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TexasSurfaceCoaters

A n E n v i r o n m e n t a l G u i d e f o r

Small Business and Local Government Assistance SectionTexas Commission on Environmental Quality

RG-404 (9/02)

What Can this Guide Do for Me?This guide is tailored to the surface coating industry and contains general

information about air, waste, and wastewater regulations. Surface coatersprepare and coat items that may be made out of metal, wood, plastic, porce-lain, or any of several other materials. The processes of cleaning and coatingcreate air pollution and hazardous waste. Having an air authorization andhandling waste properly have been the main environmental concerns for thesurface coating industry. However, water regulations are becoming increasinglyimportant. This guide also offers ways you can save money through wastereduction and contains appendixes with useful examples.

Keep in mind that this guide does not contain the complete rules or all theinformation you may need to be in compliance.

Other Environmental GuidesThe publications listed below contain information that may be useful to

you. To order any of these booklets, see “How to Get Copies of TCEQ Rules,Publications, and Forms” on the back cover.

✦ An Environmental Guide for Texas Metal Finishers, RG-291

✦ Industrial and Hazardous Waste: Rules and Regulations forSmall-Quantity Generators, RG-234

What If I’m in Violationof TCEQ Rules?

It is always better to report your own violations than to be the subject of acomplaint or to have violations discovered by the TCEQ during an inspection.In many instances, small businesses may not face fines or sanctions for theirfirst violation if they make good-faith efforts to report problems as soon asthey are aware of them and if they develop a TCEQ-approved plan to correctthe problems.

For technical questions and assistance, call the Small Business andLocal Government Assistance Section (SBLGA) for free, confidential helpat 1-800-447-2827. SBLGA is an independent section of the Texas Commissionon Environmental Quality (TCEQ). The Enforcement Division ofthe TCEQ cannot seek information about your contact with the SBLGA.

TexasSurfaceCoaters

Prepared by

Small Business and Local Government Assistance Section

Texas Commission on Environmental Quality

www.tnrcc.state.tx.us/exec/sbea/sblga.html1-800-447-2827

A n E n v i r o n m e n t a l G u i d e f o r

Beginning September 1, 2002, the TNRCC formally changed its name andbegan doing business as the Texas Commission on Environmental Quality, or

the TCEQ. Many of our forms, documents, and Web pages will continue torefer to the TNRCC for a while as we phase in our name change.

www.tceq.state.tx.us/name_change.html

Published and distributed

by the


PO Box 13087

Austin TX 78711-3087

Robert J. Huston, Chairman

R. B. “Ralph” Marquez, Commissioner

Kathleen Hartnett White, Commissioner

Jeffrey A. Saitas, Executive Director

Authorization for use or reproduction of any original material contained in this publica-tion—that is, not obtained from other sources—is freely granted. The commission wouldappreciate acknowledgment.

Copies of this publication are available for public use through the Texas State Library, otherstate depository libraries, and the TCEQ Library, in compliance with state depository law. Formore information on TCEQ publications call 512/239-0028 or visit our Web site at:

http://www.tceq.state.tx.us/publications

The TCEQ is an equal opportunity/affirmative action employer. The agency does not allow discrimination on the basisof race, color, religion, national origin, sex, disability, age, sexual orientation or veteran status. In compliance with theAmericans with Disabilities Act, this document may be requested in alternate formats by contacting the TCEQ at512/239-0028, Fax 512/239-4488, or 1-800-RELAY-TX (TDD), or by writing P.O. Box 13087, Austin, TX 78711-3087.

ii

ContentsChapter 1: Air Regulations .................................. 1Air Pollution and Authorizations .................................2De Minimis ................................................................ 3State Air Authorizations ............................................. 4Federal Operating Permit ........................................... 6Other Requirements ....................................................7Common Air Violations for Surface Coaters ............... 8

Chapter 2: Waste Regulations .............................9Kinds of Waste ......................................................... 10Making a Hazardous Waste Determination ............. 11Nonhazardous Waste ............................................... 12Universal Waste ....................................................... 12Determining Your Generator Status .......................... 13“Registration” versus a Hazardous Waste Permit ..... 14Waste Management Forms ....................................... 14Waste Storage and Management .............................. 17Transportation and Disposal .................................... 18Common Waste Violations for Surface Coaters ........ 18

Chapter 3: Water Regulations .......................... 19Kinds of Wastewater ................................................ 20Storm Water Permitting ............................................ 20On-Site Sewage Facility (OSSF) Rules ...................... 23Common Water Violations for Surface Coaters ........ 23

Chapter 4: General Regulations ....................... 25Changes to Your Business ......................................... 26Record Keeping ....................................................... 26Toxics Release Inventory .......................................... 26Property Tax Exemptions .......................................... 26The Texas Audit Act .................................................. 27Accidental Releases ................................................. 27The Waste Reduction Policy Act .............................. 27Other Agencies ........................................................ 27

Chapter 5: Waste Reduction ............................. 29Less Waste Saves You Money ................................... 30Getting Started With Waste Reduction ..................... 30Good Operating Practices ........................................ 31Good Cleaning Practices ......................................... 32Good Coating Practices ........................................... 32Equipment and Application Techniques ................... 33Surface Coating Pollution Prevention Resources ...... 34

List of FiguresFigure 1: Three Types of Air Authorization ................. 2Figure 2: Hazardous and Nonhazardous Wastes ...... 10

List of TablesTable 1: De Minimis Emission Rates

Based on Effects Screening Levels ......................... 3

Table 2: Common Permits by Rule forSurface Coating Facilities .......................................5

Table 3: Major Source EmissionThresholds for VOCs .............................................. 6

Table 4: Analyzing Your Waste Streams .................... 11

Table 5: Hazardous Waste Generator Categories ..... 14

Table 6: Waste Management Formsand Other Reports ............................................... 15

Table 7: Standard Industrial Codes (SIC)Subject to Storm Water Permitting ....................... 21

Table 8: Transfer Efficiency as a Functionof Spraying Method and Surface Sprayed ............ 34

AppendixesAppendix A: Emissions Calculations ........................ 37Appendix B: Sample Coatings Log ........................... 41Appendix C: Permit by Rule 106.433 ...................... 43Appendix D: Spray Booth Air Flow Calculations...... 45Appendix E: TCEQ Regional Offices ........................ 47

iii

Air RegulationsIn this chapter . . .

Air Pollution and Authorizations ...................................................... 2Which Rules Apply to You? ................................................................ 2

De Minimis ............................................................................................. 3

State Air Authorizations ...................................................................... 4Permit by Rule ........................................................................................ 4

Who Can Register under a PBR? ........................................................ 4State Air Quality Permit .......................................................................... 4

“Grandfathered” Facilities .................................................................. 6

Federal Operating Permit .................................................................... 6Maximum Achievable Control Technology Standards ......................... 7

Other Requirements ............................................................................. 7Special Requirements for Nonattainment andNear-Nonattainment Areas ............................................................... 8

General Requirements ........................................................................ 8Emissions Inventory ............................................................................ 8

Common Air Violations for Surface Coaters .................................. 8

C h a p t e r 1

A n E n v i r o n m e n t a l G u i d e f o r Te x a s S u r f a c e C o a t e r s2

Air Pollution andAuthorizations

Air pollution is created when certain contami-nants enter the air. Volatile organic compounds,sulfur dioxide, particulate matter, carbon monox-ide, nitrogen oxides—these are some of the aircontaminants that are regulated to protect humanhealth and the environment.

If your business emits air pollution above aminor (“de minimis”) level, the law says you mustobtain an “air authorization” before you begin toconstruct, modify, and/or operate your facility.(See “De Minimis” later in this chapter.) Eachindividual piece of equipment that emits pollut-ants into the air may require an authorization.

If your site is already in operation, you stillneed an air authorization. You should begin stepsto obtain one as soon as you become aware thatthis requirement applies to you. For more informa-tion on how to proceed if you find yourself in thissituation, call SBLGA at 1-800-447-2827.

Which Rules Apply to You?If you exceed the de minimis level of emis-

sions, you must follow one or more of the threemain types of air pollution regulations listedbelow. You must decide which ones apply to you.

1. State Air Authorization: subcategories includea Permit by Rule, a Standard Permit, or an AirQuality Permit.

2. Federal Operating Permit: See Figure 1.

3. Special Requirements for “Nonatttainment”and Near-Nonattainment Areas: These areareas that do not meet federal air pollutionstandards (Table 3 later in this chapter lists thecounties in Texas’ nonattainment areas). Alsosee Figure 1.

Figure 1 highlights some important features ofthe three types of air regulations. The rest of thischapter goes into detail about each type.

Whether you need a federal operatingpermit or must follow special requirementsfor nonattainment and near-nonattainmentareas depends on:

✦ where your business is located,

✦ what air pollutants your business emits, and

✦ how much of those air pollutants yourbusiness emits.

Figure 1.Three Types of Air Authorization

De Minimis Status or State Air Authorization

If your business creates air pollution in Texas,you must either

✦ qualify for de minimis status, or

have one of the following state airauthorizations:

✦ a Permit by Rule,

✦ a Standard Permit, or

✦ an Air Quality Permit.

Federal Operating Permit

Required only for “major sources” ofair emissions.

Special Requirements for Nonattainmentand Near-Nonattainment Areas

Requirements differ depending on how far thearea is out of compliance with federal stan-dards for air quality (see Table 3).

C h a p t e r 1 : A i r R e g u l a t i o n s

A n E n v i r o n m e n t a l G u i d e f o r Te x a s S u r f a c e C o a t e r s 3

De MinimisDe minimis sites emit such minor amounts of air

pollution that no state air authorization is required. Ifyou qualify as de minimis, you do not need to registerwith TCEQ. You only need to keep records to provethat you meet the de minimis conditions.

The de minimis rule contains a list of materialsthat, if used at or below the listed thresholds, do not

Before You Read Any Further: Sooner or later,you will have to calculate the air emissions thatyour business produces. Appendix A, “Emis-sions Calculations” gives step-by-step instruc-tions and examples. To do the calculation, youwill need:

✦ ordinary business records showing youruse of supplies such as paints, solvents,and other chemicals (Appendix B, “SampleCoatings Log” may help you track useof materials);

✦ labels that appear on paint, solvents andchemical containers, and Material SafetyData Sheets (MSDSs) that come with them;

✦ an ordinary pocket or desktop calculator.

After you have calculated your emissions,come back to Chapter 1 and work through thesections on “State Air Authorizations,” and“Federal Operating Permits.”

Table 1. De Minimis Emission Rates Based on Effect Screening Levels

ESL ofSubstance(s)

(mg/m3) (pounds/day) (tons/year) (pounds/day) (tons/year)

≥3500 5 0.9 10 2.4

1200-3499 3 0.5 6 1.3

400-1199 1 0.2 3 0.5

100-399 0.25 0.05 1 0.2

Emission Rate Cap for Emission Rate Cap forIndividual Substances, Site-wide Multiple Substances, Site-wide

require an air authorization. These materials andthresholds (in total, site-wide use per year) areas follows:

✦ cleaning and stripping solvents, 50 gallonsper year;

✦ coatings (excluding plating materials), 100gallons per year;

✦ dyes, 1,000 pounds per year;

✦ bleaches, 1,000 gallons per year;

✦ fragrances (excluding odorants), 250 gallonsper year; and

✦ water-based surfactants/detergents, 2,500 gallonsper year.

Use of other material may be considered deminimis based upon the Effects Screening Level(ESL) of the substance and site-wide emission levels(without add-on control devices) as shown by Table 1.For the latest ESL list, call the TCEQ Toxicology andRisk Assessment Section at 512/239-1795.

ExampleA business uses “Chemical X” to strip

metal parts. Chemical X has an ESL of 3,000.The site can emit 3 pounds per day and 0.5 tonsper year of “Chemical X” and still qualify forde minimis.

If you do not qualify as de minimis, you mustseek one of the state air authorizations described inthe next section of this chapter.


State Air AuthorizationsThe type of state authorization you qualify for

will depend on:

✦ the processes and materials you use,

✦ the amount of chemicals you use, and

✦ the amount of air pollution your facility creates.

Authorization does not depend on any financialaspect of your business, such as sales.

Permit by RuleMost small surface coaters qualify for a Permit

by Rule (PBR). PBRs have specific, non-negotiableconditions that your business must meet. You cansave time, as well as money, if your business quali-fies for a PBR; PBRs are approved more quicklythan an air quality permit, and there’s less reporting.

It is important that you keep accurate recordsand documents to verify that you meet the condi-tions of your PBRs. Also, you should pay carefulattention to PBR criteria before you increase yourproduction capacity or make process changes thatwill affect the amount or type of your air emissions.Such changes may require you to apply for a newPBR or a state air quality permit.

