- Email: [email protected]
Labeling requirements and synthetic minor air permits
emmmyIoI#lN-TnmnulylsDmANwDDs We sty? having trouble getting accurate information off some of our MSDSs. Are you aware of any EPA o> state regulation that mandates what information the paint vendor must provide to the user? Does the MSDS have to state the laboratory test method used fir determining VOCs? How does the user know? Is them anything we can o?o to legally require our vendor to pr0vioT.e the inform&i& we require to calculate our emissions and other pertinent reporting information? In the South Coast Air Basin there are stringent regulations on what the paint vendor must report to the user. The summary in Table I is based on South Coast AQMD Rule 443, which very specifically addresses your frustrations. Vendors who sell their products in the South Coast Basin are required to provide the following data, either on a separate sheet, MSDS, and/or on the label. If you need additional information, such as percent weight solids, percent weight water, etc., you can request that your vendor complete the tables provided in the Appendix of EPA Document 450/384-019, “Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink and Other Coatings.” The most recent document that I have in my office is dated December 1984, and, therefore, information on HAPS is not listed. If the document has been updated, it probably requires that the vendor also provide information on HAP content. Unfortunately, I have searched the Internet, specifically the EPA website, for hours looking for an updated version but nothing has surfaced. The table asks for the following information: coating density; total volatiles (weight percent); water content (weight percent); water content (volume percent); organic volatiles (weight percent); nonvolatiles content (volume percent); VOC content expressed in lb/gal, less water; and lb/gal of solids. (Metric equivalents are also required.) For coatings that are thinned or mixed with another component prior to application, the document also requires the following information for the mixed coating, ready for application: coating density; total Ron Joseph is an independent coating consultant in San Jose, Calif. Email, [email protected]. April 2gO2
Table I. Rule 443.1 -Labellng solvents
of Materials Containing Organic
Applicablefor containerslarger than 1 quart. Not applicableto architecturalcoatings. Informationmust be providedeitheron data sheet shipped with containeror on label affixedto container. VOC informationin grams of VOC per liter of coating, less water, less exempt solvent. If materialis to be thinned, thinning instructionsmust be provided,together with resultingVOC content. For multicomponentcoatings (example: polyurethanes, epoxies) mixing and thinning instructionsmust be provided,together with resultingVOC content. For coatings with reactive diluents,the VOC content or portion that doea not react during curing process muat be provided. For solventsgreaterthan one gallon,a data sheet shipped with the containeror a label on the containermust provide max.VOC content,as well as vaporpressureat 20°C. volatiles (weight percent); water content (weight and volume percent); weighted average density’ of the dilution solvent (lb/gal); dilution solvent ratio; organic volatiles content (weight percent); nonvolatile content (volume percent); and VOC content expressed in lb/gal, less water; and lb/gal of solids. (Metric equivalents are also required.) In addition, the document requires the vendor to tell you whether the result was determined by testing per ASTM method or whether it was calculated from the formulation or other method. MCUlYATlOlYOTTnEuwm%w/wrrnbwv/v I have seen data sheets that give percentages as %wIw or %vlv. What does this mean? The expression %w/w means that the value is calculated as a weight percent. You might be curious as to why the percent has units? After all, when I was at school we were taught that percentages don’t have any units. To quell your curiosity, here is an example: Suppose we have a coating that has 3.5 lb of solvents/gal. The density of the solvent is 6.8 lb/gal and the density of the coating is 10 lb/gal. Clearly, the percent by weight is 3.5110 = 35% whv. How do we calculate the percent by volume? Since we know the density of the solvent we can calculate its volume as follows: Volume = Weight (lb)/Density (lb/gal) = 3.5 (lb)/6.8 (lb/gal) = 0.51 gal 89
..
