- Email: [email protected]
Daily record keeping and complex VOC compliance calculations
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Daily Record Keeping and Complex VOC Compliance Calculations
DAILY RECORD KEEPING
In a training program that you gave to our painters and environmental supervisors recently, you told them that they should keep records ‘every” day, even on those days that no painting operations are being performed. We discussed this among our staff and found that the requirement can be quite time consuming and can add to our already burdened responsibilities. Can you please explain why you made this comment? First, this requirement only applies if your regulations or permits call for daily record keeping. If you are not subject to a regulation, or you are only required to keep monthly or annual records, the issue of “daily” records is moot. What does “daily” mean? If you work in a painting operation that applies paints and solvents every day of the week, then the word “daily” is clear. If your facility is like a job shop and applies coatings on some days, but not others, then you would assume that “daily” applies only to those days on which you paint. Put yourself into the position of an EPA or state inspector who visits your facility and sees that there are records for some days, but not others. You are told that the facility doesn’t paint every day, and that the days for which records are not available represent the days on which no painting was carried out. As an inspector you know that not all facilities are perfect in their recordkeeping rigor. So how do you know if the company representative is telling the truth? How do you know if there were days on which painting was conducted, but the painters forgot to complete the records? You don’t! Hence, you issue a Notice of Violation (NOW on grounds that the company did not comply with the “Daily” recordkeeping provision of the regulation or permit. For your information, I have given this training to many classes, including ones at which the EPA and state agencies were present. No one has ever argued about the interpretation of “daily.” Several years ago an inspector issued 17 NOVs to one of my clients
Ron Joseph is an independent Calif. E-mail, [email protected].
78
coating
consultant
in San Jose.
because there were 17 days for which no records had been completed. The company’s CEO, furious and ready to tear his hair out, called his lawyer and asked him to negotiate with the state to have the NOVs rescinded, because, the CEO argued, that on those specific days no painting was being conducted. The company’s lawyer said that there was nothing to dispute as the word “daily” means “every day.” Miffed at the response from his own well-paid lawyer the CEO relented and sent out a memo instructing all painters to keep records daily, regardless of whether any paints or solvents were used during the day. What about weekends and public holidays? It is my personal opinion that if your company is closed on weekends and holidays, no record keeping is required, because there is nobody in the shop who can be painting. If workers normally punch time cards when they show up for work but there are days on which no time cards are punched, then you can convincingly argue that records are not required on those days. What if all the painters show up for work, but the production line is shut down for annual maintenance? If you can easily prove to an inspector that there was no production from one date to another, then it can be assumed that no painting was carried out during that period. Make sure, however, that you can prove to the inspector that a shutdown had occurred during this period. CALCULATING
VOC (LB/GAL,
LESS WATER AND
EXEMPT SOLVENT FOR A MIKTURE)
Here is an advanced VOC problem that was sent to me recently. If you are responsible for performing VOC calculations in your facility, I urge you to try your hand at this one. Could you please help me calculate the VOC (lb lgal, less water and exempt solvents) for a topcoat that is comprised of three components: Component A: 60% nonexempt VOCS, 5%’ acetone, WPG 10.2 lb/gal Component B: 50% nonexempt VOCS, WPG 9.0 lb I gal Component
C: 0% nonexempt
VOCS,
90%) acetone, Metal Finishing
WPG 12.4 lblgal (See comment below) Mix ratio (by vol): 2:1:0.5 According to the MSDS for each component, the VOC (lb/gal, less water and exempt solvents) are: Component A: 6.2 lb lgal less exempt solvent and less water Component B: 4.3 lb/gal less, less exempt solvent and less water Component C: 0 lb lgal less exempt solvent and less water Before starting the calculation, notice that the weight per gallon (WPG) of Component C has been given as 12.4 lb/gal. Since 90% of the coating is acetone, the remaining 10% must either be water or solids. The MSDS rarely tells us if there is water in a coating because it is not a hazardous ingredient, but if Component C does contain water, its density is 8.33 lb/gal. The density of acetone is 6.61 lb/gal; therefore, the combination of water and acetone cannot possibly give us a WPG for Component C of 12.4 lb/gal. Similarly, if 10% of the component are solids, it would need to be far heavier than lead to give us a WPG of 12.4 lb/gal. The MSDS from which the reader copied the data is either grossly incorrect, or the reader inadvertently made an error when transposing the data. For purposes of this demonstration we’ll arbitrarily change the WPG to a more realistic value of 9.5 lb/gal. If nothing else, you’ll see how the calculations are performed. Some of you might be frustrated by the many steps I go through to solve the problem, and you will be able to do the same trick with fewer manipulations; however, I know that many of our readers are not math savvy and prefer to go slowly and methodically. The mixing ratio is given as 2:1:0.5 and for purposes of this calculation we will mix 2 gallons of (A) with 1 gallon of(B) with 2 gallon of (Cl. Although the question asks for the VOC (lb/gal, less water and exempt solvent), don’t be mislead by the reference to water. In our example there is no water in the mixture, so our goal is to calculate the VOC (lb/gal, less exempt solvents). The equation we will try to solve is: VOC (lb VOUgal, less exempt solvent) = Weight of VOC (1bMVolume (VOC + Solid) (gals)] Step #l-Weight of VOC in Each Component We can use Table I to calculate the weight of VOC in each of the three components. Armed with this information we can now proceed to Step #2 to calculate the weight of VOC (lb) in the mixture. (See Table II.)