More than one PBR may apply to your site. Forexample, you might construct metal or wood framesand display cases into which you place materialsthat you coat. The metal construction and woodwork-ing functions would not fall under your surfacecoating authorization.

Who Can Register under a PBR?Small sources of air pollution may claim a PBR

as long as they can meet all the conditions of thePBR and their emissions fall within certain limits.These general limits, explained in 30 Texas Adminis-trative Code (TAC) Section 106.4, are:

✦ No more than 25 tons per year of volatileorganic compounds (VOCs), sulfur dioxide (SO2)particulate matter (PM10) that is small enough tobe inhaled, or other air contaminants (exceptcarbon dioxide, water, nitrogen, methane,ethane, hydrogen, and oxygen).

✦ No more than 250 tons per year of carbonmonoxide (CO) or nitrogen oxides (NOx).

If your facility does not qualify for any PBRs,you may alter your processes or equipment to meetan applicable PBR. Otherwise, you must apply for astate air quality permit.

Some PBRs require you to register with the TCEQ.Others require no registration. To register, yousubmit a PI-7 form. To obtain TCEQ forms,see instructions on this booklet’s back cover. Todownload the form from the TCEQ Web site, searchfor it by the keyword PI-7 or by the numberTNRCC-10228.

The most common PBRs for surface coatingfacilities are listed in Table 2. Also, Appendix C hasthe complete text of PBR 30 TAC Section 106.433for surface coating operations. Appendix D, “SprayBooth Air Flow Calculations” can help you deter-mine the air flow required to comply with this PBR.

State Air Quality PermitIf your business cannot qualify for de minimis or

a PBR you must have a state air quality permit. Toobtain a permit, you must:

✦ submit TNRCC Form PI-1. This form hasseveral versions and sets of instructions. Toget the form, go to the TCEQ Web site(www.tceq.state.tx.us), click on “Forms,” andtype PI-1 into the box headed “keyword;”

✦ pay a fee; and

✦ submit additional information about yourspecific facility.

You may also have to publish a public notice ina prominent newspaper and post signs (often inmore than one language.) In addition, a publichearing may be required to determine whether youshould receive a permit. For assistance with thedetails of public notice and hearings, please callSBLGA at 1-800-447-2827.

Once your application is approved, a permitis mailed to you. You may begin to modify orconstruct your facility once you receive yourpermit. If you have questions about the permittingprocess, or have already started constructionwithout authorization, please call SBLGA at1-800-447-2827 for assistance.


“Facilities, including drying or curing ovens, and hand-held ormanually operated equipment, used for manufacturing, refinish-ing, and/or restoring wood products” must meet certain controland material usage limits.

This PBR limits hourly VOC emissions, but the limit dependson certain aspects of your business. Other conditions includerequirements for exhaust fans and stacks and record keeping.Metal spraying or metalizing operations may not use this PBR.

Surface coaters that use degreasing units may use this PBR ifthey meet specific requirements about equipment dimensionsand location, operating procedures, solvent use and storage,ventilation, and record keeping. Chlorinated solvent usage mustbe less than 660 gallons per year and usage for all other solventscannot exceed 1,500 gallons per year.

“Surface coating operations utilizing powder coating materialswith the powder applied by an electrostatic powder spray gunor an electrostatic fluidized bed are exempt.”

“Blast cleaning equipment using a suspension of abrasivesin water is exempt.”

Sandblasting or other dry abrasive cleaning processes indoorsor outdoors are exempted with certain restrictions.

“Containers, reservoirs, or tanks used exclusively for dippingoperations for coating objects with oils, waxes, or greases whereno organic solvents, diluents, or thinners are used; or dippingoperations for applying coatings of natural or synthetic resinswhich contain no organic solvents are exempt.”

“Equipment used exclusively to mill or grind coatings andmolding compounds where all materials charged are in a pasteform is exempt.”

“Equipment used for washing or drying products fabricated frommetal or glass is exempt, provided no volatile organic materialsare used in the process and no oil or solid fuel is burned.”

Many restrictions apply to this PBR. See 30 TAC 106.263 or callSBLGA for further information.

“Hand-held or manually operated equipment used for buffing,polishing, carving, cutting, drilling, machining, routing, sanding,sawing, surface grinding, or turning of ceramic art work, ceramicprecision parts, leather, metals, plastics, fiber board, masonry,carbon, glass, graphite, or wood is exempt.”

PaperworkGeneral Topic Number Relevant Equipment and Processes

Required

Table 2. Common Permits by Rule for Surface Coating Facilities

Purchase receiptsfor coatings,solvents, andstripping agentsmust be available.

TNRCC PI-7form for outdoorsurface coatingoperations

TNRCC PI-7form for somedegreasing units

No paperworkrequired


TNRCC PI-7form for outdoorblasting




TNRCC PI-7 formif project lasts>180 days


106.231

106.433

106.454

106.434

106.451

106.452

106.432

106.431

106.453

106.263

106.265

Manufacturing,Refinishing, andRestoring WoodProducts

Surface Coating

Degreasing Units

Powder Coating

Wet Blast Cleaning

Dry AbrasiveCleaning

Dipping Tanks &Containers

Milling & Grinding ofCoatings & MoldingsCompounds

Washing & Dryingof Glass & Metal

Routine Maintenance,Start-up and Shutdownof Facilities, andTemporary Mainte-nance Facilities

Hand-held & ManuallyOperated Machines

For a current copy of these PBRs, go to the TCEQ Web site (www.tceq.state.tx.us), locate the link to “Rules,” andsearch for Chapter 106. If you need help, call SBLGA at 1-800-447-2827.


“Grandfathered” FacilitiesIf you have operated your business in the same

location since 1972, you may qualify as a “grand-fathered facility.” In the past, grandfathered facilitieswere exempt from the requirement for a state airauthorization. However, the Texas Legislature now hasrequired all grandfathered facilities to apply for an airauthorization or shut down their operations.

It is highly unlikely that a surface coating facilitywould qualify as grandfathered. However, if you meetthe qualifications for a grandfathered facility and youare not required to submit an Emissions Inventory,you have the option to seek a special type of airpermit, the Small Business Stationary Source Permitby September 1, 2004. (See “Emissions Inventory”later in this chapter.) If you think you are grand-fathered, call the SBLGA at 1-800-447-2827 forinformation on your options.

Federal Operating PermitAny business classified as a “major source” of air

pollution must comply with additional regulationsand obtain a Federal Operating Permit. Whether youare a major source depends on the amount of pollu-tion your business has the potential to emit (PTE),and the county where your business is located. To find out if you are a major source, you must taketwo steps:

1. Calculate your potential emissions (go toAppendix A for a step-by-step explanation).

2. Compare your potential emissions to the “thresh-old” amounts shown in Table 3. If your potentialemissions exceed the applicable thresholdamounts, you are a major source.

Generally, surface coaters do not use enoughpaints, solvents, thinners, and other products contain-

Table 3. Major Source Emission Thresholds for VOCs

Near- Nonattainment Areas and Pollutant Thresholds2Statewide

Nonattainment Beaumont– Dallas–Fort Houston- HAPArea Threshold1 Port Arthur Area Worth Area Galveston Area El Paso Area Thresholds

Gregg, Nueces, Hardin, Collin, Dallas, Brazoria, El Paso County& Victoria Jefferson, & Denton, & Chambers,Counties Orange Counties Tarrant Counties Galveston,

Harris, Liberty,Montgomery,Waller, FortBend Counties

Nonattainment Nonattainment Nonattainment Nonattainment Nonattainmentstatus: Near- Status: Moderate Status: Serious Status: Severe Status: SeriousNonattainment

VOC Threshold: VOC Threshold: VOC Threshold: VOC Threshold: VOC Threshold:100 tpy3 100 tpy 50 tpy 25 tpy 50 tpy

Note: “Nonattainment” areas do not meet federal clean air standards.1The Austin and San Antonio areas are expected to be classified as near-nonattainment or nonattainment in the future.2The threshold for VOCs in counties not listed in this table is 100 tons per year (tpy).3Tons per year.

Thresholds:10 tpy

single HAP,

25 tpyall HAPs

combined


ing volatile organic compounds (VOCs) or hazardousair pollutants (HAPs) to qualify as major sources.However, in order to be sure of your status, you mustcalculate your emissions and compare them to thethresholds for your area. It is your responsibility tofind out whether your facility is a major source. CallSBLGA at 1-800-447-2827 if you want additionalinformation about Federal Operating Permits.

Maximum Achievable ControlTechnology Standards

The EPA issues rules called Maximum AchievableControl Technology (MACT) standards for manycategories of surface coaters. The list below showsthe categories of coating operations subject to MACTstandards. If you are a major source (see the openingparagraph under the heading “Federal OperatingPermit”), you must include controls for your coatingoperations in your Federal Operating Permit. Formore information on MACT standards, see http://www.epa.gov/ttn/atw/ or call 1-800-447-2827.

The following surface coating categories aresubject to MACT standards:

✦ auto and light duty truck

✦ wood-building products

✦ miscellaneous metal parts

✦ shipbuilding and ship repair

✦ fabric coating, printing, and dyeing

✦ manufacturing of paints, coatings, or adhesives

✦ large appliance

✦ metal can

✦ metal furniture

✦ paper and other webs

✦ wood furniture

Other RequirementsIn addition, you may have to (1) follow special

requirements if you are located in a nonattainment ornear-nonattainment area; (2) conform to generalrestrictions that apply statewide; and (3) submit an

Emissions Inventory. Details on these requirementsappear under the next three headings.

Special Requirements forNonattainment and Near-Nonattainment Areas

If your coating operation is located in a non-attainment or near-nonattainment county, there arelimits on the VOC content of the paints and coatingsyou may use. These requirements can be found in 30TAC Chapter 115, Sections 412 through 429 or onTCEQ’s Web page (www.tceq.state.tx.us) by followingthe link for “Rules.” The Material Safety Data Sheet(MSDS) or product label for each coating shouldindicate the VOC content in pounds per gallon (lb/gal).

You have several options for complying with thesurface coating process rules:

✦ Use coatings that comply with low VOC criteria.

✦ Use add-on controls with overall 80 percentcontrol efficiency.

✦ Be exempt because of

✧ the quantity of VOC emissions (that is, lessthan 3 lb/hr and 15 lb/day);

✧ the quantity of product used (total coatingsand solvent less than 150 gallons per year);

✧ the type of products used; or

✧ other unusual circumstances (all exemptionsrequire approval of the TCEQ and/orthe EPA).

VOC Content LimitsThe following limits are given in pounds of VOC

per gallon of coating, minus water and exemptsolvent. See 30 TAC Chapter 115 Section 421 for themost current limits, which are subject to change.

✦ Large-appliance coating (2.8 lb/gal)

✦ Metal furniture coating (3.0 lb/gal)

✦ Coil coating (2.6 lb/gal)

✦ Paper coating (2.9 lb/gal)

✦ Fabric coating (2.9 lb/gal)

✦ Vinyl coating (3.8 lb/gal)

✦ flat wood paneling

✦ magnetic tapes

✦ metal coil

✦ printing/publishing

✦ aerospace industries


The limits for VOC content in pounds/gallon (lb/gal) of coating for the following activities may varyaccording to the air quality status of your area, thetype of process, and the surface being coated. See30 TAC Chapter 115 Section 421 for the details.

✦ Can coating

✦ Vehicle coating—manufacturing and refinishing

✦ Miscellaneous metal parts and products coating

✦ Factory surface coating of flat wood paneling

✦ Aerospace coating

✦ Architectural coatings—applies to manufacturers/distributors

✦ Surface coating of mirror backing

✦ Surface coating of wood parts and products

✦ Wood furniture manufacturing facilities

✦ Marine coatings

Can I Use a Coating above These VOC limits?Yes; instead of proving that each of your coatings

meets the content limits, you may demonstrate thatthe “daily weighted average” of the coating VOCcontent on each coating line does not exceed thelimit indicated in Section 115.412–29.

How Do I Calculate This“Daily Weighted Average”?

For example, the VOC limit for coatings used formetal furniture in an ozone nonattainment area is 3.0lb/gal. If you use 1 gallon of a 4.0 lb/gal VOC metalfurniture coating and 3 gallons of a 2.5 lb/gal VOCmetal furniture coating in one day, your dailyweighted average would be 2.875 lb/gal and wouldfall below the 3.0 lb/gal limit.