Therefore, the percentage of solvent on a volume basis is 0.51 (galYl.0 (gal) = 51% v/v. WHATIS A SVNTNm MINOR PRRMm The company for which I work emits 27 tonlyr of a combination of HAPS, and we are subject to the Ship Building MXCT standard. As you are probably well aware, this requires lots of additional work in terms of monitoring, record keeping, using compliant coatings, spray guns, etc. Our local inspector told me that if I apply for a “synthetic minor” permit I can escape the MACT requirement. Is this true? Before I answer your question let me first point out that the threshold that triggers a MACT standard is 10 ton&r of a single Hazardous Air Pollutant (HAP), or 25 ton/year of a combination of HAPS. Solvents, such as MEK, MIBK, toluene, and xylene, are HAPS, whereas solvents, such as isopropyl alcohol, butyl acetate, and most of the other solvents that are used in your coatings, are VOCs but not HAPS. Secondly, you can trigger a MACT standard if your Potential to Emit G’TE) exceeds the limita given
above. The [email protected] PT’E-tid actual emissions is that when you calculate the former you need to assume that your equipment is emitting VO,Ca or HAPS at its maximum capacity, 24 hours per d& and 7 days per week, 52 weeks per year. Cl&rly; that is not realistic, and by far the majority of companies never come even close to emitting at the PTE level. There are some exceptions to the calculation of PTE, and the EPA allows you to make an argument for modifying the definition; however, the basic principle of the PTE still stands. In the following example I will demonstrate how even a small paint shop that works only two days per week can exceed the limit quite easily. Suppose the shop has three I-IVLP spray guns, each with a capacity to apply coating at 1 gal/hr, then the three guns have the potential to apply 3 gal&r X 24 hr/day X 7 daylwk X 52 wkiyear = 26,308 gal&r. That’s a lot of paint! If the coating contains solvents, such as MIBK, toluene and xylene, and has a HAP content of 2.6 lb/gal, the total PTE = 68,401 lb/yr/2,000 lb/ton = 34.2 ton&r.
COST EFFE’CTIVE MP&M WASTEWATER TkEATMENT USING PRECIPITATION AND CLARIFICATION
-.ProChemTech International, Inc. Sodium Hypophosphite, High Purity
Pure Tin, Tin-Lead, Tin-Copper
Inclinedplateclarificationis the most efficient, low cost, and troublefree process known for removalof many pollutantsfrom industrialwastewaters. We build the best, advanceddesign inclinedplate clarifiersin the world, which, when combined with appropriatePCT chemistry, can meet the proposed MP&M standards without any additional process steps. Smaller units available skidded and ready to operate. Full compliance warranty provided for systems. We can retrofit MP&M chemistry to your system. Phone 814-265-0959
FAX 814-265-1263
www.prochemtech.com 363 Ivyland Rd., Warminster, PA 1897~ Tel: (215)957-5880 Fax: (215)957-9111 E-mail: [email protected]
www. varsal. corn Circle 082 on reader card or go to www.thru.to/webconnect 84
Circle 059 on reader card or go to www.thm.to/webconnect Metal Finishing
Even though this seems ridiculous, the shop is subject to the relevant MACT standard. Now suppose that in real time the shop only uses a total of 4 gal/wk of paints for 50 weeks of the year, then its actual emissions of HAPs is 4 gal/wk X 50 wk/yr X 2.6 lb HAPS/gal = 520 lb HAPs/yr/2,000 lb/ton = 0.26 ton/yr. What a difference! EPA acknowledges the ludicrousness of such situations and allows the paint shop to apply for a “synthetic minor” permit. In this case the owner of the company would guarantee to his local state agency that his shop will never emit more than, say, 1 ton HAP&r, allowing for expansion of his business. He would also agree to accept federally enforceable permit conditions so that not only the state agency but also the EPA has the right to inspect his facility and issue violation notices. Having accepted these terms, the owner would walk away with a synthetic minor permit and never need to worry about the MACT standard. Now to the last part of the answer. In the case of the original question, the shop emits 27 ton&r of
HAP. These are real, actual emissions, not PTEs. Because it triggers the definition of “Major SQurce,” the shop is subject to the MACT standard, no matter what; however, if the company can find ways to reduce its HAP emissions below 25 ton&r it can apply for a synthetic minor permit. Suppose the shop supervisor manages to lower its actual emissions to 24.9 ton/yr, I doubt that any permit engineer will accept the new permit application, because it is more than likely that in any one year the limit will be “accidentally” exceeded. If the shop can m&e permanent process changes, such as improving transfer efficiency of paint application so that the maximum actual emissions can be reduced to 22 ton/year, the permit engineer might well issue the synthetic minor permit. This can be a win-win situation for the company. First, it escapes the MACT standard. Secondly, in taking the time to find ways to reduce its emissions, the company in all probability will also dramatically reduce its paint application costs. In this case pollullllF tion prevention (P2) would pay handsomely.
DISPOSABLLC, SLlhON DANGLER HLADS... *SAVE PLATING TIME *PROLONG CABLE LIFE AND IrPERFORM FOR PENNIES
Wateruseby6to10gdhsperminute Can@mbMEfbntby6to10gaibnsaminub 4ancentrstkwrof~ngsolutionsbchgd l l
~konpu~LIQ~YE.supoffbuHEuphrrdr,mdrupon
flames,or lmsafefuel
h84~W~wilhovtfW78OM!JDMokrA8Ufll~ffWllburrl LO@Mm CABLI LICE. Removing hsrdr betorethep&Mg
buimPhamoswt%Pfobng8the1Rbottho~~Awmibly. Il-8WE. Wd &M&a ham rhown Uut u&g our l
M&ingofchemicals
l
Exact Conthous
dlwonbk
hwd8 co& duetpennies PW bane/ hmd to UW.
