From: Jerald Trautman (TRAUTMAJ@state.mi.us)
Date: Tue Jun 01 1999 - 12:54:00 CDT
The use of acetone is not a freebie.
When determining VOC content of a coating, remember the content is to be calculated minus water and exempt compounds. Thus if you have a 4.0 lb/gal VOC content and need a 3.0 lb/gal VOC content for compliance, replacing 1 lb of VOCs with 1 lb acetone will not do it. By replacing 1 lb of VOC, the resulting coating has a VOC content of 3.45 lb/gal (when using 7.36 as a default solvent density) not a 3.0 lb/gal VOC content.
Additionally, acetone is still classed as a toxic and the predicted ambient impact must be below the ITSL screen level when a Toxic BACT determination is made in those locals with toxic regulations in a new source permit review. Predicted ambient impacts in excess of the screen level in a T-BACT analysis can be used to determine if add-on control is cost effective. Also, the amount acetone emissions may be added to the amount VOC emissions from a line in determining if add-on control is cost effective in a regular BACT determination in a new source permit review.
From an OSHA standpoint the LEL, concentrations in plant and environs of the system will be of concern.
As with all solvents, the decision to use acetone should be made with health, safety, fire, effectiveness, regulatory requirements, and cost effectiveness and not just the fact that it is not a VOC.
Jerald D. Trautman
Air Quality Division, MI Dept of Environmental Quality
Hollister Building, 4th floor
P.O. Box 30260
Lansing, Mi 48909
Phone: 517-335-4855 FAX: 517-335-3122
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