(1 gal × 4.0 lb/gal) + (3 gal × 2.5 lb/gal)= 2.875 lb/gal

4 gal average

These VOC limits must be followed even ifyou are a de minimis source or claim a PBR. Formore information about VOC limits, call SBLGAat 1-800-447-2827.

General RequirementsNo facility in Texas may create “nuisance”

emissions, including odors, “that adversely affecthuman health or welfare, animal life, vegetation, orthe normal use and enjoyment of property.” TCEQregulations also specify that a facility may not releasevisible emissions (fine particles of matter that can beseen by the naked eye) into the air.

Emissions InventoryYou may have to send the TCEQ an annual report

called an “Emissions Inventory” if the followingconditions are true of your business:

✦ your business is a “major source” of air emissions(see Table 3); or

✦ you are located in a nonattainment area (seeTable 3) and your emissions of VOCs are 10 tonsper year or more.

These reports help track and plan the state’sprogress in reducing air pollution. For detailsabout emissions inventories, please call SBLGAat 1-800-447-2827.

Common Air Violationsfor Surface Coaters

Inspections by the TCEQ find that the mostcommon air violations are:

✦ the business has no air authorization but shouldhave a PBR or state air quality permit;

✦ the business is using coatings that contain VOCquantities above regulatory limits fornonattainment or near-nonattinment areas;

✦ the business is not following the conditions of itspermit or PBR;

✦ the business is creating a nuisance condition; and

✦ poor record keeping does not show that the sitemeets the conditions of its air authorization.

Waste RegulationsIn this chapter . . .

Kinds of Waste ..................................................................................... 10What Is a Waste Stream? .................................................................. 10

Making a Hazardous Waste Determination ................................. 11Listed Hazardous Wastes .................................................................. 11Characteristic Hazardous Wastes ..................................................... 12

Nonhazardous Waste ......................................................................... 12

Universal Waste ................................................................................... 12Types of Paint and Paint-Related Universal Waste ............................ 13Shipping and Handling Universal Waste .......................................... 13

Determining Your Generator Status ............................................... 13

“Registration” versus a Hazardous Waste Permit ....................... 14

Waste Management Forms ............................................................... 14STEERS—the Electronic Reporting System ........................................ 14One-Time Shipments ........................................................................ 16Manifests .......................................................................................... 16

Waste Storage and Management ..................................................... 17Waste Management Units ................................................................ 17Satellite Accumulation Areas ............................................................ 17Handling Waste before Disposal ...................................................... 17Empty Paint Cans and Solvent .......................................................... 17

Transportation and Disposal ............................................................ 18

Common Waste Violations for Surface Coaters .......................... 18

C h a p t e r 2


Kinds of WasteBefore you throw anything away, take time to find

out if you’ll be in compliance with state and federalwaste regulations. Every day, businesses dispose ofwaste, some of it hazardous and some nonhazardous.It’s the hazardous waste that can do the most harm toyour business, your employees, and your community.That’s why it’s critical for you to know whether thewaste you have is hazardous, how to handle it, andhow to transport and dispose of it properly.

If a product or material can no longer be used forits intended purpose or some other beneficial pur-pose, it becomes a waste. If a product is in storage tobe used at some later date, it is not a waste. However,even an unused product can be a waste if it is storedpast its shelf life and cannot be used, or if it isaccidently spilled. Any time you are about to create awaste, first consider whether you can recycle it.

As shown in Figure 2, wastes can be categorizedin several ways, depending on their source and therisk they pose. The following terms describe types ofregulated waste:

✦ Hazardous: this means that the waste meetsone or more of EPA’s strict definitions of “hazard-

C h a p t e r 2 : W a s t e R e g u l a t i o n s

NonhazardousHazardous

NonindustrialIndustrialListed Characteristic

Reactivity

Toxicity

Ignitability

Corrosivity

Class 1

Class 2

Class 3

K-listed

U-listed

F-listed

P-listed

Figure 2. Hazardous and

Nonhazardous Wastes

ous waste.” Surface coaters may generatehazardous wastes.

✦ Nonhazardous/Nonindustrial: this means thatthe waste is not hazardous and comes frommunicipal sources — namely, homes or busi-nesses that do not manufacture products, siteswith no production processes. Nonhazardous/nonindustrial waste is frequently called “mu-nicipal waste” and may be disposed of throughyour regular garbage hauler.

✦ Nonhazardous/Industrial: this means that thewaste is not hazardous but comes from sourceslikely to create waste that could be dangerous ifnot properly handled.

For more information about classifying yourwaste, see TCEQ publication RG-22, Guidelines forClassification and Coding of Industrial and Hazard-ous Wastes.

What Is a Waste Stream?Coating operations may create one or more

waste streams. As one waste is being processed,several other wastes may be generated. For ex-ample, if an industrial facility produces a hazardous


IF you have AND they come from THEN the wastes are considered...WASTES that are... PROCESSES that are...

different similar different “waste streams” — e.g., a sludgeremoved from an electroplating vat is not thesame waste stream as a liquid removed froman electroplating vat.

similar different different “waste streams” – e.g., methylenechloride used in a paint-stripping operation is notthe same waste stream as methylene chloride usedin laboratory analysis.

similar similar the same “waste stream” – e.g., a site may haveseveral paint booths performing the same activitieswith the same materials, each producing drop clothwaste. The drop cloth wastes from the various loca-tions at this site could be considered one wastestream as long as they were all classified the same.

altered physically or N/A different “waste streams” – e.g., if a sludge ischemically by treatment dewatered, it may produce two new waste streams,

one a solid and the other a liquid.

acidic waste and at some point neutralizes that waste,it has generated two separate “waste streams.” Table 4gives examples of how waste flows from an operationcan produce a single or several waste streams.

Making a HazardousWaste Determination

“Hazardous waste” is any waste that is defined asbeing hazardous in Title 40, Code of Federal Regula-tions (40 CFR) Section 261.3. There are two differentways that a waste can be designated as hazardous: itcan be “listed” as hazardous or it can have hazardouscharacteristics.

Listed Hazardous WastesThe EPA has placed more than 400 chemicals

and products on four lists. When these chemicals orproducts are disposed of, you must handle them as

hazardous wastes. These lists are designated by theletters F, K, P, or U. The F and K lists include hazard-ous wastes produced during certain industrialprocesses. The F list includes chemicals fromnonspecific sources, such as used solvents. The Klist details hazardous wastes produced from specificsources, such as the production of pesticides.

The P list wastes are “acutely hazardous.” Theyare a small subset of hazardous wastes that areconsidered especially harmful even in small quanti-ties. A surface coater does not usually create acutelyhazardous wastes in its processes. However, youmay have P-list wastes if you use certain pesticideson your property, such as methyl parathion. The Ulist wastes are generally toxic, though they may alsohave other hazardous characteristics. For instance,unused acetone is on the U list.

A complete list of “listed” wastes can be foundin 40 CFR 261, Subpart D. You can find these listson the EPA Web site: www.epa.gov/epacfr40/chapt-I.info/.

Table 4. Analyzing Your Waste Streams


Characteristic Hazardous WastesThe EPA has identified four characteristics that

make a waste hazardous. There is a “TRIC” toremembering these characteristics (Toxicity; Reactiv-ity, Ignitability, Corrosivity.)

✦ Toxicity—waste containing specific concentra-tion levels of contaminants listed by the EPA. TheToxicity Characteristic Leaching Procedure(TCLP) is used to determine whether a waste istoxic. A laboratory can perform this test for a fee.Examples of wastes that could test positive for thetoxicity characteristic include paints with cad-mium or lead.

✦ Reactivity—waste that is unstable or undergoes arapid, violent chemical reaction when in contactwith water or other materials. Peroxides andsome bleaches are examples.

✦ Ignitability—waste with a flash point of less than140˚ F and easily combustible or flammable; forexample, solvents.

✦ Corrosivity—liquid waste that has a pH less thanor equal to 2 or greater than or equal to 12.5,such as hydrochloric acid or sodium hydroxide.Liquid wastes are also considered corrosiveif they corrode steel at a rate greater than6.35 mm/year.

Some wastes can be both a listed and character-istic hazardous waste. For example, spent solventsmight be found on the F list and might also exhibitthe characteristic of ignitability.

What Category Does My Waste Belong To?It’s your responsibility to find out if your shop

generates hazardous waste. Here are three ways toidentify hazardous waste:

✦ Process knowledge: use Material Safety DataSheets and product labels to determine what is inyour waste. Check whether any part of your wasteis on the EPA lists or has hazardous characteristics.Make written notes about how you classified eachwaste stream. Keep your notes in a file to supportyour waste determination.

✦ Testing: Arrange for a lab test to determine if yourwaste is hazardous.

✦ Combination: Arrive at your decision using acombination of the previous two.

Remember, you should create and keep onsite a written hazardous waste determination foreach waste. You only need to do a determinationonce for each waste stream unless you generate anew waste or your waste changes in compositionor concentration.

Nonhazardous WasteGenerators of nonhazardous waste have

different requirements if they are industrial versusnonindustrial. Industrial facilities must determinethe “class” of their nonhazardous waste. Compa-nies that make or coat products on a pre-setschedule, such as an assembly line, are consideredindustrial. All other types of businesses are consid-ered nonindustrial.

Class 1 nonhazardous wastes are consideredpotentially threatening to human health and theenvironment (see Figure 2). There are specialrequirements for handling and disposing of Class 1wastes. This class of waste may only be sent tospecially permitted facilities and must be mani-fested (see “Manifests” under the “Waste Manage-ment Forms” section of this chapter). Examples ofClass 1 waste include absorbent materials con-taminated with petroleum substances, solventswith metal contaminants, and cleaning sludges.

Class 2 nonhazardous wastes are less threat-ening. Examples include food wastes, packaging,and paper products. This waste is often acceptedby local landfills (check with them in advance)and does not require manifesting.

Class 3 nonhazardous wastes are considerednonthreatening. For example, uncontaminatedsteel is a Class 3 waste. This class of waste is oftenrecycled, reused, or landfilled and does notrequire manifesting.

Universal WasteSome hazardous surface coating wastes, such

as paint and paint-related wastes, may qualify as“Universal Waste.” Universal Waste is a specifictype of hazardous waste that is subject to moreflexible regulatory requirements regarding accu-


mulation, record keeping, and shipping. Correctlyclassifying any relevant waste as Universal Waste hasseveral advantages:

✦ It does not count toward your facility’s generatorstatus. (You may be able to change your generatorstatus to a lower level by using this wastedesignation.)

✦ It does not count toward the amount of wasteyou report on the Annual Waste Summary.

✦ It is not subject to end-of-year hazardous wastegeneration fees.

Types of Paint and Paint-Related Universal Waste

The following waste streams meet the criteria forUniversal Waste paint and paint-related waste:

✦ used or unused paint;

✦ spent solvents (for example, paint/lacquer/thinner/varnish that contains pigment);

✦ personal protective equipment, contaminatedrags, gloves, and debris resulting from paintingoperations;

✦ coating waste paint, overspray, overrun paints,paint filters, paint booth stripping materials, andpaint sludges from water wash curtains;

✦ residues from spills of paint and paint-relatedwaste (excluding spill residues from a spillof a Universal Waste paint and paint-relatedwaste material);

✦ cleanup residues from painting and paint removalactivity; and

✦ other paint and paint-related waste generated as aresult of the removal of paint.

Shipping and HandlingUniversal Waste

Universal Waste must be shipped using a nonhaz-ardous waste blue border label. These labels aregenerally supplied by your waste transporter ordisposal facility. Use the proper shipping descriptionfor the material, and add the words “UniversalWaste: Paint and Paint-Related Waste” to the shippingdescription. A common carrier (as opposed to a

registered transporter may be used to transportUniversal Waste within Texas. No manifest is required.For more information, see “Manifests” under the“Waste Management Forms” section of this chapter.

Universal Waste handlers are separated intotwo categories:

✦ A Small-Quantity Handler does not accumulatemore than 5,000 kilograms (11,000 pounds) ofUniversal Waste at any time.

✦ A Large-Quantity Handler may accumulate morethan 5,000 kilograms (11,000 pounds) of Univer-sal Waste. Small-Quantity Handlers do not needto register with either the TCEQ or the EPA.Large-Quantity Handlers must notify the EPA oftheir hazardous waste management activitiesusing either a one-time notification as describedin 40 CFR Section 273.32(b) or EPA form number8700-12. This form can be found at http://www.epa.gov/epaoswer/hazwaste/data/form8700/forms.htm.

Determining YourGenerator Status

Once you classify your wastes, the next step is tofigure out your generator status. Generator status isbased on the amount of hazardous and Class 1industrial waste your business generates monthly. Thethree categories of generator status are:

✦ Conditionally Exempt Small-Quantity Generator(CESQG);

✦ Small-Quantity Generator (SQG); and

✦ Large-Quantity Generator (LQG).

