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Regulation

Recommendation

Painting operations

Check spray paint booth specifications with TACB standard exemption 75(a) requirements.  If conditions of the exemption are met, do not complete form PI-7.  If conditions of the exemption are not met, complete and submit to the TACB regional office form PI-7.

Obtain material safety data sheets (MSDSs) on all coatings and thinners used from the suppliers; obtain the particulate control efficiently of the spray booth from the booth manufacturer.

Keep records (on a rolling 2-year retention period) of hours of operation and the usage of any coating materials and solvents used for thinning or cleanup.

Determine the amount of spray painting done in the booth. (It is assumed that spray painting is always done in the booth).  Calculate particulate emissions generated by overspray.

Three boilers (a Kewanee in building 89, a York Shipley, not in use, also in building 89, and a Kewanee in building A-100, not in use but may be used in the future)

These boilers meet the requirements of the exemption and do not require permits.

Maintain monthly fuel usage and hourly operating records.

If CSSA has no intent to use the York Shipley boiler in building 89, dismantle and remove it from CSSA.  Keep records of such activities, including date unit was taken out of service, date unit was dismantled, and final disposition destination (name of transporter and destination).

Two boilers (a Kewanee in building 46 and another in building 201)

Obtain permits, or use #2 fuel oil containing less than 0.3 percent by weight sulfur that is a petroleum distillate oil (not a blend containing waste oil or solvents), or convert the boilers to operate on natural gas.

Maintain monthly fuel usage and hourly operating records.

Steel abrasive tumbler

The tumbler does not meet the requirements of the exemption and is subject to permit requirements.  Obtain a permit for the tumbler, or operate the 3,310-cfm fan from the tumbler to the baghouse below 2,691 cfm, or replace the fan with a 2,691-cfm fan.  Discuss with TACB prior to applying for a permit.  Calculate particulate emissions as described above (Wheelabrator steel shot blaster).

Silverado sand blaster

The sand blaster is not considered a source of air pollution because it does not vent to the atmosphere; therefore, it is not subject to permitting. 

Calculate particaulte emissions as described above (Wheelabrator steel shot blaster).

Glass bead tumbler

TACB standard exemption 22

The glass bead tumbler is not in use and has not been in use for years.  However, should CSSA wish to use the tumbler, the requirements of the exemption are met.  If CSSA does not intend to use the glass bead tumbler, dismantle and remove it from CSSA.  keep records of such activities.

Weapons firing chamber

The weapons firing chamber does not meet the requirements of the exemption; therefore, a permit will be required.  Since the mass balance emission rate used to determine compliance with the exemption was based on an estimate, keep records of the dates and amounts of sand added to the chamber to calculate a more accurate mass emission rate, or conduct a source test on the chamber emissions before applying for a permit.  Compare the obtained emission rate with annual and hourly limits of the exemption to determine if the chamber meet s the exemption.  If the exemption is not met, obtain a permit.

Four USTs

The USTs meet the requirements of the exemption and will not require permits.  Keep records of the date, quantity of fuel loaded and unloaded, tank identification, fuel supplier, and a description of how the tanks were loaded and unloaded (unloaded to boiler, loaded via tank truck with vapor recovery, etc.).

Vapor degreaser

The vapor degreaser does not meet the requirements of the exemption and will require a permit.

Four solvent dip tanks (including the two solvent tanks in the preservative line) and the fingerprint remover tank

The tanks comply with the exemption and do not require permits.  Complete and submit form PI-7 to the TACB regional office in San Antonio for each tank in accordance with the exemption.

Cover or close solvent tanks when not in use.

Two small solvent dip tanks - empty, used for storing hand-carried solvent trays

If CSSA intends to use these tanks, complete and submit form PI-7 to the TACB regional office in San Antonio for each tank.

Soap tank, rinse tanks, hydrochloric acid tank, and nickel penetrate tanks in the bluing shop

The tanks meet the requirements of the exemption and do not require permits.

VCI tank

The tank meets the requirements of the exemption and is exempt from permitting.

Light-oil dip tank (in preservative line in building 90) and oil preservative dip tank (in bluing shop)

The tanks meet the requirements of the exemption and are exempt from permitting.

New VCI tank (to replace existing tank)

The tank meets the requirements of the exemption and is exempt from permitting.

New solvent tank in building 90 (to replace existing tank)

The tank meets the requirements of the exemption and is exempt from permitting.