CHANDB HEADS IN SECONDS Mixture
NEW DANGLERS LEAD THE WAY TO IMPORTANT PRODUCTION ECONOMY. U.S. Pat. #4,111,781
INC.
22 08kd8k ‘Dmgkm
Aw8nu8, J8ltlmt8n#
RI 02219
PbonuF8xt (401) 274-7742 are patented in the Unit@ States, Foreign Rights resem&.
Distributor Inquiries Invited Circle 032 on reader card or go to www.ti.~
Circle 024 on reader card or go to www.thru.tohuebconnect
Table I. Rule 443.1 -Labellng solvents
of Materials Containing Organic
Applicablefor containerslarger than 1 quart. Not applicableto architecturalcoatings. Informationmust be providedeitheron data sheet shipped with containeror on label affixedto container. VOC informationin grams of VOC per liter of coating, less water, less exempt solvent. If materialis to be thinned, thinning instructionsmust be provided,together with resultingVOC content. For multicomponentcoatings (example: polyurethanes, epoxies) mixing and thinning instructionsmust be provided,together with resultingVOC content. For coatings with reactive diluents,the VOC content or portion that doea not react during curing process muat be provided. For solventsgreaterthan one gallon,a data sheet shipped with the containeror a label on the containermust provide max.VOC content,as well as vaporpressureat 20°C. volatiles (weight percent); water content (weight and volume percent); weighted average density’ of the dilution solvent (lb/gal); dilution solvent ratio; organic volatiles content (weight percent); nonvolatile content (volume percent); and VOC content expressed in lb/gal, less water; and lb/gal of solids. (Metric equivalents are also required.) In addition, the document requires the vendor to tell you whether the result was determined by testing per ASTM method or whether it was calculated from the formulation or other method. MCUlYATlOlYOTTnEuwm%w/wrrnbwv/v I have seen data sheets that give percentages as %wIw or %vlv. What does this mean? The expression %w/w means that the value is calculated as a weight percent. You might be curious as to why the percent has units? After all, when I was at school we were taught that percentages don’t have any units. To quell your curiosity, here is an example: Suppose we have a coating that has 3.5 lb of solvents/gal. The density of the solvent is 6.8 lb/gal and the density of the coating is 10 lb/gal. Clearly, the percent by weight is 3.5110 = 35% whv. How do we calculate the percent by volume? Since we know the density of the solvent we can calculate its volume as follows: Volume = Weight (lb)/Density (lb/gal) = 3.5 (lb)/6.8 (lb/gal) = 0.51 gal 89
..
Therefore, the percentage of solvent on a volume basis is 0.51 (galYl.0 (gal) = 51% v/v. WHATIS A SVNTNm MINOR PRRMm The company for which I work emits 27 tonlyr of a combination of HAPS, and we are subject to the Ship Building MXCT standard. As you are probably well aware, this requires lots of additional work in terms of monitoring, record keeping, using compliant coatings, spray guns, etc. Our local inspector told me that if I apply for a “synthetic minor” permit I can escape the MACT requirement. Is this true? Before I answer your question let me first point out that the threshold that triggers a MACT standard is 10 ton&r of a single Hazardous Air Pollutant (HAP), or 25 ton/year of a combination of HAPS. Solvents, such as MEK, MIBK, toluene, and xylene, are HAPS, whereas solvents, such as isopropyl alcohol, butyl acetate, and most of the other solvents that are used in your coatings, are VOCs but not HAPS. Secondly, you can trigger a MACT standard if your Potential to Emit G’TE) exceeds the limita given
above. The [email protected] PT’E-tid actual emissions is that when you calculate the former you need to assume that your equipment is emitting VO,Ca or HAPS at its maximum capacity, 24 hours per d& and 7 days per week, 52 weeks per year. Cl&rly; that is not realistic, and by far the majority of companies never come even close to emitting at the PTE level. There are some exceptions to the calculation of PTE, and the EPA allows you to make an argument for modifying the definition; however, the basic principle of the PTE still stands. In the following example I will demonstrate how even a small paint shop that works only two days per week can exceed the limit quite easily. Suppose the shop has three I-IVLP spray guns, each with a capacity to apply coating at 1 gal/hr, then the three guns have the potential to apply 3 gal&r X 24 hr/day X 7 daylwk X 52 wkiyear = 26,308 gal&r. That’s a lot of paint! If the coating contains solvents, such as MIBK, toluene and xylene, and has a HAP content of 2.6 lb/gal, the total PTE = 68,401 lb/yr/2,000 lb/ton = 34.2 ton&r.
