Develop a document titled “A Permit by Rule (PBR) Evaluation for a Painting Operation” and will serve as a simulation of our work as a contract environmental engineer to an industrial organization planning a painting operation within the United States.
The Scenario:
You have contracted with an industrial organization to engineer and write a state air Permit by Rule (PBR) evaluation for a painting operation facility. According to the local state laws and U.S. Environmental Protection Agency (EPA) laws, the facility must have an air permit before construction begins. Once the facility is completed, the construction air permit will then become the operational air permit for the facility.
As a result, your client wants the air permit to automatically align the painting operation facility into operational compliance with state and federal air quality laws. Consequently, it is extremely important for you to evaluate the planned painting operation against the PBR requirements in order to meet the air permit criteria, using the state guidance document and considering the equipment and chemicals already planned for the facility operations.
You have tabulated the following information from what you have gleaned from the material SDS documents and equipment technical data sheets plan (depending on your scenario selection, each “unit” represents a single aircraft, rail tank car, or vehicle):
Interior Liner Coating Material
10 gallons coating/unit
2 gallons of solvent/unit
Unit Lining Application
Apply interior liners to two (2) units/day
Work five (5) hours/day and four (4) days/week
Unit Lining Curing
Cure interior liners of two (2) units/day
Work five (5) hours/day and four (4) days/week
Interior Liner Cure
Heater fuel source is natural gas-fired drying oven
Heater generates 2.1 million (MM) Btu/hr at maximum 2,500 hrs/year
Unit Lining Design
Cross-draft air plenum
Unit interior is the spray area
Exhaust Fan
10,000 ft3/min (CFM)
1 exhaust fan
Air Makeup Unit
5760 ft3/min (CFM)
1 air makeup system
Filter Openings
20.0 ft2 each
Two (2) filter openings
Coating WV
VOC content
2.8 lb/gal coating
Coating VM
Coating volume
1.0 gal
Water Content
Per gal/coating
1.0 lb/gal
Water Density
Per gal/water
8.34 lb/gal
Coating VW
Water volume
Calculation
Exempt-solvent Content
Per gal/coating
0.5 lb/gal
Exempt-solvent Density
Per gal/exempt solvent
6.64 lb/gal
Coating Ves
Exempt solvent volume
Calculation
Additionally, your state’s department of environmental quality (DEQ) has provided you the following PBR limits:
Potential to Emit (PTE)
100 tons VOC/year
Face Velocity
100 ft/min
Filter Velocity
250 ft/min
VOC/5-hour period
6.0 lbs/hr
Short-term Emissions
1.0 lbs/hr
Long-term Emissions
1.0 tons/yr
From your first visit with your client, these are your notes and process flow sketch reflecting the intended operational design:
The client has designed an interior coating spray painting system that allows the interior of each unit to be coated.
The operations will involve a stripped-down unit being brought into the facility’s shop.
The shop is a steel building with a finished concrete floor and a paint booth for each unit.
The unit will be placed in the spray booth.
The booth will be opened at one end of the booth for makeup air.
The exhaust air will flow through an exhaust chamber at the other end of the unit.
For each unit, once the liner application operations are completed, the forced curing (drying) operations will immediately commence.