7 DE Admin Code 1124 "Control of Volatile Organic Compound Emissions" 

23.0	 Coating of Flat Wood Paneling 

03111/2011 

23.1	 Applicability 

23.1.1	 The provisions of 23.0 of this regulation apply to any flat wood paneling coating line, 

except as specified in 23.1.2 of this regulation. 

23.1.2	 The provisions of 23.0 of this regulation do not apply to any flat wood paneling coating 

line within any facility whose actual emissions without control devices from all flat wood 

paneling coating lines within the facility are less than 6.8 kilograms (kg) (15 pounds [Ib]) 

of volatile organic compounds (VOCs) per day. 

23.1.3	 An owner or operator of a facility whose emissions are below the applicability threshold in 

23.1.2 of this regulation shall comply with the certification, recordkeeping, and reporting 

requirements of 23.7.1 of this regulation. 

23.1.4	 Any facility that becomes or is currently subject to the provisions of 23.0 of this regulation 

by exceeding the applicability threshold in 23.1.2 of this regulation will remain subject to 

these proVisions even if its emissions later fall below the applicability threshold. 

23.1.5	 Any facility that is currently subject to a state or federal rule promUlgated pursuant to the 

Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and will 

remain subject to these provisions, even if its throughput or emissions have fallen or later 

fall below the applicability threshold. 

23.2	 Definitions. As used in 23.0 of this regulation, all terms not defined herein shall have the 

meaning given them in the November 15, 1990 Clean Air Act Amendments (CAAA), or in 2.0 

of this regulation. 

'Class I hardboard paneling finish' means finishes that meet the specifications for Class I of 

Voluntary Product Standard PS-59-73 as approved by the American National Standards 

Institute. 

'Class II hardboard paneling finish' means finishes that meet the specifications for Class II of 

Voluntary Product Standard PS-59-73 as approved by the American National Standards 

Institute. 

'Exterior siding' means wood panels with a flat surface made of solid wood, hardboard. or 

waferboard and are intended for use in commercial or residential construction, generally as a 

covering for an outside wall. 

'Flat wood paneling coating line' means a coating line used to apply and dry or cure coatings 

applied to one of the following flat wood paneling product categories: printed interior panels 

made of hardwood plywood and thin particle board (i.e., less than or equal to 0.64 centimeter 

(em) (0.25 inch [in.)) in thickness); natural finish hardwood plywood panels; and hardwood 

paneling with Class II finishes. 

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"Hardboard" is a panel manufactured primarily from inter-felted ligno-<:ellulosic fibers that are 

consolidated under heat and pressure in a hot press. 

"Hardwood plywood" is plywood whose surface layer is a veneer of hardwood. 

"Natural finish hardwood plywood panels" means panels whose original grain pattern is 

enhanced by essentially transparent finishes frequently supplemented by fillers and toners. 

"Printed interior panels" means panels whose grain or natural surface is obscured by fillers and 

basecoats upon which a simulated grain or decorative pattern is printed. 

"Thin particleboard" is a manufactured board that is 0.64 cm (0.25 in.) or less in thickness made 

of individual wood particles that have been coated with a binder and formed into flat sheets 

by pressure. 

"Tileboard" means paneling that meets the specifications for Class I hardboard given by the 

standard ANSIIAHA A135.4-1995 as approved by the American National Standards Institute. 

The standard specifies requirements and test methods for water absorption, thickness 

swelling, modulus of rupture, tensile strength, surface finish, dimensions, squareness, edge 

straightness, and moisture content for five classes of hardboard. Tileboard is also known as 

Class I hardboard or tempered hardboard. 

23.3	 Standards 

23.3.1	 No owner or operator of a flat wood paneling coating line SUbject to 23.0 of this regUlation 

shall cause or allow, on any day, vac emissions from the coating of anyone of the 

following flat Wood paneling categories in excess of the emission limits in Table 23-1 of 

this regUlation: 

TabIe 23-1. VOCEmission Limits from Flat Wood Pane rma Coalrnas. 

Flat Wood Paneling Product Category 

vac Content Limits in Coatings, Inks, 

or Adhesives Beina Aoolied 

Iblgal giL 

Printed interior panels made of hardwood, 

olvwood, or thin oarticleboard 2.1" 250 

Natural finish hardwood plvwood panels 2.1 250 

Class II finishes on hardboard panels 2.1 250 

Tileboard 

Exterior sidina 

2.1 250 

2.1 250 

"This limit of 2.1 Iblgal is e quivalent to 5.0 Ib VOC per 1,000 ft" coatin g area. 