Table 5 explains how you determine your genera-tor status based on the quantity of hazardous andClass 1 waste your company generates.

Informing the TCEQ of a Changein Your Generator Status

You should review your business’ generatorstatus each year. For example, an SQG may changeto a CESQG by reducing the amount of waste createdusing the techniques in Chapter 5 of this guide or byproperly classifying waste as Universal Waste.


To change your generator status, you must write aletter stating that you have documented your changein waste generation and wish to change your officialgenerator status. Include the name of a contact withyour company, the contact’s phone number, and yourcompany’s state hazardous waste generator number.Send the letter to the following address:


Waste Evaluation Section, MC 129

P.O. Box 13087

Austin, TX 78711-3087

“Registration” versus aHazardous Waste Permit

When it comes to hazardous waste, peopleconfuse registration with having a permit. A hazard-ous waste permit is official permission from the EPAand TCEQ to treat or dispose of waste on yourproperty. Most small businesses do not need ahazardous waste permit because their waste ishauled off by a registered transporter for treatmentand/or disposal.

Table 5. Hazardous Waste Generator Categories

1 A waste management unit is an area in your facility where you collect, treat, or store the waste that you generate.It may be a storage shed, a room, an area within a berm, a solvent distillation unit, etc.

2 Accumulation begins when the storage container is placed in the waste management unit. Containers must be labeled“hazardous” and dated.3 The limit is 270 days if the treatment, storage, and disposal facility (TSDF) is more than 200 miles away.

Length of time youcan store it in a wastemanagement unitfrom the timeaccumulation begins2

no time limit

180 days3

90 days

How much hazardous wasteyou can collect In a Wastemanagement unit1

up to 2,200 lbs. (about five55-gallon drums of liquid)

up to 13,200 lbs. (about 3055-gallon drums of liquid)

any amount

How much acutelyhazardous wasteyou can generateper Month

up to 2.2 lbs.(about 1 quart)

up to 2.2 lbs.

over 2.2 lbs.

How much hazardouswaste you cangenerate per month

up to 220 lbs. (abouthalf a 55-gallon drumof liquid)

220 to 2,200 lbs.

over 2,200 lbs.

GeneratorStatus

CESQG

SQG

LQG

LQGs and SQGs need to register with the TCEQ.To register, complete an Initial Notification Package(TNRCC-0002). Businesses that need to register mustregister all wastes, both hazardous and nonhazard-ous, with the TCEQ. The TCEQ informs EPA of yourhazardous waste registration. Registration numbersare site-specific. So, if you move your business to adifferent site, you must fill out a new TCEQ InitialNotification Package and obtain new TCEQ andEPA numbers.

Waste Management FormsYou will need to fill out waste management forms

to comply with state and federal waste regulations.Table 6 describes commonly used forms.

STEERS—the ElectronicReporting System

The State of Texas Electronic EnvironmentalReporting System (STEERS) is a program for wastegenerators and receivers to submit waste manage-ment data electronically. LQGs are required to useSTEERS. For help with STEERS, call the STEERShelpline at 512-239-6925.


Is This Form Used by Generatorswith a Status of…

3 years

while siteis active

while siteis active

3 years

while siteis active

3 years

3 years

3 years

3 years

3 years

3 years

Provides basic identificationinformation about a site

To register with EPA as ahazardous waste generator andreceive an EPA ID number

To register as a hazardous orindustrial waste generator andreceive a registration numberand Notice of Registration(NOR). Also used to add a newwaste stream or managementunit to your NOR

A document the TCEQ sends tothe generator listing specificwaste streams and wastemanagement units on file withthe TCEQ

To notify the TCEQ any time awaste is sent off site forrecycling or recycled on site

To notify the TCEQ of theamount of hazardous wastegenerated and handled at afacility each year

To notify the TCEQ regionaloffice if hazardous wastewill be treated on site withouta permit

To report TRI regulatedchemicals

To report Tier II chemicals andsubstances

A four-part form that accompa-nies hazardous and nonhazard-ous Class 1 waste duringshipment and disposal

To add information to themanifest form if needed

TNRCC-10400

EPA-8700-12

TNRCC-0002

NOR

TNRCC-0525

TNRCC-0436Aor B

WAP

EPA Form R(TRI)

Tier II Form

TNRCC-0311

TNRCC- 0311B

Core Data Form

Notification ofRegulated WasteActivity

Initial NotificationPackage

Notice of Registration(NOR)

Generator Notifica-tion Form forRecycling Hazardousor Industrial Waste

Annual WasteSummary

Waste Analysis Plan

Toxics ReleaseInventory

Tier II

Texas UniformHazardous WasteManifest

Uniform HazardousWaste Manifestcontinuation sheet

Yes

Yes

Yes

Yes

Yes

Yes

Yes

If needed

If needed

Yes

Yes

No*

No

No*

No*

No*

No*

No*

If needed

If needed

No*

No*

Yes

Yes

Yes

Yes

Yes

Yes

Yes

If needed

If needed

Yes

Yes

Table 6. Waste Management Forms and Other Reports

KeepForm For

LQG?SQG?CESQG?Form NumberForm NameForm Description


Is This Form Used by Generatorswith a Status of… Keep Form

ForLQG?SQG?CESQG?

Form NumberForm NameForm Description

One-Time ShipmentsTransporters or disposal companies may require

unregistered CESQGs to obtain temporary TCEQsolid waste registration numbers, temporary EPAidentification numbers, and temporary 8-digit Texaswaste codes. (See TCEQ publication RG-22, Guide-lines for Classification and Coding of Industrial andHazardous Wastes, for an explanation of theseregistration and identification numbers.) In thesecases, CESQGs may use the one-time shipment form(TNRCC-0757, One-Time Shipment Request) toobtain these temporary numbers from the TCEQ.

ManifestsBefore you collect the maximum amount of

waste allowed by your generator status or keepwaste on site for the maximum time allowed (seeTable 5), prepare to have it hauled off site forrecycling, treatment, or disposal. Use a registeredtransporter and disposal company for hazardouswaste and Class 1 nonhazardous waste.

* Industrial facilities that generate 100 kg per month of Class 1 Waste must complete these forms.

Table 6. Waste Management Forms and Other Reports (continued)

How Do I Fill Out a ManifestIf My Company Is a CESQG?

At the top of the manifest form, in the boxthat asks for your US EPA ID No., you can use“TXCESQG.” For generator and transporternumbers, you can use CESQG if you haul yourown waste to a TCEQ-certified TreatmentStorage and Disposal Facility (TSDF).

Each time you have hazardous or Class 1 wastetransported, complete the form titled UniformHazardous Waste Manifest (TNRCC-0311). This formhas four copies:

✦ Green copy: you keep this copy. Be sure thetransporter has signed it.

✦ Yellow copy: the transporter keeps this copy.

✦ Pink copy: the disposal facility keeps this copy.

✦ White copy: this copy is returned to you by thedisposal facility with all blocks signed.

You are responsible for what happens to anywaste you generate, including its proper disposal. If

To notify the TCEQ of anywaste shipped by an unregis-tered generator or out of stateor country

To notify TCEQ that you are anunregistered generator whoneeds temporary identificationnumbers and waste codes

To notify the TCEQ if manifestsare not received back from thedisposal site

To notify the disposal facilityas to the land ban status ofthe waste

Waste ShipmentSummary

One-Time ShipmentRequest

No Form (letter fromgenerator is accepted)

No Form (letter fromgenerator is accepted)

TNRCC-0040

TNRCC-0757

ExceptionReport

“Land Ban”Documents

Yes, ifform 0757(below)is used

Yes, if youhave notregistered

No*

No

No

No

Yes

Yes

No

No

Yes

Yes

3 years

3 years

3 years

3 years


you don’t get the white copy of your manifest backwithin 35 days of having your waste hauled, call yourtransporter and/or TSDF. If you still haven’t receivedthe white copy within another 10 days, you mustinform the TCEQ in writing. This is called filing anexception report. No special form is needed.

Waste Storage andManagement

Hazardous or industrial waste may be storedin two types of storage areas at your facility: at a“waste management unit” or at a “satelliteaccumulation area.”

Waste Management UnitsA waste management unit (WMU) is an area

in your facility where you collect, treat, or storethe waste you generate. A WMU may be a storageshed, an area within a berm, or a solvent distillationunit. These WMUs must be listed on your Noticeof Registration.

Satellite Accumulation AreasYou may keep up to 55 gallons of a hazardous

waste or one quart of acutely hazardous waste at asatellite accumulation area. The satellite area is foraccumulating hazardous waste at or near the point ofgeneration. Label the satellite accumulation containerwith the words “hazardous waste” or with words thataccurately identify the container’s contents. Once thecontainer is full, it must be relocated to a wastemanagement unit within three days, at which time itshould be marked with the accumulation start date.Satellite accumulation areas do not need to be listedon your Initial Notification Package or your Notice ofRegistration.

When Does the Clock StartTicking for Stored Waste?

From the moment you relocate waste to a wastemanagement unit (the accumulation start date), theclock starts ticking on how long you can keep itthere. The length of time you can keep hazardous

waste in your WMU is determined by law anddepends on your generator status (see Table 5).

Handling Waste before DisposalAs you collect and keep wastes on site, you

should properly maintain your waste containers.Wastes may be stored in 55-gallon drums, tanks, orother containers suitable for the type of waste tobe collected. Do the following when storinghazardous waste:

✦ Clearly label each container with the words“Hazardous Waste.”

✦ Indicate the date you actually began to collectwaste in the waste management unit, and thename(s) of the waste(s) in the container.

✦ Inspect tanks on a daily basis, and containersweekly, for leaks, corrosion, and bulging.

✦ Keep containers closed except when filling oremptying them.

✦ Keep containers with ignitable or reactivewastes away from your facility’s propertyline and as far as possible from your generalwork areas.

✦ Never collect different wastes that could reactwith one another in the same container.

✦ Always keep records of your waste manage-ment unit inspections.

Empty Paint Cans and SolventWhen deciding how to dispose of your wastes,

one thing you need to know is that liquid wastescannot go into a municipal landfill. For paintcontainers of five gallons or less, if the paint isnonhazardous and less than one inch of liquidremains on the bottom, let the paint dry and throwthe can in a Dumpster or recycle it. If yourcompany’s paint containers are larger than fivegallons, call Small Business and Local GovernmentAssistance at 1-800-447-2827 to discuss yourdisposal options.

Solvents may be recycled (using a filter ordistillation) and reused. Be aware, there are airregulations that apply to solvent distillation units.See Chapter 5 for more tips on waste reduction.


Transportationand Disposal

When having your hazardous or Class 1waste shipped off site for disposal, you must dothe following:

✦ Choose a transporter that is registered to transporthazardous or Class 1 waste, and that will take itto a TCEQ-approved facility. For help in choosinga transporter or TSDF, check with the TCEQ orEPA regional offices, businesses that may haveexperience in using a hazardous waste trans-porter or TSDF, or TCEQ Publication GI-225,Commercial Hazardous and Industrial SolidWaste Management Facilities.

✦ Properly package and label your wastes forshipping. Your transporter should be able tohelp you.

✦ Manifest your hazardous and Class 1 waste (See“Manifests” under the “Waste ManagementForms” section of this chapter).

✦ Provide information about whether you arelimited from disposing of this waste on land

based on the requirements in 40 CFR Part 268.The transporter can usually help you determine ifthese “land ban” restrictions apply to your waste.

Common WasteViolations forSurface Coaters

Inspections of surface coating businessesrevealed these common waste violations:

✦ no written hazardous waste determinationwas made;

✦ hazardous waste codes were outdatedor inaccurate;

✦ waste containers were not properly labeled;

✦ no record was kept demonstrating weeklyinspections of hazardous waste storage areas;

✦ waste containers were stored open or in poorcondition; and

✦ manifests, land disposal restrictions, and otherrecords were not available.

C h a p t e r 3

Water RegulationsIn this chapter . . .

Kinds of Wastewater ........................................................................... 20Point of Wastewater Discharge Determines Permit You Need ........... 20

Storm Water Permitting ..................................................................... 20Do I Need a Storm Water Permit? ..................................................... 20“No-Exposure” Certification ............................................................. 21What Type of Storm Water Permit Do I Apply For? ........................... 22How Do I Stay in Compliance? ........................................................ 22Where Can I Get Help? .................................................................... 23

On-Site Sewage Facility (OSSF) Rules ........................................... 23Do I Need a Permit for My OSSF? .................................................... 23

Common Water Violations for Surface Coaters .......................... 23


Kinds of WastewaterWastewater includes:

✦ water contaminated with solvents, adhesives,paints, and other coatings;

✦ any water left over after a process; and

✦ water either containing waste or that hascontacted waste.

