TCEQ REGULATORY GUIDANCE Small Business and Environmental Assistance Division RG-404 February 2011 Surface Coating Facilities A Guide for Obtaining
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Hello Kinini, this is the last section of my paper which covers two

headings. Please read the instructions carefully as follows: Read the Unit VIII Study Guide (see attached), then consider the control technology options available for our scenario. Make your first Unit VIII section level 1 heading titled “Pollution Control Technologies.” Select appropriate control technologies to be used in the final exhaust air from the spray booth for the following pollutants: (a) gases and vapors, (b) aerosol particles, and (c) noise levels of 90 dBA at 1,000 Hz. Be sure to defend your suggested engineering controls with literature. Next, make your second Unit VIII section level 1 heading titled “Process Flow Diagram.” Map out the entire process by developing a drawing of the process. You might consider reviewing the drawings located within Appendix G and Appendix J in the TCEQ (2011) document and Figure 10.12 on page 381 of your textbook as good examples of clear and understandable process drawings to help you construct your own Process Flow Diagram.
Note: Since this section has two headings and a process flow diagram, I am adjusting the rate to $30, and will provide an additional $30 tip for good original work. I will definitely work with you on future classes. Thanks (As always please cite and reference as required using APA formatting).

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TCEQ REGULATORY GUIDANCE Small Business and Environmental Assistance Division RG-404 ● February 2011 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY PO BOX 13087 AUSTIN, TX 78711-3087 The TCEQ is an equal opportunity employer. The agency does not allow discrimination on the basis of race, color, religion, national origin, sex, disability, age, sexual orientation, or veteran status. In compliance with the Americans with Disabilities Act, this document may be requested in alternate formats by contacting the TCEQ at 512-239-0028, fax 512-239-4488, or 1-800-RELAY-TX (TDD), or by writing PO Box 13087, Austin TX 78711-3087. We authorize you to use or reproduce any original material contained in this publication — that is, any material we did not obtain from other sources. Please acknowledge the TCEQ as your source. Printed on recycled paper. Surface Coating Facilities A Guide for Obtaining Air Authorization in Texas Contents Introduction . ..................................................................................................................................................... 2 Which Air Authorization Applies to You? . .............................................................................................. 2 De Minimis . ........................................................................................................................................................ 2 Permit by Rule . ................................................................................................................................................... 3 New Source Review Permit. ................................................................................................................................ 7 Title V Federal Operating Permit. ...................................................................................................................... 7 Other Requirements . ...................................................................................................................................... 8 General Air Quality Rules (30 TAC 101) . .......................................................................................................... 8 Nonattainment and Near-Nonattainment Areas (30 TAC 115) . ......................................................................... 9 New Source Performance Standards (40 CFR, Part 60) . ................................................................................. 10 National Emission Standards for Hazardous Air Pollutants (40 CFR, Part 63) . ............................................. 10 Common Air Violations for Surface Coaters . ....................................................................................... 11 For More Information . ................................................................................................................................. 11 Appendix A: Common Permits by Rule for Surface Coating Facilities . ....................................... 12 Appendix B: Surface Coating Permit by Rule (30 TAC 106.433) .................................................. 13 Appendix C: Volatile Organic Compound (VOC) and Exempt Solvent Content per Gallon of Coating . ............................................................................................................................................................. 1 6 Appendix D: Calculating Maximum Hourly and Annual Emission Rates . .................................. 20 Appendix E: Emission Rate Averaged Over a Five-Hour Period . .................................................. 24 Appendix F: Potential to Emit . .................................................................................................................. 25 Appendix G: Calculation of Booth or Work-Area and Filter and Face Velocities . ................... 26 Appendix H: VOC Content Minus Water and Exempt Solvents . .................................................... 30 Appendix I: Calculations for Emissions of Products of Combustion from Heaters and Ovens .............................................................................................................................................................................. 33 Appendix J: Examples of Acceptable Stack Designs . ......................................................................... 35 Appendix K: Compliance Worksheet . ..................................................................................................... 36
