to predict the off-property concentrations for each air
contaminant. Predicted off-property concentrations of the proposed emissions are submitted to the TCEQ
Toxicology and Risk Assessment Section for a toxicology review.

Draft Page 3 of 33
During the technical review, the permit engineer will require the applicant of a new or modified facilities to
have two public notice advertisements published in a newspaper with local circulation and post signs at the
facility site for a 30-day public comment period. (Note: Public notice requirements may be waived for certain
modifications to existing permitted facilities). Additional alternate language public notice may also be required
if either the elementary school or the middle school located nearest to the facility provides a bilingual
education program. During the public comment period, anyone directly affected by the potential emissions
from the proposed facility may request a public meeting or hearing and express their concern about the
proposed application.

When all the technical issues have been resolved, the permit engineer will draft the permit special conditions
for review and comments by the appropriate TCEQ regional office, any applicable local program(s), and the
applicant. Once all parties agree on the content of the permit special conditions the permit is issued.

GENERAL REGULATION APPLICABILITY

In addition to the requirements of 30 TAC Chapters 106 and 30 TAC Chapter 116, listed below are additional
regulations that may apply to existing and new surface coating facilities.

Title 30 TAC Chapter 101: General Rules

Definitions
Nuisance
Upset, maintenance, start-up, and shutdown requirements

Title 30 TAC Chapter 111: Visible Emissions and Particulate Matter

Ground level concentrations for particulate matter
Opacity

Title 30 TAC Chapter 113: Toxic Materials

Subchapter C: NESHAP
113.360 Magnetic Tape Manufacturing Operation (40 CFR Part 63, Subpart EE)
113.380 Aerospace Manufacturing and Rework Facilities (40 CFR Part 63,
Subpart GG)
113.400 Shipbuilding and Ship Repair (Surface Coating)

Title 30 TAC Chapter 115: Control of Air Pollution from volatile organic compound (VOC)

Nonattainment areas:
DFW area- Collin, Dallas, Denton, and Tarrant Counties
El Paso area - El Paso County
Beaumont/Port Arthur area - Hardin, Jefferson, and Orange Counties
Houston/ Galveston area - Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty,
Montgomery, and Waller Counties

Draft Page 4 of 33
This chapter also applies to some attainment counties for ozone

Subchapter B: General VOC Sources

Vent Gas Control (115.121-115.123, 115.125-115.127, and 115.129)

Subchapter E: Solvent-Using Process

Surface Coating Processes (115.420-115.427, and 115.429)
Coating Processes (lb VOC/gal of coating, minus H2O & exempt solvent)
(1) Large appliance coating (2.8 lb/gal)
(2) Metal furniture coating (3.0 lb/gal)
(3) Coil coating (2.6 lb/gal)
(4) Paper coating (2.9 lb/gal)
(5) Fabric coating (2.9 lb/gal)
(6) Vinyl coating (3.8 lb/gal)
(7) Can coating (varies)
(8) Vehicle coating - manufacturing and refinishing (varies)
(9) Miscellaneous metal parts and products coating (varies)
(10) Factory surface coating of flat wood paneling (varies)
(11) Architectural coatings - applies to manufacturers/distributors (varies)
(12) Surface coating of mirror backing (varies)
(13) Surface coating of wood parts and products (varies)
(14) Wood furniture manufacturing facilities - after 12/31/99 (varies)
(15) Marine coatings - after 12/31/99 (varies)

Title 30 TAC Chapter 115 gives several options for complying with the surface coating process
rules:
(1) Use compliant coatings;
(2) use add-on control with overall 80% control efficiency; or
(3) Be exempt from rule because of size of emissions (IE., < 3 lb/hr and 15 lb/day),type of
products, or other unusual circumstances [need approval from Engineering Services
Section and/or the Environment Protection Agency (EPA)]

Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60)

Subpart Description

EE Standards of Performance for Surface Coating of Metal Furniture

MM Standards of Performance for Automobile and Light Truck Surface Coating
Operations
RR Standards of Performance for Pressure Sensitive Tape and Label Surface Coating
Operations
SS Standards of Performance for Industrial Surface Coating: Large Appliances

Draft Page 5 of 33
 TT Standards of Performance for Metal Coil Surface Coating
WW Standards of Performance for Beverage Can Surface Coating Industry
FFF Standards of Performance for Flexible Vinyl and Urethane Coating and Printing
TTT Standards of Performance for Industrial Surface Coating: Surface Coating of
Plastic Parts for Business Machines
VVV Standards of Performance for Polymeric Coating of Supporting Substrates
Facilities

NESHAP/MACT: See 30 TAC Chapter 113 above, 40 CFR Part 61, and 40 CFR Part 63

Draft Page 6 of 33
Chapter 3 - Best Available Control Technology
Title 30 TAC Section 116.111(2)(C) requires the application of BACT for all permitted emission sources.
BACT determination is made on a case-by-case basis, with consideration given to technical practicability and
economic reasonableness. Current BACT practices for surface coating operations are discussed below.

