Regulations, Violations, Permits, VOC, HAP and Such

LIMITING SPRAY BOOTH PERMITS TO GALS/DAY

Q:  Should permit writers limit paint usage in gal/day or lbs VOC/day?  Many regulations indicate a gal/day or gal/year limit.

A:  In my opinion, permits should not limit the number of gallons of paint to be used, but rather limit the total emissions (lbs) of VOC from painting operations.  This includes coatings, thinners, clean up solvents, etc.

By limiting the number of gallons of paint, the permit would not take into consideration that water-borne paints tend to have lower solids contents that their solvent-based counterparts.  MORE water-borne paint (gallons) is required to coat the same number of parts at the same coating film thickness.  Yet, most water-borne coatings have very low VOC contents, and even though more gallons might be used, the VOC emissions may well be less.

Since the goal of our regulations is to cut air pollution, VOC emissions should be limited rather than the number cans of coating that are used.

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