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Ask the Expert Question-and-Answer Archive

by Ron Joseph

November, 2004

Estimating HAP Emissions

Q. How do you recommend estimating the potential emissions of HAPs (single and combined) from a painting operation that uses many different paints with different HAP contents. My experience has been to take a worst case for each HAP present among the different paints that the sources uses. This method tends to over estimate emissions for most sources.

Some sources maintain an electronic database of the paints they use or their paint supplier does and are able to very accurately calculate actual emissions for compliance purposes.

What are your thoughts?

To the best of my knowledge there is no easy way to estimate the potential HAP emissions for several paints with different HAP contents. (Here the word "potential" means "possible," and should not be read as the EPA term "Potential to Emit.") Some paints are essentially HAP-free, while others might contain a significant percentage of Toluene, Xylene and other HAP solvents.

If you go for the worst case as you mentioned, you might cause a company to trigger a NESHAP, and this could cost the company dearly in terms of compliance, record keeping, etc.

To simplify the process, you might group all the paints and coatings into categories. For instance, if the company uses several colors within a single product range, such as "Sherwin-Williams Polane Polyurethane," you might get an average or even worst case HAP content for the range of colors, and apply that value to each color. This might work well only if all the colors are within the paint vendor's product range, and now your job is greatly simplified. However, if the paints and coatings cover a wide range of unrelated products, you have no choice by to perform the calculations for each product.

Hope this helps.

Best wishes,

Ron Joseph

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