Surface Coating Permit By Rule-PBR in Texas
Many Texas manufacturers are unaware of environmental regulations that require companies to seek “authorizations” from TCEQ for emitting air pollutants for their painting and coating processes.
Texas Commission on Environmental Quality has a very specific air authorization for this activity: “Surface Coating, 106.433” This authorization is a “PBR” or Permit by Rule. In order to meet the requirements of this regulation, companies must take inventory of all associated paints and/or coatings and track their usage and emissions to prove that they don’t exceed PBR emissions thresholds. This can be a daunting task….
This brief blog post is designed to give some basic guidelines to help companies begin the process.
The information gathering process is normally the most time consuming part of the permit process.
- Identify all of the paints you use including manufacturer name, specific color (some colors have different VOC emissions) and the associated Safety Data Sheet. If you have the old Material Safety Data Sheets, hang on to those since the new data sheets may not include the VOC content. You should already have this as part of the Chemical Inventory requirement of OSHA’s Hazard Communications standard. This will also a requirement under the Permit by Rule.
- Identify all the solvents used for thinning or for cleaning equipment.
- Any surface coating usage records. If you were tracking the quantity of paint used per project or task that would help. This also includes the amount of solvents used for thinning and cleaning.
- If your company has not been tracking usage, you can collect purchase records for the past three years of all the surface coatings and solvents. Basic usage can be determine from purchase records.
- Any process specifications where you have calculated the quantity of surface coating and thinner needed for products of fixed sizes.
- Identify any process equipment such as ovens, hot water heaters, forklifts and anything else that may burn some type of fuel. These emissions would have to be taken into consideration for your overall permit requirements.
In the meantime, and while you begin gathering this information, it’s highly recommended to immediately start tracking your coating/painting usage. Again, you should be tracking is Paint name & color, quantity used, quantity of solvent used for thinning, quantity of solvent used for cleaning, time painting started and time painting ended. This would help start documenting usage that will later help with PBR calculations.
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