A Permit By Rule

Unit II

General Consideration for Operations

Quienna Jackson

MEE 6501

April 1, 2016

Abstract

The paper outlines the surface coating requirements that must be met to receive a permit from Texas Commission on Environmental Quality. It outlines the general consideration that must be reviewed to meet the requirements. The maintenance of safety data sheets and the assigned coating and solvent coatings per week are necessary.

Keywords: permit by rule, safety, solvent, coating

General Considers for Operations

Texas Car Body Repairs is constructing a facility with an interior lining that has been carefully designed. The Texas laws and EPA regulations require the facility to have an air permit before any construction starts. The written Air permit must align the interior surface coating of the facility with the federal laws on air quality. The information presented in the table is crucial in determining the requirements that must be met in the written air application permit.

Interior Liner Coating Material	10 gallons coating/vehicle	2 gallons of solvent/vehicle
Vehicle Lining Application	Apply interior liners to two (2) vehicles/day	Work five (5) hours/day and four (4) days/week Vehicle Lining Curing
Vehicle Lining Curing	Cure interior liners of two (2) vehicles/day	Work five (5) hours/day and four (4) days/week
Interior Liner Cure	Heater fuel source is natural gas-fired drying oven	Heater generates 2.1 million (MM) Btu/hr at maximum 2,500 hrs/year
Vehicle Lining Design	Cross-draft air plenum	Vehicle interior is the spray area
Exhaust Fan	10,000 ft3/min (CFM)	1 exhaust fan
Air Makeup Unit	5760 ft3/min (CFM)	1 air makeup
Filter Openings	20.0 ft2 each	Two (2) filter openings
Coating WV	VOC content	2.8 lb/gal coating Coating VM
Water Content	Per gal/coating	1.0 lb/gal
Water Density	Per gal/water	8.34 lb/gal
Coating VW	Water volume	Calculation
Exempt-solvent Content	Per gal/coating	0.5 lb/gal
Exempt-solvent Density	Per gal/exempt solvent	6.64 lb/gal
Coating Ves	Exempt solvent volume	Calculation

The facility must meet the requirements outlined in the surface coating PBR as explained in 30 TAC 106.433. Based on the spray that the company intends to use it is necessary to maintain impeccable housekeeping practices to keep the facility safe. The immediate cleaning of all spills is mandatory. The company has a 10,000 ft3/min exhaust fan that will always run when spray equipment is being cleaned. The interior liner cure uses a heater powered by natural gas. The heater does not exceed the limit 40 million British thermal units per hour as stipulated in the law. The facility heater emits a heat of 2.1 Btr/hr.

The components of the Material Safety Data Sheet can help in checking if the company meets the limits specified for volatile uncontrolled organic compounds (Godish, Davis & Fu, 2015). The company uses 1,040 gallons (per because it utilizes 10 gallons of coating per vehicle and works on two cars per day. The facility is expected to consume a total of 832 gallons of solvent per year. The VOC content in each gallon of the coating is 2.8 pounds, which translates to 56 pounds of VOC contents per day. The VOC content is below the 500-pound threshold identified in the law (Texas Commission on Environmental Quality, 2011). The exempt solvent content in each gallon of the coating is 0.5 pounds. The total exempt solvent content per day is 10 pounds.

The facility meets the requirements of the minimum face velocity requirements in the law. The facility has two 20ft2 openings in each work area. It ensures that the flow of air is maintained all the time. Information about the daily usage of coatings and solvents can be found in the table provided for the facility. The other requirements are the development of a written site approval and the registration with the Commission.

References

Godish, T., Davis, W. T., & Fu, J. S. (2015). Air quality (5th ed.). Boca Raton, FL: CRC Press.

Texas Commission on Environmental Quality. (2011). TCEQ Regulatory Guidance. Austin: Small Business and Environmental Assitance Division.