A. SOURCE REDUCTION

Permit applications should include an analysis of source reduction methods. Source reduction means
elimination or reduction of air pollutants before they are produced, usually by a process change or material
substitution. Conversely, source reduction is not destruction or capture of an air pollutant by a control device
after it is created. Some of the guidelines discussed below are considered source reduction or process controls:

Volatile Organic compound (VOC): Use of H2O-based (low VOC) coatings, high solid content coatings,
ultraviolet (UV) coatings, electron beam coatings, and/or powder
coating

Application Method: Use of high transfer efficiency spray equipment (IE., HVLP, electrostatic, airless, flow
coating, dipping, rolling, and/or brushing)

PM: Use at least 95% efficient filters, and at least 99% efficient filters for coatings that
contain significant amounts of heavy metals

Good Housekeeping: (a) Immediate cleanup of all spills

(b) Waste coatings, solvents, and spent cleanup solvents are stored in sealed
containers until removal from the site by an authorized disposal service or until
emptying into authorized on-site waste management facilities.
(c) No visible dust emissions from handling, storage, and disposal of particulate
matter captured in the spray booth dust collection systems

In addition, proper ventilation design should be incorporated to minimize fugitive emissions in order to provide
improved off property impacts. This would include spray booth and work area fans operate during all spray
gun and equipment cleanup.

B. ADD-ON CONTROL

If site-wide VOC [may include exempt solvent] emissions are greater than 80 tons per year (TPY) for manned
coating operations after applying process control or source reduction methods, then addition of abatement
control equipment is required in most cases. Likewise, the same BACT analysis procedure shall apply for
VOC [may include exempt solvent] emissions from unmanned (automated or robotic) coating operations
greater than 40 TPY.

Draft Page 7 of 33
These levels are guidelines to show the applicant what the TCEQ currently considers as BACT; however, these
control levels are subject to change. Each applicant is required to submit a detailed BACT analysis if
proposing any controls not listed above. The BACT discussion format needs to follow the TCEQ “three tier”
method or the EPA “top down” method. Regardless of the analysis used, applicants must supply control
equipment cost estimates (amortized over the life of the control equipment) and annualized operating costs.
The EPA document OAQPS Control Cost Manual (EPA 450/3-90-006) describes how to perform the analysis
and provides the format to use for presentation of results.

Draft Page 8 of 33
Chapter 4—Emission Factors, Efficiencies, and Calculations
This chapter provides detailed instructions for calculating emissions from surface coating operations.
Calculation examples are also included to assist if a boiler, furnace, or drying oven is used as part of the
operation. Other methods of estimating emissions may be employed providing that sufficient documentation is
submitted to support the method.

Chapter 4 Contents
Spray Coating Calculations
Dip Coating Calculations
Products of Combustion From Natural Gas -- Calculations

Spray Coating Calculations. Before beginning the emission calculations, it is important to gather certain
information. The following items should be sufficient to calculate any coating calculation.

I. Gather Data.

1. Determine the maximum spray rate of the spray equipment using manufacturers data or the maximum
projected actual spray rates in gallons per hour (gal/hr): . In most cases, the manufacture’s data will
base the maximum spray rates on specific application equipment and on the orifice size of the spray nozzle.
The manufacturers usually list the spray rates in either gallons per minute or ounces per minute. If the
usage is listed in one of these units, it will need to be converted into gallons per hour.

Ex: Airless Spray Gun

Orifice Size = 0.055"
Spray Rate = 8 ounces/min = 8 ounces/min x 60 min/hr x gal/128 ounces = 3.75 gal/hr

2. Estimate the maximum annual usage rate from records of past usage at your facility. In addition, future
production increases should be accounted for in estimating material usage rates. (gal/yr):

Ex: Production Increase = 15%

Past Coatings Usage = 1500 gal/yr
Projected Coatings Usage =1500 gal/yr x (1+ 0.15) =1725 gal/yr

3. Obtain the density of the coating from the manufacturer' s Material Safety Data Sheet (MSDS). The MSDS
often lists the specific gravity (the density of the coating relative to the density of water). (lb/gal):

Ex: Density = 9.76 lb/gal; or

Specific Gravity = 1.17
Coating Density = 1.17 x (Density of Water = 8.345 lb/gal) = 9.76 lb/gal

Draft Page 9 of 33
4. Obtain the maximum and average volatile organic compound content of the coating from the MSDS. The
VOC content is often listed on the MSDS as the % volatile by weight. The maximum VOC content of any
coating should be used as a worst case for hourly emissions and the average VOC content of all coatings
could be used for annual emissions. (lb/gal):
Note: Applicants should ensure that this value does not include water as a volatile component.

Ex: Maximum VOC Content = 3.6 lb/gal

Average VOC Content = 3.0 lb/gal

5. Obtain the maximum and average solids or particulate matter (PM) content of the coating from the MSDS.
The solids content is often listed on the MSDS as % solids by weight from which the solids content can be
calculated given the coating density. The maximum PM content of any coating should be used as a worst
case for hourly emissions and the average PM content of all coatings could be used for annual emissions.
(lb/gal):
Note: This can also be obtained by subtracting the solvent (liquid portion, i.e. VOC, exempt solvent,
and water) content of the coating from the coating density.

Ex: Max. % solids by weight = 63.13%

Avg. % solids by weight = 55.00%
Max. Solids Content = 9.76 lb/gal x 0.6313 = 6.16 lb/gal
Avg. Solids Content = 9.76 lb/gal x 0.55 = 5.37 lb/gal

6. Determine the weight percent (wt%) of each chemical of the coating using the MSDS or manufacturers
data. Be sure to include the CAS number if it is available. (%):
Note: The sum of the weight percents of all constituents should be at least 100%.