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TCEQ publication RG-404 Surface Coating Facilities: A Guide for Obtaining Air Authorization in Texas 2 Revised March 2011 Introduction This document is tailored to the surface coating industry, excluding auto body shops, and contains general information about air regulations. Surface coaters prepare and coat (paint) items that may be made out of metal, wood, plastic, porcelain, or any of several other materials. Processes associated with cleaning and coating emit air contaminants. As part of its role in protecting public health and the environment, the Texas Commission on Environmental Quality (TCEQ) requires you to get proper air authorization for these emissions. Under the law, you are required to obtain authorization before you build, modify, or begin operations at your facility. Even if your site is already in operation, you still need an air authorization. You should begin steps to obtain authorization as soon as you become aware that this regulation applies to you. For more information on how to proceed if you find yourself in this situation, call the Small Business and Local Government Assistance (SBLGA) program at 800-447-2827 for confidential assistance. You can also contact the Air Permits Division at 512-239-1250 for technical assistance. Which Air Authorization Applies to You? The type of authorization you qualify for will depend on the materials and chemicals you use, the processes that you conduct, and the amount of air contaminants your facility creates. In Texas, you have three options for obtaining authorization to emit air contaminants from your surface coating facility. You must either qualify for de minimis status, or obtain authorization through a permit by rule (PBR), or New Source Review (NSR) permit. In addition, you may be required to obtain coverage under a Title V Federal Operating Permit if your emissions exceed certain levels. Ultimately, you must decide which type of authorization applies to your business and if it needs to meet any other requirements to comply with state and federal laws. De Minimis De minimis sites emit very small amounts of air contaminants. If your site qualifies as de minimis , you do not need to register with the TCEQ. However, you do need to keep records to prove that you meet the de minimis requirements. Even if your site is de minimis , you may have to comply with other state and federal regulations—see “Other Requirements,” on page 8. The rules that explain the de minimis criteria appear at 30 Texas Administrative Code (TAC) Chapter 116, Subchapter B, Division 1, Section 116.119. There are several ways that you can meet the de minimis criteria. To find out whether you can claim de minimis status: Check the De Minimis Facilities or Sources List [30 TAC 116.119(a)(1)].
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MEE 6501, Advanced Air Quality Control 1 Course Learning Outcomes for Unit VIII Upon completion of this unit, students should be able to: 6. Estimate the impact of air pollution on the environment. 7. Evaluate air pollution control technologies. 7.1 Describe air pollution control technologies for particulate-phase pollutants. 7.2 Explain air pollution control technologies for gas-phase pollutants. Reading Assignment Chapter 9: Control of Motor Vehicle Emissions Chapter 10: Control of Emissions from Stationary Sources The Guide for Obtaining Air Authorization in Texas is used with the permission of the Texas Commission on Environmental Quality. You can access the document from their website, or you can click on the link in the Unit II Mini Project in the syllabus. Texas Commission on Environmental Quality. (2011). Surface coating facilities: A guide for obtaining air authorization in Texas. Retrieved from https://www.tceq.texas.gov/searchpage?cx=004888944831051571741%3Auk- 3yh4pey8&cof=FORID%3A11&q=Surface+Coating+Facilities%3A+A+Guide+for+Obtaining+Air+Auth orization+in+Texas Unit Lesson To date, we have discussed a tremendous amount of chemistry, particle science, atmospheric science, and statistical analysis. We have worked within these different disciplines using mathematics as the common language in order to effectively approach air quality from a systems engineering perspective. We can agree that engineering air quality has been demonstrated to be an interdisciplinary science of its own! In Unit VIII, we want to comprehensively consider all of the work that we have done to understand the independent variables causally related to air quality. If we take this critical view now, we have a much better opportunity to carefully select the appropriate engineering control for the independent variables of concern to our air. Consequently, we must first understand that our air quality control options are going to largely fall into one of two categories: (a) particulate-phased pollutants, or (b) gas-phased pollutants. Understanding each will inform us to make the best possible decision when engineering the air quality controls for our systems. According to Godish, Davis, and Fu (2015), particulate-phased pollutants (measured as percentage of particulate matter or PM) really have three main capture strategies that are effective for improving air quality. These include cyclonic collection, electrostatic collection, and numerous methods of filtration collection. Settling chambers, impingers, and cyclones are designed to capture large to medium-sized particles of all types of pollutants. These may include elutriators for aerosol particle collection, as well as cyclones (to include aerosol centrifuges). The documented benefits include their relatively lower costs, simplicity of operation, durability, and generally low maintenance. However, disadvantages include relatively low UNIT VIII STUDY GUIDE Utilizing Pollution Control Technologies for Engineered Air Quality Control