You must make a hazardous waste determinationon all your wastewater using the methods describedin Chapter 2 under the heading “Making a HazardousWaste Determination.” If some of your wastewater ishazardous, follow the procedures for storing, report-ing, and disposing of hazardous waste.

Point of Wastewater DischargeDetermines Permit You Need

The type of wastewater permit you need will bedetermined by where you discharge your wastewater.

✦ If your wastewater goes to a Publicly OwnedTreatment Works (POTW) that has an approvedpretreatment program, call the POTW in yourcity or town to ask if they have special conditionsfor your discharge.

✦ If your wastewater goes to a POTW that doesnot have an approved pretreatment program,call TCEQ at 512/239-4433 and ask about“categorical discharge limits” and related report-ing requirements. You may also want to reviewTCEQ Regulatory Guidance Publication 401,Reporting Requirements for Categorical IndustrialUsers (CIUs), for more information on whatrequirements apply when you discharge waterto a POTW.

✦ If your wastewater goes into or near a lake, river,or stream, call TCEQ at 512/239-4433 and askabout an industrial wastewater discharge permitunder the Texas Pollutant Discharge EliminationSystem (TPDES).

C h a p t e r 3 : W a t e r R e g u l a t i o n s

Important: Hooking up to a POTW may bean easier process, and may have fewer long-term costs and maintenance requirements foryour operation than obtaining a TPDESpermit and discharging wastewater into anearby body of water.

✦ If your wastewater is disposed of by evaporationin an earthen pond or used for irrigation, callTCEQ at 512/239-4433 and request a Texas LandApplication Permit.

✦ If your wastewater is recycled or reused (exceptfor evaporation or irrigation), it does not require awastewater permit.

Storm Water PermittingStorm water is rainwater runoff that may be

polluted due to its contact with manufacturing orprocessing activities or with raw materials. Certainindustries and construction operators must havepermits that specify how they will limit storm waterpollution and improve the quality of streams, lakes,and rivers into which storm water flows.

Do I Need a Storm Water Permit?Many surface coaters are required to obtain a

storm water permit. Your primary Standard IndustrialClassification (SIC) code determines whether youmust obtain a storm water permit.

To find out if your SIC Code is one that mustobtain a permit, have a look at the codes listed in thegeneral permit. A list of all SIC codes subject toindustrial storm water permitting requirements isincluded in the permit. To find out your SIC code,refer to Box 5 at the top of your Texas WorkforceCommission Tax Employer’s Quarterly Report(Form C-3). The Texas Workforce Commission(at 1-800-227-7816) or the State Comptroller’s Office


“No-Exposure” CertificationFacilities that are subject to stormwater

permitting are required to obtain a storm waterpermit unless they can certify that a condition of“no-exposure” exists at their facility. To qualify fora no-exposure certification, all items in thefollowing list must be covered or located indoorsand, therefore, not exposed to storm water:

(at 1-800-252-5555) can also give you your SIC code.See Table 7 for common surface coater SIC codessubject to storm water permitting.

You may have an SIC code not listed in Table 7and still be subject to storm water permitting. If yourSIC code is not listed in the table, you can call theTCEQ’s Storm Water Permits Team at 512/239-4433to see whether you are subject to storm water permit-ting requirements.

Table 7. Standard Industrial Classification (SIC) Codes Subject to Storm Water Permitting

SIC Code Description

243x Millwood, veneer, plywood, and structural wood member mfg.

244x Wood container mfg.

249x Wood preserving and miscellaneous wood products mfg

265 Paperboard containers and boxes

3357 Drawing and insulating of nonferrous wire

5015 Automobile salvage yards

401x Railroad transportation with fleet maintenance and painting activities

411x Local and suburban passenger transportation with fleet maintenance and painting activities

412x Taxicab companies with fleet maintenance and painting activities

413x–417x Intercity and rural bus transportation with fleet maintenance and painting activities

42xx Motor freight transportation and warehousing with fleet maintenance and painting activities

43xx United States Postal Service facilities with fleet maintenance and painting activities

44xx Water transportation facilities with fleet maintenance and painting activities

45xx Air transportation facilities with fleet maintenance, painting, or deicing activities

22xx Textile mill products

25xx Furniture & fixtures mfg.

27xx Printing & publishing

308x Miscellaneous plastic products mfg.

3093 Musical instrument mfg.

394x–396xMiscellaneous mfg. Industries

& 399x311x Leather tanning and finishing

344x Fabricated structural metal products mfg.

345x Screw machine products, and bolts, nuts, screws, rivets, and washer mfg.

3471 Electroplating, plating, polishing, anodizing, and coloring

349x Miscellaneous fabricated metal mfg.

391x Jewelry, silverware, and plated ware mfg.

399x Miscellaneous mfg. Industries

35xx Industrial and commercial machinery mfg.

36xx & 38xx Electronic, electrical, photographic, & optical goods mfg.


✦ raw materials;

✦ intermediate products, by-products,or final products;

✦ waste materials;

✦ industrial machinery; and

✦ material-handling equipment or activities (stor-age, loading and unloading, or transportation ofanything on this list).

Surface coaters meeting all the no-exposurerequirements must fill out the “No-Exposure” Certifi-cation (TCEQ Form 10383) and submit it to theTCEQ. This form is available on the TCEQ Web site.(Go to www.tceq.state.tx.us and follow the link for“Forms.”) Facilities that apply for a no-exposurewaiver must operate under those conditions at alltimes. No-exposure certifications are good for the lifeof the permit, typically five years, and must berenewed if a new permit is issued. If you are unableto qualify for a no-exposure waiver or can no longeroperate under the no-exposure criteria, you mustobtain a storm water permit.

What Type of Storm WaterPermit Do I Apply For?

There are two permitting options available tosurface coaters that require a storm water permit andthat cannot meet the No-Exposure Certification:(1) a general permit and (2) an individual permit.

Option 1—Multi-Sector GeneralPermit (MSGP) #TXR050000

The Industrial Storm Water Multi-Sector GeneralPermit (MSGP) covers groups of businesses thatconduct similar operations and/or discharge similarwastewater. The application process for the generalpermit is much simpler, less expensive, and less time-consuming than the application process for anindividual permit. To apply for the MSGP:

✦ Obtain a copy of the MSGP from the TCEQ Website, www.tceq.state.tx.us. Click on the Index linkand look for “Industrial Storm Water Permits.”

✦ Also obtain the Notice of Intent (NOI) form,TNRCC-10382, which serves as the applicationto gain coverage under the MSGP.

✦ You also need the Core Data Form, TNRCC10400, which must accompany this application.For the MSGP, TCEQ has attached the Core DataForm to the NOI form you can download fromthe Industrial Storm Water Permits Web page. Orcall 512/239-4433 and ask for the MSGP and theNOI and Core Data Forms.

✦ Develop a Storm Water Pollution Prevention Plan(SWP3), as directed by the MSGP. Your SWP3must be developed before submitting the NOI.The SWP3 is a working document, and is kept onsite for review by your staff members and byTCEQ investigators when requested.

✦ Mail the NOI and Core Data Forms to: StormWater Permits, Texas Natural Resource Conserva-tion Commission, Mail Code 148, P.O. Box13087, Austin, TX, 78711-3087.

Option 2—Individual PermitAn individual permit is written for a single facility

and is site specific. An individual permit requires thecompletion of a detailed application and technicalreport. Few surface coaters need to obtain an indi-vidual permit. To apply for an individual storm waterpermit, call TCEQ at 512/239-4433 and ask for theIndustrial Wastewater Permit Application. The permitapplication consists of two parts: (1) the administra-tive report; and (2) the technical report.

How Do I Stay in Compliance?✦ At your site, keep a copy of your SWP3, a copy of

the MSGP, and a copy of the letter received fromthe TCEQ assigning you a permit number.

✦ Implement the Best Management Practices(BMPs) you developed in your SWP3. Moreinformation on these requirements is provided inthe general permit’s text.

✦ Collect samples as directed in your permit. Thepermit indicates which industries are required tocollect samples and how frequently.

✦ Document all compliance activities related tostorm water.

✦ Update and amend your SWP3 as needed to keepit current.


Where Can I Get Help?For more information on storm water permits, see

the TCEQ Web site at www.tceq.state.tx.us and lookunder “Industrial Storm Water” in the index. Forspecific questions:

✦ Call your regional TCEQ storm water investigator.

✦ Call the TCEQ’s Storm Water Permits Team at512/239-4433.

✦ Call SBLGA at 1-800-447-2827 for confidentialassistance.

On-Site Sewage Facility(OSSF) Rules

Businesses may use on-site sewage facilities(commonly referred to as septic systems) only fordomestic waste and only for up to 5,000 gallons ofwaste per day. The domestic waste must be collected,treated, and disposed of on site. Do not use an on-site sewage facility (OSSF) for discharge of produc-tion wastewater.

All septic systems must be built and installedaccording to TCEQ-approved standards. For more

information about these standards, call TCEQ’sInstaller Certification section at 512/239-2428.

Do I Need a Permit for My OSSF?You must obtain a permit to construct and

operate an OSSF. These permits are issued by localgovernmental units that have been authorized asan agent of the TCEQ, or directly by the TCEQ if nolocal government has been authorized to issue thepermit. Call the TCEQ regional office in your area(see Appendix V) for more information.

Common Water Violationsfor Surface Coaters

Inspections of surface coating businesses revealthese common water violations:

✦ operating without a storm water permit;

✦ failure to write or implement a storm waterpollution prevention plan;

✦ discharging wastewater without proper authoriza-tion (POTW permission, TPDES, or land applica-tion permit); and

✦ discharging process wastewater to an OSSF.

C h a p t e r 4

General RegulationsIn this chapter . . .

Changes to Your Business .................................................................. 26

Record Keeping .................................................................................... 26

Toxics Release Inventory ................................................................... 26

Property Tax Exemptions ................................................................... 26

The Texas Audit Act ............................................................................. 27

Accidental Releases ............................................................................ 27

The Waste Reduction Policy Act ...................................................... 27

Other Agencies .................................................................................... 27


Changes to Your BusinessIf you plan to change any process, method of

operation, or equipment at your business, you mustfirst consider whether you can still meet all theconditions of your PBR, permit, and other authoriza-tions. Changes to your business may change yourwaste generator status or trigger the need for a newpermit or permit amendment.

Record KeepingYou must keep appropriate records that verify

your compliance with environmental rules. Eachtype of authorization specifies its own record-keeping requirements. How long you keep recordsfor the TCEQ varies. For example, any business thatcreates hazardous waste must keep records such asshipping manifests, notices of registration, andannual waste summaries for three years. However,compliance records for air authorization such asPBR 106.433 must be kept for five years in manycases. If your business falls under the reportingrequirements for either Emissions Inventory (seethat heading in Chapter 1) or Toxics ReleaseInventory, you must also keep whatever records arenecessary to file those reports or to document thatno report is required.

Toxics Release InventoryUnder the federal right-to-know law, certain

facilities must report “releases”of specific toxicchemicals in waste. These reports are compiled into astate-by-state Toxics Release Inventory (TRI). Report-able items include toxics in your air emissions orwater discharges and all hazardous waste that yourfacility generates.

You are required to file a report if your facilitymeets all of the following conditions:

C h a p t e r 4 : G e n e r a l R e g u l a t i o n s

✦ you have 10 or more full-time employees ortheir equivalent in total annual employee hoursworked (that is, 20,000 hours);

✦ you annually use at least 10,000 pounds of aTRI-listed chemical, or you manufacture orprocess more than 25,000 lbs of a TRI-listedchemical;

✦ you are in one of 27 specific industries (includ-ing Standard Industrial Classification Codes 20through 39 and metal mining, coal mining,electric utilities, commercial hazardous wastetreatment, wholesale chemical and alliedproducts, wholesale petroleum bulk terminalsand stations, and solvent recovery services);

✦ you manufacture, process, or use persistent,bioaccumulative, toxic (PBT) chemicals abovecertain chemical-specific thresholds (thesechemicals, such as mercury and dioxins, tend topersist in the environment and build up in thefood chain).

For more information on TRI requirements,contact TCEQ’s TRI program at 512/239-4TRI (4874),or visit the TCEQ’s Web site at www.tceq.state.tx.us.Click on the “Index” button and find “Toxics ReleaseInventory.” You may also visit the EPA’s TRI page atwww.epa.gov and click on the “Search” button tofind “Toxics Release Inventory.”

