23.0 Coating of Flat Wood Paneling 

(2010 revision, draft 1) 

ll1!11!1QQ3 mm/dd/2010 

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: 23.1.2.1 ARy any flat wood 

paneling coating line within any facility whose actual emissions without oontrol devices 

from all flat wood paneling coating lines within the facility are less than 6.8 kilograms (kg) 

(15 pounds lib]) of volatile organic compounds (VOCs) per day. 

23.1.2.2 Class I Ramb"am paReliRg ~RisRes, paRisle b"ard "sed iR NrRil"re, iRs"lali"R 

998n:i1, exterier siefiR€I, tileeaarB, aAo settY/eea plyueeg seatiA§I !iRes. 

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

23.1.2.1 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 23.1.2.1 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 (CMA), 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. 

"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 (cm) (0.25 inch [in.]) in thickness); natural finish hardwood plywood panels; and 

hardwood paneling with Class II finishes. 

"Hardboard" is a panel manufactured primarily from inter-felted Iigno-cellulosic 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 em (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 has a colored, waterproof surface coating. 

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 

23.3.1.1111911911 23.3.1.2 ofthis regulation: 

T a ble 23-1. vac EmiSSion Limits f rom Flat wood Pane r Inn Coatlnos.

Flat Wood Panelino Product Catenorv 

vac Content Limits in Coatings. Inks. 

or Adhesives Beinn Aoolied 

Ib/qal q/L 

Printed interior panels made of hardwood. 

nlvwood or thin narticleboard 2.1­ 250

Natural finish hardwood nlvwood nanels 21 250 

Class II finishes on hardboard oanels 21 250 

Tileboard 

Exterior sidinn 

2.1 250 

2.1 250 

-This limit of 2.1 Iblgal is equivalent to 5.0 Ib vac per 1.000 tr' coating area. 

• 'lOG seAteRt Vall::l8S are 8*pFeSSea iR l::lRits at FRass at vae (kg. Ie) per area af 

s9alee! fiAisl1ee!IlFEle!IIs! (1 gg sqllaFEl melers (m2j, 1,ggg sqllare feel [ft2J) 

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	 (Reservee!j 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 reguirements of 8.0 of this regulation. 

23.5	 Control Devices 
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 

iesser of the value calculated according to the procedure in 23.6.2 of this 

regulation for that day or 95%. If the calculated efficiency is less than 90% use 

90% as the needed efficiency. 

23.5.1.4	 Demonstrating each day that the overall emission reduction efficiency achieved 

for that day, as determined in 5.0 of Appendix D of this regulation, is greater than 

or equal to the overall emission reduction efficiency fe€!wired 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 controi 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 D of this regulation, and the monitoring equipment is 

installed, calibrated, operated, and maintained according to the vendor's 

specifications at all times the control device is in use. 

23.6	 Test Methods and Efficiency of Control System 

23.6.1	 Test melRods. The test methods f9llflll specified in 23.6. of tRis feewlalioR aRd iR 

Appendix A, Appendix B and Appendix 0 of this regulation shall be used to determine 

compliance. 

23.6.2	 Overall emissisR fedwstisR effisieRsy fer ssRlfel systems. The required overall emission 

reduction efficiency of the control system for the day shall be calculated according to the 

following equation: 

E [(VOC. -S)lx100 

VQC.	 _ (23-1) 

where: 

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

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

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

coaling material applied), kfl \IQGl1gg m" af saales fiRisRes ~F8S~G1 (Ill '10GI 

1,g99 II'); as determined by the applicable test methods and procedures 

specified in Appendix B of this regulation, 

S =applicable vae emission limitation in Table 23-1 of this regulation in terms of !Q 

vaC/gal of coating material applied (or kg VaC/L of coating material applied) kfl 

VQCI1 gg m' af saates fiRisRes ~F8s~sl (Ill VOCl1 ,ggg ft'), 

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 vac emissions on any day from all flat wood 

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

23,1,2,..1. of this regulation, before the application of capture systems and control devices, 

shall comply with the following: 

23,7,1,1	 Certification, Ily ~lavemllar 15, 19QJ, Within six months after [insert the effective 

date of this revision of 23.01. the owner or operator of a facility rafereRs8s 

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 vac 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 vac emissions for that 

day: 

T= fe,D,a

,,' 

(23-2) 

where: 

T = Total vae 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 

VaC/day (Ib VaC/day). 

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

i = Subscript denoting an individual coating. 

