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Coating source permitting question



Question for those who write/review permits or those who have seen a lot of
permits for surface coating sources.

Typically, what do particular States/locals require coating sources to do
when calculating VOC emissions?  Do they require them to simply use the
numbers on the MSDS (if so, do they use the high number or the average when
a range is given for a particular component)?  Is a certified product data
sheet required for anyone other than sources subject to the Wood Furniture
NESHAP?  Are sources required to do a one-time Method 24 or obtain Method 24
results from their coating suppliers?  Is a more frequent Method 24 analysis
required?  Is manufacturer's formulation data sufficient?  Or, is the source
given a choice on how they want to document, e.g., "MSDS or equivalent
documentation?"

Basically, what documentation are coating sources typically required to have
to prove that coating X has a VOC content of Y?

Thanks for the help...

Amy Marshall
Midwest Research Institute
(919) 851-8181, ext. 5135
amarshall@mriresearch.org