Property Tax ExemptionsYour pollution control equipment may be

exempt from property tax. Under Proposition 2,adopted by the Texas Legislature in 1993, certainproperty and systems used by businesses for envi-ronmental compliance can be exempt from propertytaxes. Your equipment may be on the preapprovedlist. If it is not, you may still ask the TCEQ to deter-mine whether your pollution control equipmentqualifies for a property tax exemption.


ments for spills can be found in 30 TAC Chapter 327.The reportable quantities and requirements for airemissions can be found in 30 TAC Chapter 101. Tonotify TCEQ about an accidental release, call yourTCEQ regional office (see Appendix E).

The Waste ReductionPolicy Act

The Waste Reduction Policy Act (WRPA) wasadopted by the Texas Legislature to help preventpollution in Texas. WRPA requires certain facilities to:

✦ prepare a source reduction/waste minimizationplan (SR/WM);

✦ submit an executive summary of their plan; and

✦ report to the TCEQ annually on their pollutionprevention activities.

These requirements apply to:

✦ Large-Quantity Generators (LQGs);

✦ Small-Quantity Generators (SQGs); and

✦ Toxics Release Inventory reporters.

LQGs, SQGs, and TRI Form R reporters mustprepare a five-year plan to keep on site for inspec-tion. WRPA requirements for SQGs differ from thosethat must be met by LQGs and TRI Form R reporters.

For more information about WRPA requirements,call the Industrial Pollution Prevention team at512/239-3100.

Other AgenciesLocal, city, county, state, and federal agencies

may impose other requirements pertaining to registra-tion, notification, permits, inspections, certificates ofoccupancy, or business licenses. For example, somemunicipal sewage treatment plants issue localdischarge permits. The Texas Department of Healthrequires reporting of large volumes of hazardousmaterials under its Tier II program; call 512/458-7111for more information. In addition, local fire depart-ments frequently have reporting requirements. Youalso may be subject to federal Occupational Safetyand Health Administration (OSHA) standards. (Seethe back cover of this guide for ways to obtain moreinformation about OSHA.)

Examples of preapproved tax-exempt pollutioncontrol equipment used by some surface coatersinclude cyclone-type dust control equipment andsolvent distillation or recycling equipment.

If you think your business might qualify for thistax exemption, get the guidance document PropertyTax Exemptions for Pollution Control Property: DraftGuidance Document for Preparation of Use Determi-nation. You can locate this and other information onthe TCEQ Web site by using the index to select“Tax Exemption.” For further information about the“Prop 2” program, call Small Business and LocalGovernment Assistance at 1-800-447-2827.

The Texas Audit ActThe Texas Environmental, Health, and Safety

Audit Act provides an incentive for you to performvoluntary audits of your company’s compliance withenvironmental, health, and safety regulations. Toqualify for the audit, follow steps 1–4 in exact order.

1. Notify the TCEQ that you plan to do an audit.

2. Complete the audit.

3. Tell the TCEQ what problems you found.

4. Correct these potential violations in atimely manner.

If you complete these steps, you could be exemptfrom penalties. Some information discovered in anaudit is privileged and confidential, and cannot be usedagainst you in civil and administrative proceedings.

For information about this audit process, pleaserefer to Texas Environmental, Health, and SafetyAudit Privilege Act (RG-173). For information on howto order this publication, see “How to Get Copies ofTCEQ Rules, Publications, and Forms” on the backcover. For more information, call TCEQ’s LitigationDivision at 512/239-3400.

Accidental ReleasesAny time you have an accidental release, it’s a

good idea to keep a record of the event, and it isrequired for all unintended air emissions. Reportingis also required if the spill or emission is abovecertain thresholds, commonly known as “reportablequantities.” The reportable quantities and require-

C h a p t e r 5

Waste ReductionIn this chapter . . .

Less Waste Saves You Money ............................................................ 30

Getting Started with Waste Reduction .......................................... 30

Good Operating Practices ................................................................ 31Practices You Can Implement Now ....................................................... 31Practices that Require Investment ......................................................... 31

Good Cleaning Practices ................................................................... 32

Good Coating Practices ..................................................................... 32

Equipment and Application Techniques ........................................ 33Equipment ........................................................................................ 33Application Techniques .................................................................... 34Other Practices ................................................................................ 34

Surface Coating Pollution Prevention Resources ........................ 34


Less Waste SavesYou Money

If your business never had pollution, you wouldn’thave to worry about regulations, permits, or environ-mental reporting. However, most companies mustfollow at least one environmental regulation.

The good news is that the more you reducewaste, the fewer regulations that apply to you andthe less time you’ll spend dealing with the govern-ment. For example, if you generate less than 220pounds of hazardous waste per month and lessthan 220 pounds of Class 1 waste per month, youdo not need to register with the EnvironmentalProtection Agency (EPA) or the TCEQ. This willsave you both time (less reporting) and money(no waste generation fees.)

On the other hand, if your facility generates morethan 2,200 pounds of hazardous waste in a year oryou report under the Toxics Release Inventory (TRI)program, you are required to submit a pollutionprevention plan to the TCEQ. For more informationon this requirement, order publication numberRG-209, Does the Waste Reduction Policy ActApply to You?

Getting Started withWaste Reduction

Re-think, reduce, reuse, recycle. Four simplethings that you can do to save money:

1. Re-think your processes; a new approach cansometimes result in greater savings.

2. Reduce the amount of materials you use.

3. Reuse materials whenever possible.

4. Recycle things you can’t reuse.

C h a p t e r 5 : W a s t e R e d u c t i o n

Begin to develop a plan for your business bytaking these steps:

✦ Identify your sources of waste or pollution. Thiscan be done by developing a simple process-flow diagram, which clearly shows the rawmaterials going into your process and thewastes or pollution coming out.

✦ Consider your options for waste reduction.Research the types of waste reduction technol-ogy available for your processes. If you are amember of a trade organization, ask othermembers what they are doing.

✦ Calculate what you spend to control pollutantsfrom each process, and compare those figureswith costs to reduce pollution from thoseprocesses. For example, compare the costs forthe disposal of paint wastes and thinners to thepurchase price of a distillation unit. The distilla-tion unit would allow you to recover and reusethe thinner, which would in turn save youmoney on product purchases (new thinner)and disposal costs.

✦ Start with the waste reduction activities thathave the most benefit. Identify your facility’slargest source of pollution and tackle that first.For most surface coating facilities, this willprobably be waste paint and coatings, as well asVOC emissions.

✦ Develop a way to track the effectiveness of yourprogram. Have a clear understanding of thebenefits offered by pollution prevention. Setgoals based on these benefits, such as time andmoney saved, and design a spreadsheet orpaper tracking form that clearly demonstratesprogress toward these goals.

✦ Check your operation on a regular basis to findnew ways to reduce waste. Keep up withchanging technology. Certain products andservices may be available today that were notavailable at the time you originally identifiedwaste reduction options for your company.


✦ Educate your employees on your waste reduc-tion policies. Consider making waste reductiona part of your monthly safety meetings, and offerbonus incentives to employees who activelycontribute to your waste reduction program.

As you develop a pollution prevention programfor your business, remember the following.

✦ The small business owner or manager largelydetermines the success of the program. His orher attitude will set the tone for the employees.

✦ Your employees will be the best source for ideason waste reduction. Educate your staff aboutyour goals, and then brainstorm for ideas onhow to reduce or eliminate sources of pollution.

✦ Pollution prevention is an ongoing process.

Good Operating PracticesGood operating practices are not only easy to

do, they cost little or no money and can significantlyreduce your pollution and save you money. Thefollowing list goes over good operating practices youcan implement right away.

Practices You Can Implement Now

Practice Good HousekeepingKeep lids on waste or supply containers, pick up

trash off the floors, and immediately clean upspills—all help avoid pollution.

Train EmployeesTrain employees to use equipment and handle

chemicals properly. Target your training efforts atemployees you believe are stable and permanent.They can serve as role models for newer employees.

Involve EmployeesAsk employees for their ideas about ways to

reduce pollution. They often have good ideas abouthow to reduce waste. Many companies have beenpleasantly surprised by the financial gains realizedfrom their employees’ ideas.

Keep Wastes SeparatedWhen employees mix wastes, contamination

spreads and the resulting waste may be more expen-sive to treat or dispose of. Avoid mixing differentkinds of hazardous wastes. Also, keep hazardous andnonhazardous waste streams separated.

Control Inventory and PurchasingPurchase chemicals in the smallest quantities

possible. Inventory and purchasing should becontrolled by a central person. Limit access tochemical supplies. Chemicals should be stored in alocked, covered space and have a floor and con-tainment area that is compatible with the chemical.Good inventory management can reduce feedstockpurchases and increase efficiency and productivityby using, selling, or returning materials before theirexpiration date.

One company saved money and suppliesby reusing solvent from cleaner to dirtierprocesses and by having a foreman controlsolvent distribution. The company reduced itswaste from 310 to 152 tons per year andsaved $7,200 in disposal and feedstock costs.

Many facilities save 20 percent fromreduced purchases and waste generation afterimplementing materials tracking programs.

Practices That Require Investment

Purchase Bar Coding and Scanning SystemsBar coding systems can be purchased for a few

hundred dollars and often pay for themselves within ayear. One use of a bar coding system is to make suresupplies are used before their expiration date. Otheruseful information includes:

✦ which department is using the coating;

✦ MSDS information;

✦ type of storage required (for example, fire-resistant steel cabinet for flammables); and

✦ spill cleanup procedure.


Good Cleaning PracticesThere are many good cleaning practices you can

implement in your waste reduction program.

Switch to Less Hazardous SolventsSubstitute less hazardous solvent degreasers

(aqueous-based solvents are less hazardous thanpetroleum-based products). Use less toxic solventssuch as dibasic acid esters, terpenes, amines, andalcohols. When determining which solvent to use,consider the total life-cycle cost of the product.

One company used terpenes to clean partsbut then had to dispose of a chrome- andnickel-contaminated used solvent. The newsolvent was biodegradable and nonhazard-ous whereas the previous solvent was not.

Reuse SolventsMinimize your costs for purchasing solvents and

disposing of hazardous waste by filtering and reusingyour solvents many times.

Adopt Blast CleaningUse an air blast system that shoots steel shot,

plastic beads, or other abrasives at a surface to strippaint, rust, or soils from a part. Blast cleaning stillmay generate hazardous waste if the material you areremoving is hazardous. For example, if you sandblastlead paint, then the sand/lead paint waste may behazardous.

One company used sandblasting instead ofmethylene chloride to remove paint andeliminated spent halogenated solvents usedin degreasing waste from this process.

Reclaim SolventsReclaim solvents for reuse. Either on-site or off-

site filtration, gravity separation, or distillation may beused to reclaim solvents. Save cleanup solvent to uselater as thinner for paint of the same color.

Cover Cleaning BathsKeep cleaning baths covered when not in use

to reduce evaporation of cleaner or solvent.

PrecleanExtend solvent life by precleaning parts

(wiping with a rag or using an air blower).

Locate Equipment CarefullyLocate cold-cleaning equipment away from

drafts, fans, or windows. Minimize air flow overtanks so vapors hovering above tanks are notblown away, thus contributing to air pollution. Ifyou qualify for PBR 106.454, refer to the rule forventilation requirements.

Adopt a Spray Gun Cleaning SystemUse a spray gun cleaning system to efficiently

use and reuse solvents.

A company in San Marcos purchased aspray gun washer that circulates solventthrough the gun. The cleaning solvent isfiltered to remove particulates that clogthe gun, and the solvent is reused severaltimes. As a result, the amount of solventused fell by 60 percent, and employeesspent less time cleaning the guns. This$700 enclosed gun washer paid for itselfin six months.

Set Up Staged or Countercurrent RinsingStaged or countercurrent rinsing uses three

tanks of solvent that are progressively cleaner. Thepart goes into the first (dirtiest) tank of solvent,then the second tank, and finally the third(cleanest) tank of solvent. The first tank is dis-carded when the last solvent tank becomes toodirty. Most companies can save at least 20 percentof solvent cost with staged rinsing.

Good Coating PracticesGood coating practices are also a large part of

a waste reduction program.


Use Paint Cup LinersIf you change paint colors frequently, consider

using disposable paint cup liners—they will reducesolvent waste and labor costs from cleaning paintpots. Another advantage to using disposable liners isthat if the paint you use does not contain metals, theliners with dried paint become a nonhazardouswaste stream.

Order Low VOC CoatingsFor surfaces that need to be painted, ask your

supplier for coatings with lower volatile organiccompounds and higher solids than the coatings youcurrently use.

