MSOP and missing emissions?

We have a Minor Source Operating Permit for our paint booth process and record our VOC usage daily, along with submitting quarterly usage reports to the state. We also receive 55-gal drums of isopropyl alcohol on a regular basis, and someone asked me recently if I was including those emissions discharged to the atmosphere as part of our permit. I am not. Am I out of compliance? 

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Answers

  • Unfortunately, you are likely out of compliance. Isopropyl Alcohol is federally regulated as a smog forming volatile organic compound reportable to EPA. In my experience, to definitively know the VOC requirements for a facility, you would need specific details of the state in which it is located, the EPA region under whose regulations they operate, if they are operating under a Federal NESHAP, the existence of state and local emission regulations, and the specific application or way in which the product will be used.