COST EFFE’CTIVE MP&M WASTEWATER TkEATMENT USING PRECIPITATION AND CLARIFICATION
-.ProChemTech International, Inc. Sodium Hypophosphite, High Purity
Pure Tin, Tin-Lead, Tin-Copper
Inclinedplateclarificationis the most efficient, low cost, and troublefree process known for removalof many pollutantsfrom industrialwastewaters. We build the best, advanceddesign inclinedplate clarifiersin the world, which, when combined with appropriatePCT chemistry, can meet the proposed MP&M standards without any additional process steps. Smaller units available skidded and ready to operate. Full compliance warranty provided for systems. We can retrofit MP&M chemistry to your system. Phone 814-265-0959
FAX 814-265-1263
www.prochemtech.com 363 Ivyland Rd., Warminster, PA 1897~ Tel: (215)957-5880 Fax: (215)957-9111 E-mail: [email protected]
www. varsal. corn Circle 082 on reader card or go to www.thru.to/webconnect 84
Circle 059 on reader card or go to www.thm.to/webconnect Metal Finishing
Even though this seems ridiculous, the shop is subject to the relevant MACT standard. Now suppose that in real time the shop only uses a total of 4 gal/wk of paints for 50 weeks of the year, then its actual emissions of HAPs is 4 gal/wk X 50 wk/yr X 2.6 lb HAPS/gal = 520 lb HAPs/yr/2,000 lb/ton = 0.26 ton/yr. What a difference! EPA acknowledges the ludicrousness of such situations and allows the paint shop to apply for a “synthetic minor” permit. In this case the owner of the company would guarantee to his local state agency that his shop will never emit more than, say, 1 ton HAP&r, allowing for expansion of his business. He would also agree to accept federally enforceable permit conditions so that not only the state agency but also the EPA has the right to inspect his facility and issue violation notices. Having accepted these terms, the owner would walk away with a synthetic minor permit and never need to worry about the MACT standard. Now to the last part of the answer. In the case of the original question, the shop emits 27 ton&r of
HAP. These are real, actual emissions, not PTEs. Because it triggers the definition of “Major SQurce,” the shop is subject to the MACT standard, no matter what; however, if the company can find ways to reduce its HAP emissions below 25 ton&r it can apply for a synthetic minor permit. Suppose the shop supervisor manages to lower its actual emissions to 24.9 ton/yr, I doubt that any permit engineer will accept the new permit application, because it is more than likely that in any one year the limit will be “accidentally” exceeded. If the shop can m&e permanent process changes, such as improving transfer efficiency of paint application so that the maximum actual emissions can be reduced to 22 ton/year, the permit engineer might well issue the synthetic minor permit. This can be a win-win situation for the company. First, it escapes the MACT standard. Secondly, in taking the time to find ways to reduce its emissions, the company in all probability will also dramatically reduce its paint application costs. In this case pollullllF tion prevention (P2) would pay handsomely.
DISPOSABLLC, SLlhON DANGLER HLADS... *SAVE PLATING TIME *PROLONG CABLE LIFE AND IrPERFORM FOR PENNIES
Wateruseby6to10gdhsperminute Can@mbMEfbntby6to10gaibnsaminub 4ancentrstkwrof~ngsolutionsbchgd l l
~konpu~LIQ~YE.supoffbuHEuphrrdr,mdrupon
flames,or lmsafefuel
h84~W~wilhovtfW78OM!JDMokrA8Ufll~ffWllburrl LO@Mm CABLI LICE. Removing hsrdr betorethep&Mg
buimPhamoswt%Pfobng8the1Rbottho~~Awmibly. Il-8WE. Wd &M&a ham rhown Uut u&g our l
M&ingofchemicals
l
Exact Conthous
dlwonbk
hwd8 co& duetpennies PW bane/ hmd to UW.
CHANDB HEADS IN SECONDS Mixture
NEW DANGLERS LEAD THE WAY TO IMPORTANT PRODUCTION ECONOMY. U.S. Pat. #4,111,781
INC.
22 08kd8k ‘Dmgkm
Aw8nu8, J8ltlmt8n#
RI 02219
PbonuF8xt (401) 274-7742 are patented in the Unit@ States, Foreign Rights resem&.
Distributor Inquiries Invited Circle 032 on reader card or go to www.ti.~
Circle 024 on reader card or go to www.thru.tohuebconnect