Draft Page 10 of 33
 Name CAS No. Wt. %
Toluene 108-88-3 35%
MAK 78-13-3 < 8%
Silica - Amorphous 61790-53-2 0.5 - 1.0 %
Resin 11%

NOTE: THIS IS VERY IMPORTANT. In order to conduct a proper health effects review, this information
must be known (some species of VOC and PM are more toxic than others). If the MSDS does not provide
100% of the chemicals in a coating, request that the manufacturers provide a complete list. If they are reluctant
to reveal all constituents to you, they can send a complete list directly to the TCEQ. The TCEQ has rules and
procedures for handling confidential information, i.e., keeping it confidential.

7. Coatings are often mixed or thinned with catalysts and solvents prior to application. Emissions should be
calculated for coatings as they are applied. Note: Isocyanates and diisocyanates are common
components of catalysts. If these are included in the coating contact the manufacturer and ask them
if they are emitted. It is usually acceptable to assume that the isocyanate-based compounds are
totally reactive with the paint when mixed and therefore are not emitted.

8. Estimate the percent overspray (% overspray) using the attached Table 1. Data from transfer efficiency
testing or application equipment vendors are also acceptable.(%):

Ex: Airless Spray Method

Relatively Flat Surface
Overspray % = 20%
Transfer Efficiency % = (1- Overspray) = 80% = 0.80

10. Obtain the paint booth filter efficiency from the filter vendor or manufacturer. The overall efficiency
should be at least 95 percent.
(%):

Ex: Filter Efficiency (F.E.) = 96% = 0.96

11.Estimate the amount of VOC emitted inside the spray booth (Booth
Flash off) and the amount of VOC emitted outside the spray booth (Fugitive Flash off = 1 - Booth Flash
off). Use coating manufacturers data or the attached Figure 1. (%):

Ex: From Figure 1.

Polyurethane Paint (use curve 5)
Booth Time = 30 min.
Booth Flash off = 55%

Draft Page 11 of 33
 Fugitive Flash off = 45%

II. Calculation of Total VOC and PM Emissions

These calculations are necessary to estimate overall VOC and PM (Particulate Matter) emissions. This data is also
used to complete Table 1(a) which is required with the permit application, Form PI-1.

Step 1: CALCULATE SHORT TERM EMISSIONS

1. Total VOC (Booth and Fugitive)

Spray rate x Max VOC content = VOC lb/hr

3.75 gal/hr x 3.6 lb/ gal = 13.5 lb/hr VOC

2. Fugitive VOC Emissions

Total VOC x T.E. x fugitive flash off = VOC lb/ hour

13.5 lb/hr x 0.80 x 0.45 = 4.9 lb/hr VOC

3. Booth VOC Emissions (rigorous method)

(Total VOC x T.E. x booth flash off) + (total VOC x % overspray)

= VOC lb/ hr

(13.5 lb/hr x 0.80 x 0.55) + (13.5 lb/hr x 0.20) = 8.6 lb/hr VOC

4. Booth Emissions (simple method)

total VOC - fugitive VOC = booth VOC lb/hr

13.5 lb/hr - 4.9 lb/hr = 8.6 lb/hr VOC

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 5. PM Emissions
Note: All PM emissions will be in the booth.

Spray rate x max. PM content x (1 - T.E.) x (1 - F.E.) = PM lb/hr

3.75 gal/hr x 6.16 lb/gal x (1 - 0.80) x (1 - 0.96) = 0.18 lb/hr PM

Step 2: CALCULATE ANNUAL EMISSIONS

1. Total VOC Emissions (Booth and Fugitive)

Annual usage x avg. VOC content x 1 ton/2000 lb = VOC ton/yr

1725.0 gal/yr x 3.0 lb/gal x 1 ton/2000 lb = 2.6 ton/yr VOC

2. Fugitive VOC Emissions

Total VOC x T.E. x fugitive flash off = VOC ton/yr

2.6 ton/yr x 0.80 x 0.45 = 0.94 ton/yr VOC

3. Booth VOC Emissions (rigorous method)

(Total VOC x T.E. x booth flash off) + (total VOC x % overspray)

= VOC ton/yr

(2.6 ton/yr x 0.80 x 0.55)+(2.6 ton/yr x 0.20) =1.66 ton/yr VOC

4. Booth VOC Emissions (simple method)

Total VOC - fugitive VOC = booth VOC

2.6 ton/yr - 0.94 ton over yr = 1.66 ton/yr VOC

5. PM Emissions
Note: All PM emissions will be in the booth.

{Annual usage x avg. PM content x (1 - T.E.) x (1 - F.E.) x

1 ton}/2000 lb = PM ton/yr

{1725.0 gal/yr x 5.37 lb/gal x(1 - 0.80) x (1 - 0.96) x 1 ton}/

2000 lb = 0.04 ton/yr PM

Draft Page 13 of 33
Step 3: ENTER THE RESULTS FROM STEPS 1 AND 2 INTO TABLE 1(a) AND SUBMIT IT
WITH THE APPLICATION.

Example:

Table 1(a)
EPN Name Contaminant #/hr TPY
Name
SB1 Spray Booth VOC 8.60 1.66
PM 0.18 0.04
F1 Fugitive VOC 4.90 0.94

III. Calculation of Speciated VOC and PM Emissions

These calculations are necessary to complete a health effects review, and should be submitted with each application
for a permit. In order to complete a proper health effects review, it is necessary to know the emission rate of each
chemical (species) contained in a coating. The results should be used to fill in columns 1 and 3 of the attached
Table 2 titled “Health Effects Review”.