Table I. Determining
Weight
WPG of Component (lb/gal) 10.0 9.0 9.5
% wt. voc 60.0 50.0 0.00
Component A B C Table II. Weight
of Components
E (lb of VOC) = = =
6.0 4.5 0.0
of VOC in Each Component
Component
Gal
A B C Total
2.0 1.0 0.5 3.5
Table Ill. Weiaht
wt. of VOC (lb) 6.0 4.5 0.0
E (lb of VOC) = = =
12.0 4.5 0.0 16.5 lb
of Acetone
Component
Gal
% wt. Acetone
WPG of Component
A B C Total
2.0 1.0 0.5
5.0 0.0 90.0
10.0 9.0 9.5
Wt. (lb of Acetone) = = =
1.0 0.0 4.3
5.3
Step #2-Weight of VOC in the Mixture In this mixture of 3.5 gal we have 16.5 lb of VOC, but we need to know the volume of only the (VOC + Solid), and not include the volume of acetone. To calculate the volume of acetone we need to know the weight and density of acetone in the mixture. Using a table similar to Table I, we calculate the weight of acetone. (See Table III.) Step #3-Calculate Mixture
the Weight ofAcetone
in the
Step #4-Calculate the Volume of Acetone in the Mixture To calculate the volume of acetone we need to know its density (lb/gal), and for this we can refer to an MSDS or chemical handbook. General sources give the density of acetone as 6.61 lb/gal. Volume acetone (gal) = Wt. (lb)/Density (lb/gal) II 5.3 (lbY6.61 (lb/gal) = 0.80 gal Since the total mixture of the coating is 3.5 gal, the volume less acetone is (3.5 - 0.80) = 2.7 gal. Step #5-Calculate the VOC (lb/gal, less exempt solvents): We are now ready to calculate the VOC of the mixture, less exempt solvents: VOC (lb/gal, less exempt solvents) = 16.5 lb/2.70 gal = 6.1 lb/gal, less exempt solvent MF
.. *, .
Daily Record Keeping and Complex VOC Compliance Calculations
DAILY RECORD KEEPING
In a training program that you gave to our painters and environmental supervisors recently, you told them that they should keep records ‘every” day, even on those days that no painting operations are being performed. We discussed this among our staff and found that the requirement can be quite time consuming and can add to our already burdened responsibilities. Can you please explain why you made this comment? First, this requirement only applies if your regulations or permits call for daily record keeping. If you are not subject to a regulation, or you are only required to keep monthly or annual records, the issue of “daily” records is moot. What does “daily” mean? If you work in a painting operation that applies paints and solvents every day of the week, then the word “daily” is clear. If your facility is like a job shop and applies coatings on some days, but not others, then you would assume that “daily” applies only to those days on which you paint. Put yourself into the position of an EPA or state inspector who visits your facility and sees that there are records for some days, but not others. You are told that the facility doesn’t paint every day, and that the days for which records are not available represent the days on which no painting was carried out. As an inspector you know that not all facilities are perfect in their recordkeeping rigor. So how do you know if the company representative is telling the truth? How do you know if there were days on which painting was conducted, but the painters forgot to complete the records? You don’t! Hence, you issue a Notice of Violation (NOW on grounds that the company did not comply with the “Daily” recordkeeping provision of the regulation or permit. For your information, I have given this training to many classes, including ones at which the EPA and state agencies were present. No one has ever argued about the interpretation of “daily.” Several years ago an inspector issued 17 NOVs to one of my clients
Ron Joseph is an independent Calif. E-mail, [email protected].
78
coating
consultant
in San Jose.