Don’t Paint ItSometimes there is no need to paint a part. If a

part does not need a corrosion resistant or decorativecoating, then maybe you don’t need to paint it at all.

A major airline based in north Dallas onlypaints critical parts of their airplanes. Thissaves the company more than one milliondollars per year in fuel costs because of thereduced weight of the aircraft. It also reducedtheir wastes and emissions they created inthe painting process.

Order High-Solids CoatingsHigh-solids coating formulations reduce the

amount of organic solvent needed by increasing theconcentration of reactive resin in the solvent. Somehigh-solids paints contain close to 85 percent solidswith VOCs of 2.3 to 3.5 pounds per gallon, and onlyrequire a 5 to 10 percent addition of reducer/thinner.Although high-solids paints cost more, the shopneeds less to coat its parts, uses less thinner to reducethe paint, and creates less hazardous waste.

One company saved $1,500 a month andreduced its VOC and hazardous air pollutants(HAPs) emissions by 68 percent after switch-ing to high-solids paints.

Choose Powder CoatingAnother option for paint application that can be

used on metallic parts is powder coating. In thisprocess, powdered paint is first processed in asupply hopper where compressed air diffuses thepaint into a fluidized state. Air pumps then movethe powder through flexible tubing to the sprayguns. The spray guns disperse an electrostaticallycharged powder toward an electrically groundedpart. The powder sticks to the electrostaticallycharged part. The coated part is then baked in anoven where the powder melts, flows, and fuses tothe part’s surface. One bonus to this process is thatair authorization for powder coating does notrequire reporting to the TCEQ.

Replace Paint Booth FiltersConsider replacing current paint filter elements

with plastic substitutes. These elements last longerbetween replacements, allow increased air floweven when saturated, and are fire-treated to reducecombustibility. In some cases, these filters can bewashed off for reuse. If you are using water washcontrol on the booths, consider converting todry filters.

Equipment andApplication Techniques

Two factors determine transfer efficiency,which means how much coating will actuallycover a part: (1) equipment and (2) coating applica-tion techniques.

EquipmentThere is a broad range of transfer efficiencies

associated with various coating systems, as shownin Table 8.

You might also consider using a High-Volume,Low-Pressure (HVLP) gun. The transfer efficiency forHVLP guns has been tested at around 65 to85 percent.


Other PracticesReturnable tote containers and drums,

electrocoating, and powder painting are all waysin which your company can save money andreduce pollution.

Surface Coating PollutionPrevention Resources

For additional help reducing your emissions andother wastes, the TCEQ has developed the CoatingsOperation Workbook for Reducing Waste, availableat the TCEQ Pollution Prevention Web site:www.srwm.org. Other Web sites that might be usefulto you in your efforts to prevent pollution include:

✦ National Center for Manufacturing Sciences:www.paintcenter.org

✦ U.S. Environmental Protection Agency:www.epa.gov/ebtpages/pwastereduction.html

✦ Northwest P2 Research Center:www.pprc.org/pprc

✦ Waste Reduction Resource Center:wrrc.p2pays.org

✦ Coatings Guide: cage.rti.org

✦ Solvent Alternatives Guide: sage.rti.org

STAR Program ShowsTraining Pays Off

The Spray Technique Analysis and Research(STAR) Training Program focuses on HVLP gun useby auto body spray coaters, but the basic tech-niques can apply to many different kinds of coatingapplications. Developed by the Iowa Waste Reduc-tion Center, the STAR Program has proven thattraining employees to effectively use an HVLP gunhas benefits for employers and employees.

Here are just a few techniques taught in theSTAR Program:1. Spray edges first.

2. Always hold the spray gun perpendicular to whatyou’re coating and use parallel strokes.

3. For small and medium panels, make each passthe full length of the panel, feathering the triggerat the beginning and end of each pass.

4. For large panels, walk the full length if possible.Otherwise, make strokes with a 4 to 5 inchoverlap.

During the STAR training, staff videotape allparticipants’ technique as they paint a car hood andbumper. Afterwards, staff teach students properspray paint techniques and then ask students tocritique the video of his or her technique. Researchfrom the STAR program finds that average pre-training spray transfer efficiencies range from 45 to55 percent while average post-training transferefficiencies jump to 70 to 75 percent.

Application TechniquesEquipment and training are closely linked. A

company can have the best equipment with a hightransfer efficiency, but if employees are not trained touse the equipment properly then the company will bewasting supplies.

A 65-employee furniture manufacturer inHouston replaced conventional air-atomizedspray guns with HVLP guns and providedworker training. As a result, annual expendi-tures on paints and coatings plummeted from$69,000 to $35,000. Furthermore, annualVOC emissions fell from 25 tons to 16 tons.

Table 8. Transfer Efficiency as a Function ofSpraying Method and Sprayed Surface

Method of “Table Leg” “Bird Cage”Spraying Flat Surface Surface Surface

Air-atomized 50% 15% 10%

Airless 75–80% 10% 10%

Electrostatic

Disk 95% 90–95% 90–95%

Airless 80% 70% 70%

Air-atomized 75% 65% 65%

Source: Air Pollution Engineering Manual, Air & WasteManagement Association, 1992, p. 362.

Appendixes

Appendix A: Emissions Calculations .............................................. 37

Appendix B: Sample Coatings Log ......................................... 41

Appendix C: Permit by Rule 106.433 ............................................ 43

Appendix D: Spray Booth Air Flow Calculations ........................ 45

Appendix E: TCEQ Regional Offices .............................................. 47


(

Appendix A:

Emissions Calculations

The “gallons” cancelout, leaving you withpounds per hour.

( ) ( ) ( )

( ) )

You will calculate your emissions in three steps:✦ determine maximum hourly emissions;

✦ determine annual “actual” emissions; and

✦ determine annual “potential to emit.”

As discussed in Chapter 1, many requirements apply only if your potential to emit exceeds certain thresholds.Your potential to emit is equal to the emissions your business would create if you operated at your maximum designcapacity, 365 days a year, 24 hours per day.

Maximum Hourly EmissionsLook at your busiest hour from your coating-use records. How many gallons of coating (including thinner) were

applied during that one hour?Write that number here: __________ gallons/hour.

Now find out how many pounds of volatile organic compounds, or VOCs, are in one gallon of coating. You canfind this information from Material Safety Data Sheets (MSDS), suppliers, and/or product labels.Write that number here: ___________ lbs/gallon.

Plug these numbers into the following equation:

Gallons of Coating Applied(including thinner) × Pounds of VOC

=Pounds of VOC Emissions

1 hour 1 gallon of Coating 1 hour

EXAMPLE:Let’s say, in your busiest hour, you used 0.5 gallon of coating mixed with thinner. You called your coating sup-

plier and he told you that there are 3 pounds of VOCs in one gallon of coating and thinner mixed together. Multiply0.5 by 3 to get the amount (in pounds) of VOCs emitted in one hour.

0.5 gallons of coating×

3 pounds of VOCs= 1.5 pounds VOC emissions per hour

1 hour 1 gallon of Coating


) (

)The “hours” cancelout, leaving you withpounds per hour.

3,120 pounds

1 Year

1 ton

2,000 pounds

= 1.56 tons VOCs per year

The “pounds” cancelout, leaving you withtons per hour.

×

( ) (

( )

Annual Actual EmissionsNow, to find out how many tons of VOCs are produced per year, first multiply the number of pounds of VOC

emissions per hour by the number of hours worked per year. Then take that number and divide it by 2,000 (sincethere are 2,000 pounds in one ton). This will give you the number of tons of VOCs emitted per year.

For example, if your facility is operating 8 hours per day, 5 days per week, 52 weeks per year, than that meansthat you are operating for 2,080 hours per year.

8 hours/day × 5 days/week × 52 weeks/year = 2,080 hours/year.

You calculated on the prior page that your facility emits 1.5 pounds of VOCs per hour. So we will take 1.5pounds per hour and multiply that number by the number of hours worked per year, which is 2,080. This will giveyou 3,120 pounds per year.

To get tons of VOCs emitted per year, take 3,120 and divide by 2,000. The result is 1.56 tons of VOCs emittedper year.

1.5 pounds VOCs×

2,080 hours worked= 3,120 pounds per year

1 hour 1 year


)1.5 lbs VOC

Hr

8,760 hr

yr= 13,140 lb/year×

13,140 pounds

Year

1 ton

2000 pounds= 6.57 tons per year

( ( )( ) ( )

Maximum Annual Potential to Emit The easiest way to calculate your potential to emit is to multiply your maximum hourly rate of emissions by

8,760 hours—the maximum number of hours in a year.

(24 hours/day) × (365 days/year) = 8,760 hours/year

You calculated your maximum hourly emission rate above:

For this example, the potential to emit is 6.57 tons per year.

Once you have calculated your potential to emit, compare it to the limits for your county in Table 3 ofChapter 1. If your potential to emit is above the threshold for your county, you are a “major source.”

×


Month/Year: Operation:

Hour 1 2 3 4 5 6 7 8 9

Coating: Coating Coating

Date Date lbs/day lbs/week

1 Sat

2 Sun

3 Mon

4 Tue

5 Wed

6 Thu

7 Fri

8 Sat

9 Sun

10 Mon

11 Tue

12 Wed

13 Thu

14 Fri

15 Sat

16 Sun

17 Mon

18 Tue

19 Wed

20 Thu

21 Fri

22 Sat

23 Sun

24 Mon

25 Tue

26 Wed

27 Thu

28 Fri

29 Sat

30 Sun

31 Mon

lbs/month lbs/month

Coating lbs/hour

Appendix B:

Sample Coatings Log


The Permit by Rule (PBR) that many surfacecoaters will use for their painting and coating airauthorization is 30 TAC Section 106.433. You mayneed other PBRs for other processes, such asabrasive blasting or degreasing. The text of PBR106.433 (previously known as Standard Exemption75) is reproduced below.

Surface coating or stripping facilities, excludingvehicle repair and refinishing shops, shall meet thefollowing conditions of this section to be permittedby rule.(1) This section does not cover metalizing (spraying

molten metal onto a surface to form a coating).However, this section does cover the use ofcoatings which contain metallic pigments.

(2) All facilities covered by this section at a siteshall implement good housekeeping proceduresto minimize fugitive emissions, including thefollowing.

(A) All spills shall be cleaned up immediately.

(B) The booth or work area exhaust fans shallbe operating when cleaning spray guns andother equipment.

(C) All new and used coatings and solventsshall be stored in closed containers. Allwaste coatings and solvents shall beremoved from the site by an authorizeddisposal service or disposed of at a permit-ted on-site waste management facility.

(3) Drying or curing ovens shall either be electricor meet the following conditions:

(A) The maximum heat input to any oven mustnot exceed 40 million British thermal unitsper hour (Btu/hr).

(B) Heat shall be provided by the combustionof one of the following: sweet natural gas;liquid petroleum gas; fuel gas containing nomore than 5.0 grains of total sulfur com-pounds (calculated as sulfur) per 100 drystandard cubic foot; or Number 2 fuel oil

with not more than 0.3 percent sulfurby weight.

(4) No add-on control equipment shall be used tomeet the emissions limits of this section. The totaluncontrolled emissions from the coating materials(as applied) and cleanup solvents shall notexceed the following for all operations:

(A) 25 tons per year (tpy) of volatile organiccompounds (VOC) and ten tpy of exemptsolvents for all surface coating and strippingoperations covered by section at a site;

(B) 30 pounds per hour (lb/hr) of VOC and 5.0lb/hr of exempt solvents for all surfacecoating and stripping operations covered bythis section at a site;

(C) if emissions are less than 0.25 lb/hr of VOCand/or exempt solvents, a facility is exemptfrom the remaining requirements of thissection, including paragraphs (5) - (9) ofthis section.

(5) Opacity of visible emissions shall not exceed 5.0percent. Compliance shall be determined by theUnited States Environmental Protection AgencyMethod 9 averaged over a six-minute period.

(6) The following conditions apply to surface coatingoperations performed indoors, in a booth, or inan enclosed work area:

(A) no more than six lb/hr of VOC emissions,averaged over any five-hour period, and 500pounds per week per booth or enclosed workarea;

(B) minimum face velocity at the intake openingof each booth or work area is 100 feet perminute (ft/min). Emissions shall be exhaustedthrough elevated stacks that extend at least1.5 times the building height above groundlevel. All stacks shall discharge vertically;rain protection shall not restrict or obstructvertical flow;

Appendix C:

Permit by Rule 106.433


used solely by the owner or operator of thefacility or the owner of the property uponwhich the facility is located.

(D) Before construction of the facility begins,written site approval shall be receivedfrom the appropriate regional office of thecommission or any local program havingjurisdiction.