Step 1: CALCULATE SHORT TERM SPECIATED EMISSION RATES.

1. Calculate a generic short term weight percent factor to be used for all VOC species.
spray rate x density x wt% of species = wt% lb/hr
3.75 gal/hr x 9.76 lb/gal x wt% = 36.6 wt% lb/hr
2. Calculate short-term emission rates for each VOC species using the generic weight percent factor calculated
above.
Wt% of
VOC Wt% lb/hr Species lb/hr
MAK 36.6 x 0.08 = 2.93
Toluene 36.6 x 0.35 = 12.81

Note: This information should be used to fill in columns 1 and 3 of the Table titled “Health Effects
Review”. Remember to include the CAS number of each chemical in column 2. The CAS
number can be obtained from the MSDS, a chemical dictionary, or the coating manufacturer.

3. Break up the short-term emission rates into booth and fugitive emissions in a similar manner as was done for
total VOC in Calculation of Total VOC and PM Emissions. (Substitute the lb/hr emission rate of each
species for the spray rate and VOC content used in Calculation of Total VOC and PM Emissions.) Note:
VERY IMPORTANT! For a health effect review, the sources of emissions must be known.

Fugitive (for MAK):

Draft Page 14 of 33
 MAK lb/hr x T.E. x fugitive flash off = fugitive MAK lb/hr
2.93 lb/hr x 0.80 x 0.45= 1.05 lb/hr fugitive ~ MAK
etc.
Booth (rigorous method):

(MAK lb/hr x T.E. x booth flash off)+ (MAK lb/hr x % overspray) = booth MAK lb/hr
(2.93 lb/hr x 0.80 x 0.55) + (2.93 lb/hr * 0.20)
= 1.88 lb/hr booth MAK

etc.

Booth (simple method):

MAK lb/hr - fugitive MAK lb/hr = booth MAK lb/hr
2.93 lb/hr - 1.05 lb/hr = 1.88 lb/hr booth MAK
4. Calculate a generic short-term weight percent factor to be used for all PM species.

spray rate x density x wt% of species x (1 -T.E.) x (1-F.E.) = wt% lb/hr

3.75 gal/hr x 9.76 lb/gal x wt% of species x (1-0.80) x (1- 0.96) = 0.29 wt% lb/hr

5. Calculate short-term emission rates for each PM species. Note: All PM emissions should occur within
the booth.

Wt% of
VOC Wt% lb/hr Species lb/hr

Silica 0.29 x 0.01 = 0.0029

Resin 0.29 x 0.11 = 0.0319

Note: This information should be used to fill in columns 1 and 3 of the Table 2 entitled “Health Effects
Review”. Remember to include the CAS number of each chemical in column 2. The CAS number
can be obtained from the MSDS, a chemical dictionary, or the coating manufacturer.

Draft Page 15 of 33
Step 2: CALCULATE ANNUAL SPECIATED EMISSION RATES.

1. These emission rates are seldom required, you will be notified if they are necessary. DO NOT
PERFORM THESE CALCULATIONS UNLESS INSTRUCTED TO DO SO.

2. The method of calculation is analogous to the short term speciated emission rates. For any necessary
assistance, contact the Coatings and Combustion Section in the Office of Air Quality New Source
Review Permits Division of the TCEQ in Austin.

IV. Calculation of Emission Rates for Multiple Part Coatings

Many coatings must be thinned and many contain several parts as well. For example, many coatings require a
catalyst and must also be thinned. For these coatings, spray rates must be determined for each part (the thinner,
the catalyst, and the coating) to be used in the calculations in Calculation of Total VOC and PM Emissions
Sections and Calculation of Speciated VOC and PM Emissions.

Note: Only examples of short term emission rates for multiple part coatings are shown here. Annual
emission rates are based on yearly usage of each part and should be calculated as shown in
Calculation of Total VOC and PM Emissions, Step 2 and may need to be speciated (See:
Calculation of Speciated VOC and PM Emissions, Step 2).

Example 1: SINGLE PART COATING WITH THINNING

Coating = 5 parts (VOC = 3.0 lb/gal, PM = 3.5 lb/gal)

Thinner = 1 parts (Density = 6.5 lb/gal, VOC = 100% by wt.)

1. Mixing Ratio.
Thinned coating: 5 gallons coating + 1 gallon solvent
= 6 gallons mixed coating
Coating Fraction = 5/6
Solvent Fraction = 1/6

2. To calculate the hourly VOC emission rate:

spray rate x [(VOC content x 5/6) + (density of thinner x 1/6) ] =VOC lb/hr
3.75 gal/hr x [(3.0 lb/gal x 5/6)+(6.5 lb/gal x 1/6)] = 13.44 lb/hr VOC

3. To calculate the hourly PM emission rate:

spray rate x (PM content x 5/6) x (1 - T.E.) x (1 - F.E.) = PM lb/hr

3.75 gal/hr x (3.5 lb/gal x 5/6) x (1 - 0.80) x (1 - 0.96) = 0.09 lb/hr PM

Note: The thinner has no PM content.