23.3.2	 As an alternative to compliance with the emission limits in 23.3.1 of this regulation, an 

owner or operator of a flat wood paneling coating line may meet the requirements of 23.5 

of this regulation. 

23.4	 Work Practice Standards. No owner or operator of a flat wood paneling coating line subject 

to 23.0 of this regulation shall perform coating operation of any flat wood paneling category in 

Table 23-1 of this regulation unless the owner or operator meets the work practice 

requirements of 8.0 of this regulation. 

23.5	 Control devices 

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23.5.1	 An owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation 

may comply with 23.0 of this regulation by: 

23.5.1.1	 Installing and operating a capture system on that line. 

23.5.1.2	 Installing and operating a control device on that line. 

23.5.1.3	 Determining for each day the overall emission reduction efficiency needed to 

demonstrate compliance. The overall emission reduction needed for a day is the 

greater of: 

23.5.1.3.1	 lesser of the value calculated according to the procedure in 23.6.2 of this 

regulation for that day or 95%, or 

23.5.1.3.2	 90%. 

23.5.1.4	 Demonstrating each day that the overall emission reduction efficiency achieved 

for that day, as determined in 3.0 of Appendix D of this regulation, is greater 

than or equal to the overall emission reduction efficiency needed for that day as 

determined in 23.5.1.3 of this regulation. 

23.5.2	 An owner or operator of a flat wood paneling coating line subject to 23.0 of this regUlation 

shall ensure that: 

23.5.2.1	 A capture system and control device are operated at all times that the line is in 

operation, and the owner or operator demonstrates compliance with 23.0 of this 

regulation through the applicable coating analysis and capture system and 

control device efficiency test methods specified in Appendix B, Appendix D and 

Appendix E of this regulation and in accordance with the capture efficiency test 

methods in Appendix D of this regulation. 

23.5.2.2	 The control device is equipped with the applicable monitoring equipment 

specified in 2.0 of AppendiX 0 of this regulation, and the monitoring equipment 

is installed, calibrated, operated, and maintained according to the vendo~s

specifications at all times the control device is in use. 

23.6	 Test methods and efficiency of control system 

23.6.1	 The test methods specified in 23.6, Appendix A, Appendix B and Appendix 0 of this 

regulation shall be used to determine compliance. 

23.6.2	 The required overall emission reduction efficiency of the control system for the day shall 

be calculated according to the following equation: 

E = [(vae. -S)]X100 

vae. (23-1) 

where: 

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E =The required overall emission reduction efficiency of the control system for the 

day. 

VOC. = The maximum VOC content of the coatings, as applied, used each day on a 

coating line in units of Ib VOC/gal of coating material applied (or kg VOC/L of 

coating material applied), as determined by the applicable test methods and 

procedures specified in Appendix B of this regulation. 

S applicable VOC emission limitation in Table 23-1 of this regulation in terms of Ib 

VOC/gal of coating material applied (or kg VOC/L of coating material applied). 

23.7	 Recordkeeping and reporting 

23.7.1	 Requirements for coating sources exempt from emiSSion limitations. An owner or 

operator of a flat wood paneling coating line that is exempt from the emission limitations 

of 23.3 of this regulation because combined VOC emissions on any day from all flat wood 

paneling coating lines at the facility are below the applicability threshold specified in 

23.1.2 of this regulation, before the application of capture systems and control devices, 

shall comply with the following: 

23.7.1.1	 Certification. Within six months after March 11, 2011, the owner or operator of a 

facility specified in 23.7.1 of this regulation shall certify to the Department that the 

facility is exempt by providing the following: 

23.7.1.1.1	 The name and location of the facility. 

23.7.1.1.2	 The address and telephone number of the person responsible for the facility. 

23.7.1.1.3	 A declaration that the facility is exempt from the emission limitations of 23.3 

of this regulation because combined VOC emissions on any day from all flat 

wood paneling coating lines at the facility are below the applicability 

threshold before the application of capture systems and control devices. The 

following equation shall be used to calculate total VOC emissions for that 

day: 

(23-2) 

where: 

T = Total VOC emissions from coating lines at the facility for each category 

of flat wood paneling (as specified in 23.3.1 of this regulation) before the 

application of capture systems and control devices in units of kg 

VOC/day (Ib VOC/day). 

n =Number of different coatings applied on each coating line at the facility. 

i = Subscript denoting an individual coating. 

