frp.txt
frp.txt — 2.3 KB
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Fiberglass Reinforced Plastics (FRP) and Cultured Marble Plants TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology (BACT) be applied to all facilities that must obtain a permit. This BACT determination is made on a case-by-case basis and we encourage discussion between applicants and the TNRCC to determine BACT for each facility. Current BACT practices for the FRP industry are: 1. Low volatile organic compound (VOC), usually styrene, content resin. 2. Vapor suppressed resin. 3. Enclosed molding process, i.e. resin injection 4. At least ninety-five percent air filter efficiency 5. Low vapor pressure cleaning solvents: a. Acetone usage must be less than one percent of total resin usage. b. Acetone replacement compounds with a vapor pressure less than one millimeter Hg. c. Water-based compounds with a VOC content less than five percent by weight. 6. An air ventilation system providing an average of at least 100 feet per minute (fpm) through all building openings. This airflow will minimize fugitive emissions; thereby, reducing off-property styrene concentrations. (Highly recommended) 7. Vertical airflow stacks with stack heads that conform to one of the designs found in the American Conference of Governmental and Industrial Hygienists. 8. Total VOC emissions greater than eighty tons per year may require add-on controls. These levels are guidelines to show the applicant what the TNRCC is currently considering as BACT; however these control levels are subject to change. Each applicant is required to submit a detailed BACT analysis if proposing any controls not listed above. The BACT discussion format needs to follow the TNRCC "three tier" method or the EPA "top down" method. Regardless of the analysis used, applicants must supply control equipment cost estimates, amortized over the life of the equipment, and annualized operating costs. The EPA document OAQPS Control Cost Manual, EPA 450/3-90-006, describes how to perform the analysis and provides the format to use for presentation of results. This manual can be obtained by writing the National Technical Information Service (NATS), 5285 Port Royal Road, Springfield, Virginia 22161 or telephoning 703-487-4650.