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Texas Natural Resource Conservation Commission
Interoffice Memorandum

To:  Coatings Group
Date:  May 12, 1997
From:  Allen Zolondek
Subject:  Evaluating Off-Property Concentrations of Inorganic Fluorides

Since inorganic fluorides have been removed from 30 TAC 113, the following method will now
be used for evaluating off-property concentrations of inorganic fluoride emissions.

Water Soluble Inorganic Fluorides (1), Hydrogen Fluoride, & Hydrofluoric Acid: 

The individual concentrations from each of these three categories are summed together to obtain
a Total Hydrogen Fluoride (Total HF) concentration.  The Total HF concentration is compared
with a 3-hour ESL of 4.9 micrograms/m3 and a long-term ESL of 0.5 micrograms/m3.

(1)  Before summing, the concentration of each water soluble inorganic fluoride compound must
first be converted to an equivalent Hydrogen Fluoride concentration as follows:

Concentration (HF Equivalent) = No. Fluoride Atoms (Compound) x ((M.W. HF)/(M.W.
Compound)) x Concentration (Compound)

Non-Water Soluble Inorganic Fluorides:   

The concentrations of these compounds are individually compared with a short-term ESL.