Regulations, Violations, Permits, VOC, HAP and Such

POTENTIAL TO EMIT

Q:  How can a company ensure/verify that they are meeting a permit condition that calls for a specified minimum transfer efficiency (TE)?

A:  This is a very difficult, if not an impossible task to perform with any degree of reliability or repeatability.  It is possible to perform TE tests on a production line, but the test protocol must be carefully spelled out.  Even after following the protocol, day-to-day variations will occur and the TE value will change, because there are too many variables that need to be controlled.

Perhaps and easier method that will achieve the same goal, namely to verify the efficiency of an operation, is to determine the monthly or annual “coating rate”.  In essence, the company would keep records of the number of parts it paints over a period of weeks or months, and also keeps records of the amount of paint and solvent used to coat those parts. The “coating rate” can be based on the amount of paint and solvent used to coat say 100 or 1,000 parts.  Better still, you could express this as lbs of VOC used for 100 or 1,000 parts.

When issuing a permit you would first make an initial determination and then compare the results after several weeks or months.

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