C =Mass ofVOC per area of coated finished product in units of kg VOC/100 

m2 (Ib VOC/1,OOO ft'). 

D = The surface area coated at the facility each day in units of m2

/day 

(ff/day). 

a Constant = 100 m2 if using metric units. 

1,000 ff if using English units. 

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23.7.1.2	 Recordkeeping. On and after March 11, 2011, the owner or operator of a facility 

specified in 23.7.1 of this regulation shall collect and record all of the following 

infonnation each day and maintain the information at the facility for a period of 

five years: 

23.7.1.2.1	 The name and identification number of each coating, as applied, used to coat 

each type of flat wood paneling product. 

23.7.1.2.2	 The volume of coating (i) (exclUding water and exempt compounds), as 

applied, used each day to coat each type of flat wood paneling product 

(specified in 23.3.1 of this regulation), and the surface area coated each day 

of each type of flat wood paneling product. 

23.7.1.2.3	 The total vac emissions at the facility, as calculated using the equation 

under 23.7.1.1.3 of this regulation. 

23.7.1.3	 Reporting. an and after March 11, 2011, the owner or operator of a facility 

specified in 23.7.1 of this regulation shall notify the Department of any record 

showing that combined vac emissions from all coating lines at the coating 

facility exceed 6.8 kg (15 Ib) on any day, before the application of capture 

systems and control devices. A copy of such record shall be sent to the 

Department within 45 calendar days after the exceedance occurs. This 

requirement is in addition to any other exceedance reporting requirements 

mandated by the State of Delaware. 

23.7.2	 Requirements for coating sources using complying coatings. An owner or operator of a 

flat wood paneling coating line subject to 23.0 of this regulation and complying with 23.3 

of this regulation by means of the use of complying coatings shall comply with the 

following: 

23.7.2.1	 Certification. Within six months after March 11, 2011, or upon startup of a new 

coating line, or upon changing the method of compliance for an existing coating 

line from control devices to the use of complying coatings, the owner or operator 

of a coating line specified in 23.7.2 of this regulation shall certify to the 

Department that the coating line is or will be in compliance with the requirements 

of the applicable section of this regUlation on and after March 11, 2011, or on and 

after the initial startup date. Such certification shall include: 

23.7.2.1.1	 The name and location of the facility. 

23.7.2.1.2	 The address and telephone number of the person responsible for the facility. 

23.7.2.1.3	 Identification of SUbject sources. 

23.7.2.1.4	 The name and identification number of each coating, as applied, used to coat 

each type of flat wood paneling product. 

23.7.2.1.5	 The vac content of each coating for each type of flat wood paneling product 

(specified in 23.3.1 of this regulation) in terms of Ib VaC/gal of coating 

material applied (or kg VaC/L of coating material applied) and the volume of 

each coating (in tenns of gal or L) coated each day of each type of flat wood 

paneling prodUct. 

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23.7.2.2	 Recordkeeping. On and after March 11, 2011, or on and after the initial startup 

date, the owner or operator of a coating line referenced in 23.7.2 of this 

regulation and complying by the use of complying coatings shall collect and 

record all of the following information each day for each coating line and maintain 

the information at the facility for a period of five years: 

23.7.2.2.1	 The name and identification number of each coating, as applied, used to coat 

each type of flat wood paneling product. 

23.7.2.2.2	 The VOC content of each coating for each type of flat wood paneling product 

(specified in 23.3.1 of this regulation) in terms of Ib VOC/gal of coating 

material applied (or kg VOC/L of coating material applied) and the volume of 

each coating (in terms of gal or L) coated each day of each type of flat wood 

paneling product. 

23.7.2.3	 Reporting. On and after March 11, 2011, the owner or operator of a flat wood 

paneling coating line referenced in 23.7.2 of this regulation shall notify the 

Department in either of the following instances: 

23.7.2.3.1	 Any record showing use of any non<omplying coatings shall be reported by 

sending a copy of such record to the Department within 45 calendar days 

following that use. This reporting requirement is in addition to any other 

exceedance reporting mandated by the State of Delaware. 

23.7.2.3.2	 At least 30 calendar days before changing the method of compliance from 

the use of complying coatings to control devices, the owner or operator shall 

comply with all requirements of 23.7.3.1 of this regulation, as well as 7 DE 

Admin Code 1102. Upon changing the method of compliance from the use 

of complying coatings to control devices, the owner or operator shall comply 

with all requirements of the section applicable to the coating line referenced 

in 23.7.3 of this regulation. 

