Best available control technology (BACT) equivalent for the control of volatile organic emissions from paint dipping operations

摘要

This article provides details of a study conducted to demonstrate an equivalent method of Best Available Control Technology (BACT) compliance for volatile organic emissions from dip coating of certain miscellaneous metal parts. The study was proposed to show that the total volatile organic compound (VOC) emissions from 3.8 lb of VOC/gallon coating formulations were no greater than the total VOC emissions from 3.5 lb/gal formulations used under the same conditions for coating steel joists. The presumptive BACT standard enforced by the Virginia Department of Environmental Quality (DEQ) for dip coating of steel joists is 3.5 lb/gal. The requirement of 3.5 lb/gal was derived from the U.S. Environmental Protection Agency (EPA) Guideline Series Control of Volatile Organic Emissions from Existing Stationary Sources-Volume VI: Surface Coating of Miscellaneous Metal Parts and Products. On June 5, 1998, the source completed a 12-month, full-scale comparison study under a consent order with the Virginia DEQ. During the study period, the source made daily measurements of product produced, paint used, and emissions from the control and test paint tanks and reported data to EPA and the DEQ every two months. The study concluded that a 26 reduction in paint usage and a 20 reduction in emissions was achieved in the test tanks using a 3.8 lb/gal coating compared to the control tanks using a 3.5 lb/gal coating. This study enables the source to achieve greater emission reductions than the presumptive BACT level and at the same time reduce painting costs by 34. This study provides positive results for the environment, the steel joist industry, and the construction industry. This study could impact EPA's current Maximum Achievable Control Technology (MACT) rule development for Miscellaneous Metal Parts and Products and national VOC rules for this source category under Section 183(e) of the Clean Air Act.