C =Mass of vac per area of coated finished product in units of kg VaC/100 

m' (Ib VaC/1 ,000 ft'). 

D = The surface area coated at the facility each day in units of m'/day 

(ft'/day). 

a = Constant = 100 m' if using metric units. 

= 1,000 ft' if using English units. 

--_._. __._---------­
23.7.1.2	 Recordkeeping. On and after ~la"ameer 15, 1993 [insert the effective date of this 

revision of 23.01, the owner or operator of a facility rafereRsad specified in 23.7.1 

of this regulation shall collect and record all of the following information 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 VOC emissions at the facility, as calculated using the equation 

under 23.7.1.1.3 ofthis regulation. 

23.7.1.3	 Reporting. On and after Na'lamear 15, 1993 [insert the effective date of this 

revision of 23.01, the owner or operator of a facility referaRsad specified in 23.7.1 

of this regUlation shall notify the Department of any record showing that 

combined VOC 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. By ~la'lemeer 15,1993, Within six months after [insert the effective 

date of this revision of 23.01, 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 

refareRsed 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 Na'.'emeer 15, 1993, [insert the 

effective date of this revision of 23.01,. 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 VOC content of each coating TAe ma66 af VOC per area af saated 

fiRi6Aed preQ~st 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 VOG/L of coating material applied) kg VOCI1 gg m2 (Ill '/oC11 ,ggg fI2} 

and the volume of each coating (in terms of gal or Ll s~FlaGe aFea coated 

each day of each type of flat wood paneling product. 

23.7.2.2	 Recordkeeping. On and after Ng'JemlleF 15, 1993 [insert the effective date of this 

revision of 23.01, 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 VaG content of each coating TAS mass gf \lOC ",SF aFsa sf Gsales 

fiRisASS I'fss~Gl for each type of flat wood paneling product (specified in 

23.3.1 of this regUlation) in terms of Ib VaG/gal of coating material applied 

(or kg VOG/L of coating material applied) kg VQCI199 m2 (Ill VOCI1 ,999 fl2j 

and the volume of each coating (in terms of gal or Ll s~FlaGe aFsa coated 

each day of each type of flat wood paneling product. 

23.7.2.3	 Reporting. On and after ~lg'JemlleF 15, 1993 [insert the effective date of this 

revision of 23.01. 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-complying 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. Gode 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. By Ng'JemllsF 15, 1993, Within six months after 

[insert the effective date of this revision of 23.01, 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 0 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 No',ember 15, 1993, [insert the effective date of this 

revision of 23.01, or on and after the initial startup date. 

23.7.3.2	 Recordkeeping. On and after Nsvember 15, 1993 [insert the effective date of this 

revision of 23.01. 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 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 VOG content of each coating TAe mass ef VOG per area ef Gealed 

fiRi6Aed pred~GI for each type of flat wood paneling product (specified in 

23.3.1 of this regulation) in terms of Ib VOG/gal of coating material applied 

(or kg VOG/L of coating material applied) kg VOG!11111 m2 (Ib VOG!1 ,llllll ft:!) 

and the volume of each coating (in terms of gal or Ll s~rfaGe area coated 

each day of each type of flat wood paneling product. 

23.7.3.2.3	 The maximum VOG content of the coatings, as applied, used each day Q!l 

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

material appliedlma66 ef VOG per area ef Gsated fiRisAed preg~GI iR term6 sf 

kg VOG!111Q m211b VOG!1,QQll ft:!]) 

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

coating line as determined 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 determined in 3.0 of Appendix 0 of this regulation. 

23.7.3.2.6	 Gontrol 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 performed 

including dates and duration of any outages. 

23.7.3.2.9	 For thermal incinerators, all 3-hour periodS of operation in which the average 

combustion temperature was more than 28'G (50'F) below the average 

combustion temperature during the most recent performance test that 

demonstrated that the facility was in compliance. The combustion chamber 

set-point shall be no less than that during the most recent performance 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 28'G (50'F) below the average temperature of the 

process vent stream immediately before the catalyst bed during the most 

recent performance 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 Jess than that during the most recent 

performance test that demonstrated that the facility was in compliance. 

23.7.3.2.11 For camon adsomers, all three-hour periods of operation during which either 

the average voe 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 

recent determination of the recovery efficiency of the camon adsorber that 

demonstrated that the facility was in compliance. 

23.7.3.3	 Reporting. On and after ~Je'/e",i:ler Hi, 1gg~ [insert the effective date of this 

revision of 23.01, 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.