23.7.3	 Requirements for coating sources using control devices. Any owner or operator of a flat 

wood paneling coating line subject to 23.0 of this regulation and complying with 23.3 of 

this regUlation by the use of control devices shall comply with the following: 

23.7.3.1	 Testing of control equipment. Within six months after March 11, 2011, or upon 

startup of a new coating line, or upon changing the method of compliance for an 

existing coating line from the use of complying coatings to control devices, the 

owner or operator of the subject coating line shall perform a compliance test. 

Testing shall be performed within 90 days of startup, and pursuant to the 

procedures in Appendix A, Appendix B and Appendix D of this regulation and 

23.6 of this regUlation. The owner or operator of the subject coating line shall 

submit to the Department the results of all tests and calculations necessary to 

demonstrate that the subject coating line is or will be in compliance with the 

applicable section of this regulation on and after March 11, 2011, or on and after 

the initial startup date. 

23.7.3.2	 Recordkeeping. On and after March 11, 2011, or on and after the initial startup 

date, the owner or operator of a coating line referenced in 23.7.3 of this 

regulation shall collect and record all of the following information each day for 

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each coating line and maintain the information at the facility for a period of five 

years: 

23.7.3.2.1	 The name and identification number of each coating used On each coating 

line, as applied, used to coat each type of flat wood paneling product. 

23.7.3.2.2	 The vac content of each coating for each type of flat wood paneling product 

(specified in 23.3.1 of this regUlation) in terms of Ib VaC/gai of coating 

material applied (or kg VaC/L of coating material applied) and the volume of 

each coating (in temns of gal or L) coated each day of each type of flat wood 

paneling product. 

23.7.3.2.3	 The maximum vac content of the coatings, as applied, used each day (in 

terms of Ib VaC/gal of coating material applied [or kg vaC/L of coating 

material applied)). 

23.7.3.2.4	 The required overall emission reduction efficiency for each day for each 

coating line as detemnined in 23.6.2 of this regulation. 

23.7.3.2.5	 The actual overall emission reduction efficiency achieved for each day for 

each coating line as detemnined in 3.0 of Appendix 0 of this regulation. 

23.7.3.2.6	 Control device monitoring data. 

23.7.3.2.7	 A log of operating time for the capture system, control device, monitoring 

equipment, and the associated coating line. 

23.7.3.2.8	 A maintenance log for the capture system, control device, and monitoring 

equipment detailing all routine and non-routine maintenance perfomned 

including dates and duration of any outages. 

23.7.3.2.9	 For themnal incinerators, all 3-hour periods of operation in which the average 

combustion temperature was more than 10·C (50·F) below the average 

combustion temperature during the most recent perfomnance test that 

demonstrated that the facility was in compliance. The combustion chamber 

set-point shall be no less than that during the most recent perfomnance test 

that demonstrated that the facility was in compliance. 

23.7.3.2.10 For catalytic incinerators, all three-hour periods of operation	 in which the 

average temperature of the process vent stream immediately before the 

catalyst bed is more than 10·C (50·F) below the average temperature of the 

process vent stream immediately before the catalyst bed dUring the most 

recent perfomnance test that demonstrated that the facility was in 

compliance. The set-point for the process vent stream immediately before 

the catalyst bed shall be no less than that during the most recent 

perfomnance test that demonstrated that the facility was in compliance. 

23.7.3.2.11 For carbon adsorbers, all three-hour periods of operation during which either 

the average vac concentration or the reading of organics in the exhaust 

gases is more than 20% greater than the average exhaust gas concentration 

or reading measured by the organics monitoring device during the most 

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recent determination of the recovery efficiency of the carbon adsorber that 

demonstrated that the facility was in compliance. 

23.7.3.3	 Reporting. On and after March 11, 2011, the owner or operator of a subject 

coating line referenced in 23.7.3 of this regulation shall notify the Department in 

the following instances: 

23.7.3.3.1	 Any record showing noncompliance with the applicable requirements for 

control devices shall be reported by sending a copy of the record to the 

Department within 45 calendar days following the occurrence. This 

requirement is in addition to any other exceedance reporting mandated by 

the State of Delaware. 

23.7.3.3.2	 At least 30 calendar days before changing the method of compliance from 

control devices to the use of complying coatings, the owner or operator shall 

comply with all requirements of 23.7.2.1 of this regulation, and 7 DE Admin 

Code 1102. Upon changing the method of compliance from control devices 

to the use of complying coatings, the owner or operator shall comply with all 

requirements of the Section applicable to the coating line referenced in 

23.7.2 of this regulation. 

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