Draft Page 16 of 33
 4. Calculate VOC and PM emission rates as in Calculation of Total VOC and PM Emissions and
speciated emission rates as in

SUBSTITUTE THE COATING EMISSION RATE OR THE THINNER EMISSION RATE FROM
STEP 3 OF THIS SECTION FOR THE SPRAY RATE OF THOSE SECTIONS.

Note: Solvents common to the thinner and coating should be summed. For example, if both the
coating and thinner contain MEK, then total MEK should be summed.

Example 2: CATALYZED COATINGS.

Coating = 3 parts (VOC = 3.3 lb/gal, PM = 3.6 lb/gal)

Catalyst = 2 parts (Density = 5.0 lb/gal, VOC = 100% by wt.)

1. Mixing Ratio.

Coating Mixture: 3 gallons coating + 2 gallon catalyst

= 5 gallons mixed coating
Coating Fraction = 3/5
Catalyst Fraction = 2/5

2. To calculate the hourly VOC emission rate:

spray rate x [(VOC content x 3/5)+ (density of catalyst x 2/5)]

= VOC lb/hr
3.75 gal/hr x [(3.3 lb/gal x 3/5) +(5.0 lb/gal x 2/5)] = 14.93 lb/hr VOC

3. To calculate the hourly PM emission rate:

Note: The catalyst has no PM content.

spray rate x (PM content x 3/5) x (1- T.E.) x (1 - F.E.) = PM lb/hr

3.75 gal/hr x (3.6 lb/gal x 3/5) x (1 - 0.80) x (1- 0.96)=0.06 lb/hr PM

4. Calculate VOC and PM emission rates as in Calculation of Total VOC and PM Emissions and
speciated emission rates as in Calculation of Speciated VOC and PM Emissions.

SUBSTITUTE THE COATING EMISSION RATE OR THE CATALYST EMISSION RATE

FROM STEP 3 OF THIS SECTION FOR THE SPRAY RATE OF THOSE SECTIONS.

Draft Page 17 of 33
Dip Coating Calculations
I. Gather Data

1. Determine the maximum usage rate of all coatings, thinners, and catalysts (gal/hr):

Ex: Usage Rate = 5.0 gal/hr

Note: The usage rate should be based on the amount of coating, thinner, or catalyst required to
refill the dip tank after one hour at the maximum possible production rate. This is
important because usage limitations in the permit, if issued, may be based upon
production rates.

2. Estimate annual usage from records of past usage at your facility and using production projections
(gal/yr):

Ex: Annual Usage = 1000 gal/yr

3. Obtain the density of the coating, thinner, or catalyst from the manufacturer'
s Material Safety Data
Sheet (MSDS) (lb/gal):

Ex: density = 8.32 lb/gal

4 Obtain the maximum VOC content of the coating, thinner, or catalyst from the MSDS. (lb/gal):

Ex: VOC content = 6.00 lb/gal

NOTE: Thinners are almost always 100% VOC.

5. Determine the weight percent (wt%) of each chemical of the coating, thinner, or catalyst using the
MSDS or manufacturers data (%):
Ex: 0.38 = wt% of Xylene in the coating.

NOTE: THIS IS VERY IMPORTANT! In order to conduct a proper health effects review, this
information must be known (some species of VOC are more toxic than others). If the
MSDS does not provide 100% of the chemicals in a coating, request that the
manufacturers provide a complete list. If they are reluctant to reveal all constituents to
you, they can send a complete list directly to the TCEQ. The TCEQ has rules and
procedures for handling confidential information, i.e., keeping it confidential.

6. Gather maximum mixing and thinning ratios for single and multiple part coatings (ratio):

Ex: 1 part thinner: 6 parts coating

7. Estimate the amount of VOC emitted inside areas in which the emissions are captured and vented to a
stack (captured flash off), and the amount of VOC emitted outside controlled areas (fugitive flash

Draft Page 18 of 33
 off = 1 - captured flash off). For example, dipping occurs in an airtight room in which the emissions
are captured and directed to a stack, and then coated parts are set in an open uncontrolled area to dry.
Use the attached Figure 1.
(%):

Ex: Captured Flash off = 90% = 0.90

(i.e., 90% of the VOC will flash off in dipping room, 10% will flash off as fugitive. This was obtained
using Curve 1 of Figure 655 for lacquer and by estimating that the parts are removed from the dipping
room 3 minutes after dipping.)

Note: When dipping, the transfer efficiency is 100%, and no particulates are emitted.

II. Calculation of Total VOC Emissions

These calculations are necessary to estimate overall VOC emissions. They are also needed to complete Table 1(a)
that is required with the application for a permit, Form PI-1 General Application Instructions. VOC emissions can
be broken down into captured and fugitive emissions. Fugitive emissions are those emissions that are not captured
and vented to a stack. It is assumed that for the majority of dipping operations, all VOC emissions will be fugitive.