because there were 17 days for which no records had been completed. The company’s CEO, furious and ready to tear his hair out, called his lawyer and asked him to negotiate with the state to have the NOVs rescinded, because, the CEO argued, that on those specific days no painting was being conducted. The company’s lawyer said that there was nothing to dispute as the word “daily” means “every day.” Miffed at the response from his own well-paid lawyer the CEO relented and sent out a memo instructing all painters to keep records daily, regardless of whether any paints or solvents were used during the day. What about weekends and public holidays? It is my personal opinion that if your company is closed on weekends and holidays, no record keeping is required, because there is nobody in the shop who can be painting. If workers normally punch time cards when they show up for work but there are days on which no time cards are punched, then you can convincingly argue that records are not required on those days. What if all the painters show up for work, but the production line is shut down for annual maintenance? If you can easily prove to an inspector that there was no production from one date to another, then it can be assumed that no painting was carried out during that period. Make sure, however, that you can prove to the inspector that a shutdown had occurred during this period. CALCULATING
VOC (LB/GAL,
LESS WATER AND
EXEMPT SOLVENT FOR A MIKTURE)
Here is an advanced VOC problem that was sent to me recently. If you are responsible for performing VOC calculations in your facility, I urge you to try your hand at this one. Could you please help me calculate the VOC (lb lgal, less water and exempt solvents) for a topcoat that is comprised of three components: Component A: 60% nonexempt VOCS, 5%’ acetone, WPG 10.2 lb/gal Component B: 50% nonexempt VOCS, WPG 9.0 lb I gal Component
C: 0% nonexempt
VOCS,
90%) acetone, Metal Finishing
WPG 12.4 lblgal (See comment below) Mix ratio (by vol): 2:1:0.5 According to the MSDS for each component, the VOC (lb/gal, less water and exempt solvents) are: Component A: 6.2 lb lgal less exempt solvent and less water Component B: 4.3 lb/gal less, less exempt solvent and less water Component C: 0 lb lgal less exempt solvent and less water Before starting the calculation, notice that the weight per gallon (WPG) of Component C has been given as 12.4 lb/gal. Since 90% of the coating is acetone, the remaining 10% must either be water or solids. The MSDS rarely tells us if there is water in a coating because it is not a hazardous ingredient, but if Component C does contain water, its density is 8.33 lb/gal. The density of acetone is 6.61 lb/gal; therefore, the combination of water and acetone cannot possibly give us a WPG for Component C of 12.4 lb/gal. Similarly, if 10% of the component are solids, it would need to be far heavier than lead to give us a WPG of 12.4 lb/gal. The MSDS from which the reader copied the data is either grossly incorrect, or the reader inadvertently made an error when transposing the data. For purposes of this demonstration we’ll arbitrarily change the WPG to a more realistic value of 9.5 lb/gal. If nothing else, you’ll see how the calculations are performed. Some of you might be frustrated by the many steps I go through to solve the problem, and you will be able to do the same trick with fewer manipulations; however, I know that many of our readers are not math savvy and prefer to go slowly and methodically. The mixing ratio is given as 2:1:0.5 and for purposes of this calculation we will mix 2 gallons of (A) with 1 gallon of(B) with 2 gallon of (Cl. Although the question asks for the VOC (lb/gal, less water and exempt solvent), don’t be mislead by the reference to water. In our example there is no water in the mixture, so our goal is to calculate the VOC (lb/gal, less exempt solvents). The equation we will try to solve is: VOC (lb VOUgal, less exempt solvent) = Weight of VOC (1bMVolume (VOC + Solid) (gals)] Step #l-Weight of VOC in Each Component We can use Table I to calculate the weight of VOC in each of the three components. Armed with this information we can now proceed to Step #2 to calculate the weight of VOC (lb) in the mixture. (See Table II.)
Table I. Determining
Weight
WPG of Component (lb/gal) 10.0 9.0 9.5
% wt. voc 60.0 50.0 0.00
Component A B C Table II. Weight
of Components
E (lb of VOC) = = =
6.0 4.5 0.0
of VOC in Each Component
Component
Gal
A B C Total
2.0 1.0 0.5 3.5
Table Ill. Weiaht
wt. of VOC (lb) 6.0 4.5 0.0
E (lb of VOC) = = =
12.0 4.5 0.0 16.5 lb
of Acetone
Component
Gal
% wt. Acetone
WPG of Component
A B C Total
2.0 1.0 0.5
5.0 0.0 90.0
10.0 9.0 9.5
Wt. (lb of Acetone) = = =
1.0 0.0 4.3
5.3
Step #2-Weight of VOC in the Mixture In this mixture of 3.5 gal we have 16.5 lb of VOC, but we need to know the volume of only the (VOC + Solid), and not include the volume of acetone. To calculate the volume of acetone we need to know the weight and density of acetone in the mixture. Using a table similar to Table I, we calculate the weight of acetone. (See Table III.) Step #3-Calculate Mixture
the Weight ofAcetone
in the
Step #4-Calculate the Volume of Acetone in the Mixture To calculate the volume of acetone we need to know its density (lb/gal), and for this we can refer to an MSDS or chemical handbook. General sources give the density of acetone as 6.61 lb/gal. Volume acetone (gal) = Wt. (lb)/Density (lb/gal) II 5.3 (lbY6.61 (lb/gal) = 0.80 gal Since the total mixture of the coating is 3.5 gal, the volume less acetone is (3.5 - 0.80) = 2.7 gal. Step #5-Calculate the VOC (lb/gal, less exempt solvents): We are now ready to calculate the VOC of the mixture, less exempt solvents: VOC (lb/gal, less exempt solvents) = 16.5 lb/2.70 gal = 6.1 lb/gal, less exempt solvent MF