(8) The following records shall be maintained atthe plant site for the most recent 24 monthsand be made immediately available to thecommission or any pollution control agencywith jurisdiction:

(A) Material Safety Data Sheets for all coatingmaterials and solvents;

(B) data of daily coatings and solvent use andthe actual hours of operation of each coatingor stripping operation;

(C) a monthly report that represents actual hoursof operation each day, and emissions fromeach operation in the following categories:

(i) pounds per hour;

(ii) pounds per day;

(iii) pounds per week; and

(iv) tons emitted from the site during theprevious 12 months;

(D) examples of the method of data reductionincluding units, conversion factors, assump-tions, and the basis of the assumptions.

(9) Before construction begins, the facility shall beregistered with the commission using Form PI-7.

Effective September 4, 2000

(C) for spraying operations, emissions of particu-late matter must be controlled using either awater wash system or a dry filter system witha 95 percent removal efficiency as docu-mented by the manufacturer. The facevelocity at the filter shall not exceed 250 ft/min or that specified by the filter manufac-turer, whichever is less. Filters shall bereplaced whenever the pressure drop acrossthe filter no longer meets the manufacturer’srecommendation.

(7) For surface coating operations that are performedoutdoors or in a non-enclosed work area, or forindoor operations that do not meet the conditionsof paragraph (6) of this section, the followingconditions apply.

(A) No more than six lb/hr of VOC emissions,averaged over any five-hour period, and500 pounds per week shall be emitted atany time for all operations authorized bythis paragraph.

(B) If coatings applied with spray equipmentcontain more than 0.1 percent by weight ofchromates, lead, cadmium, selenium,strontium, or cobalt, then total VOC emis-sions shall be further limited to 240 poundsper week and 2,000 pounds per year. Ifcoatings are applied with non-spray equip-ment (such as brushes, rollers, dipping orflow coating), the additional restrictions inthis paragraph do not apply.

(C) Coating operations shall be conducted atleast 50 feet from the property line and atleast 250 feet from any recreational area,residence, or other structure not occupied or


Appendix D:

Spray Booth Air Flow CalculationsCalculating Air Intake Opening and Filter Areas

Square or RectangleIf air passes through a single intake opening or filter bank and the shape is square or rectangular, the

calculation is: (L � W = Area)Air Intake Opening (or Filter) Length � Air Intake Opening (or Filter) Width = Area of Intake or Filter

CircleIf the shape of the intake opening is circular: π � r2 = Area (π = 3.14 and r = radius of air intake opening)

Multiple OpeningsIf air passes through two or more intake openings or filter banks, add all the intake or filter areas to determine

the intake or filter areas.area intake 1 + area intake 2 + area intake 3 = total intake opening areaarea filter 1 + area filter 2 + area filter 3 = total filter area

Calculating Face VelocityThe calculation for face velocity is the same for all types of spray booths (side draft, cross draft, end draft or

down draft booths, and enclosed work areas).1. First, know your fan flow capacity in cubic feet/minute.

2. Determine the area of your air intake opening and the filter.

3. Take the fan flow capacity (#1) and divide it by the air intake or filter area (#2).

Intake Face Velocityfan flow capacity (cubic ft/min)

= face velocity (ft/min) (must be at least 100 ft/min)air intake area (sq ft)

Filter Face velocityfan flow capacity (cubic ft/min)

= face velocity (ft/min) (can’t exceed 250 ft/min)air filter area (sq ft)

TipFace velocity can be calculated either by the formula above or measured with a velocimeter. The cost of this

measurement device ranges from approximately $20 to $200 and can be purchased through an industrial/commer-cial equipment and supply catalog.


Examples of Face Velocity CalculationsIn order to achieve a face velocity of at least 100 ft./min. at the air intake opening and no more than 250 ft/min

at the exhaust, adjustments may be made to the fan flow capacity, or you may change the size of the air intake/effective exhaust area. There are no minimum or maximum limits to either the fan flow capacity or the size of theair intake or filter.

Face Velocity/Fan Flow Capacity ExampleA fan flow capacity of 7,000 cubic feet per minute (cfm) will provide a face velocity of 100 ft/min if the air

intake area is 70 sq ft:fan flow capacity = 7,000 cubic ft/min

= 100 ft/min face velocityintake area 70 sq ft

Air Intake Area/Fan Capacity ExampleAn air intake area of 40 sq ft will require a fan capacity of 4,000 cfm to obtain a 100 ft/min face velocity:fan flow capacity = 4,000 cubic ft/min

= face velocity of 100 ft/minintake area 40 sq ft

If you already have a fan and do not wish to make changes to the fan strength, you may adjust the size of theintake and exhaust filter areas and use the fan flow capacity you have now.

Flow Capacity/Air Intake/Air Filter ExampleIf you have a fan with a flow capacity of 1,500 cfm, you must determine what size air intake opening you can

have to meet the 100 cfm limit at the opening, and then determine what size air intake opening area you need soyou don’t exceed the 250 cfm maximum at the exit.

To Figure Out the Intake Openingfan flow capacity = 1,500 cubic ft/min

= 15 sq ftface velocity 100 ft/min

This means that for a 1,500 cfm fan size, your intake opening can be no bigger than 15 sq ft. It can be smaller ifyou choose.

To Figure Out the Effective Exhaust Sizefan flow capacity = 1,500 cubic ft/min

= 6 sq ftface velocity 250 ft/min

This means that for a 1,500 cubic ft/min fan size, your exhaust area can be no smaller than 6 sq ft. It can belarger if you choose.


1 – AMARILLORegional Director - Brad Jones3918 Canyon Dr.Amarillo, TX 79109-4933806/353-9251 FAX: 806/358-9545

Perryton Office511 South MainPerryton, TX 79070806/435-8059 FAX: 806/434-8443

2 – LUBBOCKRegional Director - Jim Estes4630 50th St., Ste. 600Lubbock, TX 79414-3520806/796-7092 FAX: 806/796-7107

3 – ABILENERegional Director - Winona Henry1977 Industrial Blvd.Abilene, TX 79602-7833915/698-9674 FAX: 915/692-5869

4 – DALLAS/FORT WORTHRegional Director - Frank Espino2301 Gravel Dr.Fort Worth, TX 76118-6951817/588-5800 FAX: 817/588-5700

Stephenville (Confined AnimalFeeding Operations)580-D W. Lingleville Rd.Stephenville, TX 76401254/965-5624 or 800/687-7078

5 – TYLERRegional Director - Leroy Biggers2916 Teague Dr.Tyler, TX 75701-3756903/535-5100 FAX: 903/595-1562

6 – EL PASORegional Director - Archie Clouse401 E. Franklin Ave., Ste. 560El Paso, TX 79901-1206915/834-4949 FAX: 915/834-4940

7 – MIDLANDRegional Director - Jed Barker3300 North A St., Bldg. 4, Ste. 107Midland, TX 79705-5404915/570-1359 FAX: 915/570-4795

8 – SAN ANGELORegional Director -Ricky Anderson622 S. Oakes, Ste. KSan Angelo, TX 76903-7013915/655-9479 FAX: 915/658-5431

9 – WACORegional Director - Anna Dunbar6801 Sanger Ave., Ste. 2500Waco, TX 76710-7826254/751-0335 FAX: 254/772-9241

10 – BEAUMONTRegional Director - Georgie Volz3870 Eastex Fwy.Beaumont, TX 77703-1892409/898-3838 FAX: 409/892-2119

11 – AUSTINRegional Director - Patty Reeh1921 Cedar Bend Dr., Ste. 150Austin, TX 78758-5336512/339-2929 FAX: 512/339-3795

12 – HOUSTONRegional Director -Don A. Thompson5425 Polk Ave., Ste. HHouston, TX 77023-1486713/767-3500 FAX: 713/767-3520

13 – SAN ANTONIORegional Director - Richard Garcia14250 Judson Rd.San Antonio, TX 78233-4480210/490-3096 FAX: 210/545-4329

South Texas Watermaster Office210/490-3096 FAX: 210/545-43291-800/733-2733

14 – CORPUS CHRISTIRegional Director - Buddy Stanley6300 Ocean Dr., Ste. 1200Corpus Christi, TX 78412-5503361/825-3100 FAX: 361/825-3101

15 – HARLINGENRegional Director - Tony Franco1804 West Jefferson Ave.Harlingen, TX 78550-5247956/425-6010 FAX: 956/412-5059

Rio Grande Watermaster Office956/425-6010 FAX: 956/412-5059

Eagle Pass Office1152 Ferry St., Ste. HEagle Pass, TX 78852830/773-5059 FAX: 830/773-4103

16 – LAREDORegional Director -Gerardo J. Pinzon1403 Seymour, Ste. 2Laredo, TX 78040-8752956/791-6611 FAX: 956/791-6716

Appendix E:

TCEQ Regional Offices


11

10

5

6

16

7

14

12

8

43

1

2

9

15

13

Region 1 - Amarillo806/353-9251

Region 3 - Abilene915/698-9674

Region 2 - Lubbock806/796-7092

Region 6 - El Paso915/834-4949

Region 8 - San Angelo915/655-9479

Region 7 - Midland915/570-1359

Region 12 - Houston713/767-3500

Region 13 - San Antonio210/490-3096

Region 14 - Corpus Christi361/825-3100

Region 15 - Harlingen956/425-6010

Region 5 - Tyler903/535-5100

Region 4 - DFW817/588-5800

JohnsonKaufmanNavarroPalo PintoParkerRockwallSomervellTarrantWise

Region 10 - Beaumont409/898-3838

Region 9 - Waco254/751-0335

HemphillHutchinsonLipscombMooreOchiltreeOldhamParmerPotterRandallRobertsShermanSwisherWheeler

AndersonBowieCampCherokeeCassDeltaFranklinGreggHarrisonHendersonHopkinsLamar

CollinCookeDallasDentonEllisErathFanninGraysonHoodHunt

ArcherBaylorBrownCallahanClayColemanComancheCottleEastlandFisherFoardHardemanHaskellJackJones

KentKnoxMitchellMontagueNolanRunnelsScurryShackelfordStephensStonewallTaylorThrockmortonWichitaWilbargerYoung

BaileyCochranCrosbyDickensFloydGarzaHaleHockley

KingLambLubbockLynnMotleyTerryYoakum

ArmstrongBriscoeCarsonCastroChildressCollingsworthDallamDeaf SmithDonleyGrayHallHansfordHartley

BrewsterCulbersonEl Paso

HudspethJeff DavisPresidio

CokeConchoCrockettIrionKimbleMasonMcCulloch

MenardReaganSchleicherSterlingSuttonTom Green

MartinMidlandPecosReevesTerrellUptonWardWinkler

AndrewsBordenCraneDawsonEctorGainesGlasscockHowardLoving

BellBosqueBrazosBurlesonCoryellFallsFreestoneGrimesHamiltonHill

LimestoneLampasasLeonMadisonMcLennanMilamMillsRobertsonSan SabaWashington

AngelinaHardinHoustonJasperJeffersonNacogdochesNewtonOrange

PolkSabineSan AugustineSan JacintoShelbyTrinityTyler

BrooksCameronHidalgoJim Hogg

KenedyStarrWillacy

AransasBeeCalhounDe WittGoliadGonzalesJacksonJim Wells

KlebergLavacaLive OakNuecesRefugioSan PatricioVictoria

AtascosaBanderaBexarComalEdwardsFrioGillespieGuadalupe

KarnesKendallKerrMedinaRealUvaldeWilson

AustinBrazoriaChambersColoradoFort BendGalveston

HarrisLibertyMatagordaMontgomeryWalkerWallerWharton

Region 11 - Austin512/339-2929

HaysLeeLlanoTravisWilliamson

BastropBlancoBurnetCaldwellFayette

Region 16 - Laredo956/791-6611DimmitDuvalKinneyLa SalleMaverick

McMullenVal VerdeWebbZapataZavala

MarionMorrisPanolaRainsRed RiverRuskSmithTitusUpshurVan ZandtWood


How to Get Copies of TCEQRules, Publications, and Forms✦ On the Internet go to www.tceq.state.tx.us and click on the

link for “Rules,” “Publications,” or “Forms.” Download andsave or print a copy.

If the item you want is not listed on the Web site, the TCEQPublications Unit will try to help you find it; contact them asshown below.✦ Fax your order to 512/239-4488, or order by voice at

512/239-0028.

✦ Write to TCEQ Publications, MC 195; PO Box 13087;Austin, TX 78711-3087.

Try to give the number of the rule, publication, or form, aswell as the title; this information will help the TCEQ get thecorrect item to you as quickly as possible.