Step 1: CALCULATE SHORT-TERM EMISSIONS

1. Total VOC (Captured and Fugitive)

usage rate x VOC content = VOC lb/hr

5.0 gal/hr x 6.0 lb/gal = 30.0 lb/hr VOC

2. Fugitive VOC Emissions

Note: Fugitive VOC emissions are those that occur outside areas where emissions are captured
and controlled, open drying areas. See Overview, Paragraph 7.
total VOC x fugitive flash off = VOC lb/hour
30.0 lb/hr x 0.10 = 3.0 lb/hr VOC
3. Captured VOC Emissions (rigorous method)
total VOC x captured flash off = VOC lb/hr
30.0 lb/hr x 0.90 = 27.0 lb/hr VOC
4. Captured Emissions (simple method)
total VOC - fugitive VOC = captured VOC lb/hr
30.0 lb/hr - 3.0 lb/hr = 27.0 lb/hr VOC

Step 2: CALCULATE ANNUAL EMISSIONS

1. Total VOC Emissions (Captured and Fugitive)

annual usage x VOC content x 1 ton/2000 lb = VOC ton/yr
1000.0 gal/yr x 6.0 lb/gal x 1 ton/2000 lb = 3.0 ton/yr VOC

Draft Page 19 of 33
 2. Fugitive VOC Emissions:
total VOC x fugitive flash off = VOC ton/yr
3.0 ton/yr x 0.10 = 0.30 ton/yr VOC
3. Captured VOC Emissions (rigorous method):
total VOC x captured flash off = VOC ton/yr
3.0 ton/yr x 0.90 = 2.70 ton/yr VOC
4. Captured VOC Emissions (simple method)
total VOC - fugitive VOC = captured VOC
3.0 ton/yr - 0.30 ton/yr = 2.70 ton/yr VOC

Step 3: ENTER THE RESULTS FROM STEPS 1 AND 2 INTO TABLE 1(a) AND SUBMIT IT WITH
THE APPLICATION.

Example:

Table 1(a)
EPN Name Contaminant Name #/hr TPY

DR1 Dip Room VOC 27.00 2.70

F1 Fugitive VOC 3.00 0.30

III. Calculation of Speciated VOC Emissions

These calculations are necessary to complete a health effects review, and should be submitted with each application
for a permit. In order to complete a proper health effects review, it is necessary to know the emission rate of each
chemical (species) contained in a coating. The results should be used to fill in columns 1 and 3 of the attached
Table 2 entitled “Health Effects Review”.

Draft Page 20 of 33
Step 1: CALCULATE SHORT-TERM SPECIATED EMISSION RATES.

1. Calculate a generic short-term weight percent factor to be used for all VOC species.
usage rate x density x wt% of species = wt% lb/hr
5.0 gal/hr x 8.32 lb/gal x wt% = 41.60 wt% lb/hr
2. Calculate short-term emission rates for each VOC species using the generic weight percent factor
calculated above.

Wt% of
VOC Wt% lb/hr Species lb/hr

Xylene 41.60 x 0.38 = 15.81

Toluene 41.60 x 0.35 = 14.56
MIBK 41.60 x 0.01 = 0.42

Note: This information should be used to fill in columns 1 and 3 of the Table 2 entitled “Health
Effects Review”. Be sure to include the CAS number of each chemical in column 2. The
CAS number can be obtained from the material safety data sheets, a chemical dictionary,
or the coating manufacturer.

3. Break up the short-term speciated emission rates into captured and fugitive emissions in a similar manner
as was done for total VOC in Calculation of Total VOC and PM Emissions. (substitute the lb/hr
emission rate for each species for the usage rate and VOC content used in Calculation of Total VOC and
PM Emissions)
Note: This is important. For a health effects review, it is necessary to know the source of
emission.

Fugitive (for Xylene):

xylene lb/hr x fugitive flash off = fugitive xylene lb/hr
15.81 lb/hr x 0.10 = 1.58 lb/hr fugitive xylene

etc.
Captured (rigorous method):
xylene lb/hr x captured flash off = captured xylene lb/hr
15.81 lb/hr x 0.90 = 14.23 lb/hr captured xylene

etc.
Captured (simple method):
xylene lb/hr - fugitive xylene lb/hr = captured xylene lb/hr
15.81 lb/hr - 1.58 lb/hr = 14.23 lb/hr captured xylene

etc.

Draft Page 21 of 33
Step 2: CALCULATE ANNUAL SPECIATED EMISSION RATES.

1. These emission rates are seldom required. You will be notified if they are necessary. DO NOT
PERFORM THESE CALCULATIONS UNLESS INSTRUCTED TO DO SO.

2. The method of calculation is analogous to the short term speciated emission rates. For any necessary
assistance, contact the Coatings Section in the Office of Air Quality New Source Review Division of the
TCEQ in Austin.

IV. Calculation of Emission Rates for Multiple Part Coatings

Many coatings must be thinned and many contain several parts as well. For example, many coatings require a
catalyst and must also be thinned. For these coatings, maximum usage rates must be determined for each part
(the thinner, the catalyst, and the coating) to be used in the calculations in Sections II and III above. The
emission rates for the coating, thinner, and catalyst must be calculated separately using the methods of Sections
II and III.

Note: Solvents common to the thinner and coating should be summed. For example, if both the coating
and thinner contain methylethylketone (MEK). then total MEK emission rates should be summed
for each emission point after the individual calculations.

Draft Page 22 of 33
Natural Gas Combustion Calculations

Many coatings facilities employ natural gas-fired boilers, furnaces, and drying ovens. The following method of
calculating emissions due to the combustion of natural gas employs estimates taken from Section 1.4 of the
U.S. Environmental Protection Agency Document AP-42, “Compilation of Air Pollutant Emission Factors.”
Combustion of Liquefied Petroleum Gas (LPG) is covered in Section 1.5 of AP-42, and the combustion of fuel
oil is covered in Section 1.3.

