Abatement Control Standards
For Surface Coatings

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Q:  I work for a company that has a large painting operation and we are being expected to install an abatement device to abate the VOC and HAP emissions.  What are the standards for abatement? 

A:  Without knowing more about your operation I will give you a somewhat generic answer. If you are subject to Best Available Control Technology (BACT) the requirements will be more stringent than if you voluntarily install an abatement device without the need to meet a specific regulation. The standards for abatement will also depend on the industry you are in, the type of products you are painting, where your company is located, (in an attainment or non-attainment area) and the costs to abate.

A good place to start is to browse the EPAs BACT Clearinghouse at http://www.epa.gov/ttn/catc/ and while you are about it also visit the California Air Resources Board BACT Clearinghouse at www.arb.ca.gov/bact/bact.htm . 
To illustrate how this works, go to the ARB site and search the BACT database. Look under Category #161, spray booths. Once you have arrived at the Spray Booth page scroll down until you see a coating operation that closely fits your own operation. It is quite possible that you won’t find an exact match, but you should find something close.

For instance, I arbitrarily scrolled down to Arbek Manufacturing, Inc and then went across to the requirements in the right column of the table which call for “Super-low VOC coatings with equivalent reduction to an air pollution control system with 85.5% overall control.”

The company also has a facility wide VOC limit of 346 lbs/day.

As you continue to scroll down the list you will see companies that have installed zeolyte concentrators, thermal oxidizers and more. In each case you have the option to see more details about the abatement control requirements. Permit conditions for an abatement control device might also require a company to install Continuous Emission Monitors (CEMs) and maintain record keeping on a daily basis.

I haven’t taken the time to check the EPA BACT Clearinghouse, but I imagine that it might be somewhat similar.

If you use coatings that contain inorganic HAPs, such as chromates, you might also be required to measure and demonstrate a specified capture efficiency for your spray booth. Dry filter and water-wash spray booths will have different capture efficiency requirements.  

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