Industrial painting in Texas requires the evaluation of numerous air regulations before a comprehensive compliance assessment can be completed. Listed below is an brief outline and the various regulatory links that are needed to be evaluated. This is not an exhaustive list. Contact Mounce & Associates for a complete evaluation. The evaluation includes:
- Base material being coated (metal, wood, plastic, etc.)
- Surface preparation (Sandblasting, phosphating, wipe cleaning, chemical maskant, etc.)
- Material Handling (container management)
- Coating type and associated solvents (Speciation of coatings and solvents)
- Environmental controls (ventilation, particulate filtration, stack height, thermal oxidation)
- Application (spray, roll, dip, etc.
- Cleanup (Gun and line flush)
- Waste disposal (Non-hazardous, Hazardous, Universal)
TAC 115 Control of Volatile Organic Compounds
If your facility is located in one of the VOC non-attainment areas in Texas, you must meet the TAC 115 requirements. Specifically, you must spray a VOC compliant coating. The VOC limit is dependent upon the type of process and products being coated AND the county you are located in.
NESHAP Programs (National Emission Standards for Hazardous Air Pollutants)
It is very important that a NESHAP applicability evaluation be performed BEFORE beginning operationss. For example, NESHAP WWWWWW! (40 CFR 63)
PNSS Programs (STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES)
It is very important that a PNSS applicability evaluation be performed. (40 CFR 60)
Texas Regulations
TITLE 30 ENVIRONMENTAL QUALITY
CHAPTER 115 – CONTROL OF AIR POLLUTION FROM VOLATILE ORGANIC COMPOUNDS
TAC 106 Permit by Rule
Subchapter S – Surface Coating 106-431 – 106-436
If you can’t meet the requirements for the Permit by Rule, you are probably required to obtain a New Source Review Permit (TAC 116).
TAC 116 – CONTROL OF AIR POLLUTION BY PERMITS FOR NEW CONSTRUCTION
If your annual emissions for Hazard Air Pollutants (HAP) or VOC exceeds the major source limits, then you are required to obtain a Federal Operating Permits.
CHAPTER 122 – FEDERAL OPERATING PERMITS PROGRAM
Additional Information
TCEQ Small Business Assistance – Surface Coating page
Labsafety.com – Isocyanates in the workplace
House of Kolor (Automotive & Motorcycle paints)
OR MODIFICATION