I. Gather Data.

1. Determine the heat input rating of the boiler, furnace, or drying oven using manufacturer’s
specifications (BTU/hr):

Ex: heat input = 15 million BTU/hr

2. Determine the heating value of the natural gas that you use. If unknown, use the value given by AP-42,
1000 BTU/scf (scf = standard cubic foot) (BTU/scf):

Ex: heating value = 1000 BTU/scf

3. Obtain the applicable uncontrolled emission factor from Table 1.4-1 of AP-42, Section 1.4 (lb/mmcft):

Ex: Particulate (PM)* = 13.7 lb/106ft3

Sulfur Dioxide (SO2) = 0.6 lb/106ft3
Nitrogen Oxides (NOx) = 140 lb/106ft3
Carbon Monoxide (CO) = 35 lb/106ft3
TOC = 5.8 lb/106ft3

* PM is the sum of filterable and condensable PM

NOTE: If there is a range of emission factors, use the largest number in the range, unless using a
smaller one can be justified and documented. For example, if the sulfur content of the
natural gas can be provided by the supplier, and that sulfur content can be documented as
constant, then that emission factor may be substituted.

4. Determine the desired annual operating hours for the permit

(hr/yr):

Ex: operating hours = 8760 hr/yr

II. Calculation of Emissions From Combustion of Natural Gas

These calculations are needed to complete Table 1(a) that is required with the application for a permit, Form
PI-1 “General Application Instructions”

Draft Page 23 of 33
Step 1: CALCULATE MAXIMUM HOURLY EMISSIONS

Heat input/heating value x emission factor = lb/hr

(15,000,000 BTU/hr÷1000 BTU/scf) x (13.7 lb PM ÷ 1,000,000 cft)
= 0.20 lb/hr PM
(15,000,000 BTU/hr÷1000 BTU/scf) x (0.6 lb SO2 ÷ 1,000,000 cft)
= 0.01 lb/hr SO2
(15,000,000 BTU/hr÷1000 BTU/scf) x (140 lb NO2 ÷ 1,000,000 cft)
= 2.10 lb/hr NO2
(15,000,000 BTU/hr÷1000 BTU/scf) x (35 lb CO ÷ 1,000,000 cft)
= 0.53lb /hr CO
(15,000,000 BTU/hr÷1000 BTU/scf) x (5.8 lb TOC ÷ 1,000,000 cft)
= 0.09 lb/hr TOC

Step 2: CALCULATE ANNUAL EMISSIONS.

lb/hr x operating hours x 1 ton/2000 lb = TPY
0.20 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 0.90 TPY PM
0.01 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 0.04 TPY SO2
2.10 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 9.20 TPY NO2
0.53 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 2.32 TPY CO
0.09 lb/hr x 8760 hr/yr x 1 ton/2000 lb = 0.38 TPY TOC

Step 3: ENTER THE RESULTS FROM STEPS 1 AND 2 INTO TABLE 1(a) AND SUBMIT IT
WITH THE APPLICATION.
Example:

Table 1(a)
EPN Name Contaminant Name #/hr TPY
EPN1 Boiler PM 0.20 0.90
SO2 0.01 0.04
NOx 2.10 9.20
CO 0.53 2.32
TOC 0.09 0.38

Draft Page 24 of 33
 Table 1
PERCENT OVERSPRAY AS A FUNCTION OF SPRAYING METHOD
AND SPRAYED SURFACE

Method of Spraying Flat Surfaces Table Leg Bird Cage Surface

Surfaces
Air Atomization 50 85 90
Airless 20 to 25 90 90
Electrostatic
Disc 5 5 to 10 5 to 10
Airless 20 30 30
Air-atomized 25 35 35
Table 232 - Air Pollution Engineering Manual, Second Edition, AP-40, U.S. Environmental Protection
Agency, May, 1973

Draft Page 25 of 33
 Table 2
HEALTH EFFECTS REVIEW

NAME OF CAS EMISSION MAXIMUM EFFECTS

SPECIES NUMBER RATES OFF-PROPERTY SCREENING
(lbs/hour) CONCENTRATIONS LEVEL
(CURRENT LIST)

Draft Page 26 of 33
 Figure 1

Figure 655 - Air Pollution Engineering Manual, Second Edition, AP-40, U.S. Environmental Protection
Agency, May, 1973

Draft Page 27 of 33
 DRAFT PERMIT SPECIAL CONDITIONS
Note: These are sample special conditions that may be found in a permit for the coating industry.
You are reminded that special conditions are facility specific and the special conditions may
not include or be limited to the following examples.

Draft Page 28 of 33
 SPECIAL CONDITIONS

Permit No. 12345

GENERAL

1. This permit authorizes the construction and operation of a metal parts manufacturing
facility. These facilities are located at 1234 No Name Street, Austin, Travis County.

OPERATING CONDITIONS AND RESTRICTIONS

2. All equipment shall be operated and maintained within the limits and specifications set
forth by the manufacturer.

3. Opacity of emissions from any emission point shall not exceed 5 percent as determined by
Environmental Protection Agency Method 9 except for those periods described in Texas
Commission on Environmental Quality (TCEQ) 30 TAC Section 111.111.

4. Emissions from the spray booths shall be exhausted vertically through elevated stacks with
a minimum height from ground level of 33 feet. In addition, the stacks shall not be
equipped with rain protection that causes restrictions or obstructions to vertical discharge.

5. High-volume, low-pressure paint application equipment or other equipment that is proven

to reach the same or higher transfer efficiency shall be used.