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MEE 6501, Advanced Air Quality Control 2 UNIT x STUDY GUIDE Title efficiencies for smaller particles, the propensity for erosion of components due to abrasive actions of particles, and the large space required to accommodate the equipment (Phalen & Phalen, 2013; Godish et al., 2015). Electrostatic precipitators (including mist precipitators) are designed to operate at high temperatures while creating moisture-laden air as the capture medium. This makes electrostatic capture very efficient for very fine particles. The advantages include the compact nature of the equipment, the lack of dust generation during the capture process, and the constant pressure drop to the system during particle capture. Still, among the most significant disadvantages of the design are the large space requirements for the equipment, the relatively higher initial costs, and the phenomena of some pollutant particle charges not being matched well enough to the system for efficient capture (Phalen & Phalen, 2013; Godish et al., 2015). Filtration options include traditional filtration systems (such as medium filters) that are excellent for capturing dust, fumes, and non-sticky particles with a wide disparity of sizes. This makes for highly efficient systems, moderate power requirements, and a nice, dry disposable waste. However, the low initial cost is often offset by higher bag replacement costs (such as replacing entire bag houses during maintenance shutdowns), and the potential for fire hazards seem to be intrinsically higher in these designs (Phalen & Phalen, 2013; Godish et al., 2015). More advanced filtration options include spray chambers and wet scrubbers (to include venturi scrubbers and wet cyclones). These afford very small particle capture, constant pressure drop (not unlike electrostatic precipitators), and no dust generation. But, one of the disadvantages of the design is that the process involves water. As such, the wastewater generated from the process creates another waste stream that must be handled properly for pre-treatment and ultimate disposal (Phalen & Phalen, 2013; Godish et al., 2015). According to your textbook, gas-phased pollutant capture strategies include a few more options than PM capturing. These include thermal oxidizing (thermal oxidizers, flaring, and catalytic systems), adsorption (packed sorbent beds), absorption (scrubbing), and biological treatment. The different options available within each of these strategies afford the air engineer to aptly match the diverse types of gas pollutants to the control. Thermal oxidizers or “afterburners” are gas combustion chambers with temperatures typically ranging 540ºC to 815ºC. These systems are robust enough to accommodate a moderate range of gases and work similarly to a flare in terms of simply combusting the gas mixtures into less complex gases. There is normally very little maintenance requirements for this technology, and the process is very efficient. However, as with any combustion-related process, carbon dioxide (CO 2 ) and carbon monoxide (CO) is still a potential outcome as a byproduct of combustion (Phalen & Phalen, 2013; Godish et al., 2015). Flare systems are typically used specifically for hydrocarbon-rich gases within a range of concentration just below the upper explosive limit (UEL) and just above the lower explosive limit (LEL). The benefit is that the explosive gases are combusted, often close to or exceeding 99% efficiency. The disadvantage is that, not unlike afterburners, natural gas is often used as a prime for the flare system to keep the pilot lit, even while producing other byproducts of combustion (Phalen & Phalen, 2013; Godish et al., 2015). Catalytic systems (catalytic oxidizers or catalytic converters) are actually catalyst-filled filters that typically operate at elevated temperatures between 370ºC to 480 ºC to treat gases at or near the LEL (Phalen & Phalen, 2013). Benefits include the low maintenance requirements associated with thermal oxidation, as well as the low system pressure drop that is also indicative of electrostatic precipitators. However, one of the most routinely leveraged benefits is the use of this technology to reduce the footprint (size) and fuel use of other systems. Disadvantages include the inefficiencies inherent in the design during colder temperatures, the strong potential for particles to clog the catalytic converter, and the seemingly growing expense of catalyst replacement (Phalen & Phalen, 2013; Godish et al., 2015). Adsorption systems (packed beds) are designed to leverage the adherence (sticking nature) of gas molecules through the van der Waals attractional force phenomena. These can be through either solid or liquid adsorption systems. As discussed at length in your textbook, this is often accomplished with solid media systems by packing beds with various packing media of metal, glass, plastic beads, and activated charcoal in order to create a sorbent environment for the molecules traveling through the system. The polarity of the molecules helps to inform the air engineer of the appropriate media to use in the system, targeting the gas molecules of interest for capture. This specificity of gas molecule targeting is among the benefits of this type of technology, as well as the relative ease of incorporating higher temperature gases for destruction of
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