Monitor My Small Shop?
Do I Need a Permit?
Estimating VOC Emissions
Why Monitor My Small Shop?
Most of Connecticut has been designated a "serious" non-attainment area for ozone. Greater Fairfield County has been designated a "severe" non-attainment area for ozone. This area excludes Shelton, but includes New Milford and Bridgewater. Ground level ozone, along with other airborne irritants is commonly called smog. Smog contributes to the haze we see over cities on hot summer days. Smog stings our eyes and aggravates existing health problems, such as asthma, especially in young children and the elderly. Smog is created when Volatile Organic Compounds (VOCs) combine with oxides of nitrogen (NOx) in the presence of sunlight. VOCs may be found in prep products, paints and other products containing solvents. The oxides of nitrogen (NOx) are emitted from fossil fuel burning sources such as motor vehicles, power plants and boilers.
Over the past twenty years we have made progress in reducing smog by concentrating pollution control and prevention efforts on larger businesses and utilities. More reductions must be made for Connecticut to meet the federal government's deadline for attaining "healthy" air quality levels.
Do I Need A Permit?
Air regulations are quite complex. To simplify the permitting process, the Air Management Bureau developed a General Permit for Automotive Refinishing Operations. This general permit applies to any facility with spraying or coating operations. Facility owners/operators need to inventory all VOC containing materials such as degreasers, prep solvents, primers and coatings. Purchase records provide a shorcut to estimating emissions from a facility. If spray booths/spray areas were constructed prior to December 27, 1988 and the total annual usage of VOC containing material is less than 2,000 gallons, the facility can register under the general permit. If the spray booths/spray areas were constructed after December 27, 1988 the threshold for total annual usage of VOC containing material must be less than 1,000 gallons. There are specific conditions of the general permit a facility owner/operator must comply with which include:
Actual emissions of VOC < 5 or 10 tons per year from the entire facility (depending on construction date).
Chromate emissions must comply with Maximum Allowable Stack Concentration.
Must use a particular control with a minimum of 80% removal efficiency (dry filter).
Any applicator used must have a transfer efficiency guaranteed by the manufacturer of at latest 65% (HVLP or better).
Must use some form of gun cleaning system.
Must comply with odor and noise regulations.
Permit does not
contain wax or grease remover limitation.
Estimating VOC Emissions
The first step is to gather the information needed to determine what your facility's potential emissions are. This can be found in inventory and purchasing records, Material Safety Data Sheets (MSDS) and equipment specifications.
From the MSDS determine the "worst" product used in terms of its VOC or HAP content for each piece of air pollutant producing equipment.
Determine the hourly application ratings for all spraying equipment. Facilities that heat with fossil fuels will also need to determine the ratings for all fossil fuel burning equipment.
Determine the quantity of pollutants that could be emitted from these units if they ran 8760 hours (24 hours/day, all year) without any emissions controls. Use the worst case product from step 1.
If the result of your emissions inventory for any HAP is over 10 tpy, or any combination of HAP is over 25 tpy, or any VOC is over 25 or 50 tpy, depending on your location, you must contact the DEP and apply for a permit.
But we never run 24 hours a day, 365 days per year! This potential emissions inventory provides a standard for measuring improvement from the worst possible pollution situation.
The next step is to determine how much your facility actually emitted over the previous twelve month period. For each product use the following calculation:
(Quantity of product used) x [(% VOC) - (% captured or destroyed) - ( % retained in substrate)] = Actual Emissions
Estimate how much of each product actually used:
(Inventory at beginning of 12 month period)
+ (Amount purchased during 12 month period)
- (Inventory at end of 12 month period)
= Quantity of product used
Determine the VOC and HAP content from the MSDS for each product.
Determine what percentage of each VOC and each HAP was destroyed or captured by control equipment. The equipment vendor should have supplied this information to you.
Your supplier(s) may be able to provide methods and systems to help you track material usage, including VOCs and HAPs content. This type of procedure is being instituted nationwide in many industries to help better manage inventory and ease the burden of emissions tracking.
For Further Information From the DEP
The Bureau of Air Management has a set of worksheets available to help you through this process. For a copy of these, or further information on air permitting requirements, call (860) 424-3028.
The Small Business and Compliance Assistance Program has trained help available by calling (860) 424-3382.
This fact sheet is provided solely as a preliminary source of information on pollution prevention and environmental regulations. It does not constitute legal advice, and should not substitute for review of the actual regulations. These regulations may be found in the "Regulations of Connecticut State Agencies" (RCSA) title 22a section 174, and the Code of Federal Regulations (CFR) title 40, sections 60, 61 and 63. There are specific requirements that could affect your shop's emissions of HAPs covered in RCSA 22a-174-29.
For more information, call the Office of Pollution Prevention at (860) 424-3297, e-mail Pollution Prevention Coordinator or write to:
Department of Environmental Protection
Bureau of Waste Management
Office of Pollution Prevention
79 Elm Street
Hartford, CT 06106-5127
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Last Updated: August 1999