6. All emissions from the paint booths shall be exhausted through a particulate removal
system that achieves an overall particulate removal efficiency of 95 percent.

7. Parts that have been coated or painted shall remain in the paint booth with the exhaust
system in operation for a minimum of five minutes.

8. This permit allows the use of volatile organic compounds (VOC), non-VOC, and
particulate matter (PM)-containing compounds or products which meet the following
conditions:

A. The new or replacement compound/product shall serve the same basic function,
and the emissions shall be emitted from the same location as the replaced
compound/product.

B. The Effects Screening Level (ESL) for any new or replacement speciated
ingredient contained in the new or replacement product shall not be less than the
ESL value for the replaced speciated ingredient, and the emission rate (ER) for the
replacement ingredient shall not be greater than the ER for the replaced ingredient,
except if the following condition is met:
 where:
BERNEW
is the
ER
(lbs/hr) of replacement speciated ingredient (chemical) being
exhausted from the spray booth stacks.

FERNEW is the ER (lbs/hr) of replacement speciated ingredient (chemical) being

exhausted as a fugitive emission.

ESLNEW is the ESL of the replacement speciated ingredient (chemical).

The 30-minute ESL value for any new chemical emitted that is not represented in
the permit application is limited to the use of the TCEQ-approved ESL for the
individual chemical contained in the TCEQ ESL list dated September 5, 1997.
The use of new chemicals not listed in the September 5, 1997 ESL list will require
an amendment to this permit unless they meet paragraph C of this condition.
If new chemicals are used that are contained in the TCEQ ESL list dated
September 5, 1997, and their ESL is less than (more toxic than) 10 g/m3 for PM
and 50 g/m3 for VOC and non-VOC emissions, this condition does not apply.
Before any chemicals that are more toxic than the limits specified above are
introduced, an amendment to this permit will be required.

C. If the TCEQ ESL list dated September 5, 1997 does not include the replacement
speciated ingredient, an ESL derived by the TCEQ Toxicology and Risk
Assessment Section shall be used. The ESL shall be obtained in writing prior to
the use of the replacement ingredient.

D. This condition allows for changes in coatings formulations and does not allow for
any increase in total emissions from any emission point.

RECORDKEEPING

9. General Condition No. 7 regarding information and data to be recorded shall be

supplemented as follows:

A. Material Safety Data Sheets for all materials currently in use and those in use for
the previous two years.

B. Data of the daily actual hours of all operations with the potential of emitting air
contaminants and the daily amounts of all materials with the potential of emitting
VOCs.

Draft Page 30 of 33
 C. The data recorded in Special Condition No. 9B shall be used to produce a monthly
report that represents the VOC emissions from each emission point as shown on
the maximum allowable emission rates table (MAERT) in pounds per hour on a
daily basis and tons emitted for the previous 12-month period. The report shall
include examples of the method of data reduction including units, conversion
factors, assumptions, and the basis of the assumptions.

GOOD INDUSTRIAL HOUSEKEEPING

10. All paint gun cleanup shall be performed in an enclosed spray gun cleaning system. The
waste shall be removed from the site by a licensed disposal service unless reused or
recycled.

11. All waste paint, solvents, and cleanup rags shall be stored in sealed containers until
removed from the site by a licensed disposal service unless reused or recycled.

12. The filters that are used to remove particulate matter shall be removed and disposed of in
such a manner that prevents trapped particulates from escaping into the atmosphere.

13. All spills of materials that have the potential to emit air contaminants shall be cleaned up
immediately, and the waste materials shall be stored in sealed containers until removed
from the site by a licensed disposal service.

DETERMINATION OF COMPLIANCE

14. The records required in Special Condition No. 9 shall constitute the method of
demonstrating continuous compliance with the limits specified in the MAERT.

15. All equipment that has the potential of emitting air contaminants shall be physically
identified and marked in a conspicuous location as follows:

A. The facility identification numbers as submitted to the Emissions Inventory

Section of the TCEQ.

B. The emission point numbers as listed on the MAERT.

Dated

Draft Page 31 of 33
 EMISSION SOURCES - MAXIMUM ALLOWABLE EMISSION RATES
Permit No. 12345

This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant’s
property covered by this permit.

AIR CONTAMINANTS DATA

Emission Source Air Contaminant Emission Rates *

Point No. (1) Name (2) Name (3) lb/hr TPY

PB-1 Paint Booth No. 1 VOC 36.5 13.0

PM 0.1 0.2

PB-2 Paint Booth No. 2 VOC 18.0 8.1

PM 0.1 0.1

FUG-1 Fugitive Drying Area VOC 9.3 7.7

(1) Emission point identification - emission point number from plot plan.
(2) Specific point source name.
(3) VOC - volatile organic compounds as defined in General Rule 101.1
PM - particulate matter, suspended in the atmosphere, including PM10.
PM10 - particulate matter equal to or less than 10 microns in diameter.

* Emission rates are based on and the facilities are limited by the following maximum operating schedule:

8 Hrs/day 6 Days/week 52 Weeks/year or 2,496 Hrs/year

Dated
References

Air Pollution Engineering Manual, Second Edition, AP-40, U.S. Environmental Protection Agency,
May, 1973

Compilation of Air Pollutant Emission Factors, AP-42, U.S. Environmental Protection Agency, Research
Triangle Park, NC, 199x

Draft Page 33 of 33