STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR RESOURCES 

AIR POLLUTION CONTROL REGULATION NO. 35 

CONTROL OF VOLATILE ORGANIC COMPOUNDS 

AND VOLATILE HAZARDOUS AIR POLLUTANTS 

FROM WOOD PRODUCT MANUFACTURING OPERATIONS 

Effective 7 March 1996 

Last Amended 19 July 2007 

AUTHORITY: These regulations are authorized pursuant to R.I. Gen. Laws § 42-

17.1-2(s) and 23-23, as amended, and have been promulgated pursuant to the 

procedures set forth in the R.I. Administrative Procedures Act, R.I. Gen. Laws Chapter 

42-35. 
RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR RESOURCES 

AIR POLLUTION CONTROL REGULATION NO. 35 

CONTROLOFVOLATILEORGANICCOMPOUNDSAND 

VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING 

OPERATIONS 

3 5 .1 Definitions ............................................................................................................................. 1 

35.2 Applicability .......................................................................................................................... 7 

35.3 Emission Limitations for Finishing Operations ......................................................................... 8 

Table 2. Emissions Limitations for Finishing Materials ................................................................ 9 

35.4 Emission Limitations for Cleaning and Gluing Operations ..................................................... .12 

35.S Work Practice Standards ....................................................................................................... 12 

35.6 Compliance Procedures and Monitoring Requirements ........................................................... 19 

3 5. 7 Recordkeeping and Reporting ................................................................................................ 26 

35.8 Performance Test Methods .................................................................................................... 32 

35.9 General Provisions ................................................................................................................ 35 

TABLE 1. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS ............................................ 38 

TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF 

SOL VENTS .................................................................................................................. 43 
RHODE ISLAND DEPARTMENT OF ENVIRONMENT AL MANAGEMENT 

OFFICE OF AIR RESOURCES 

AIR POLLUTION CONTROL REGULATION NO. 35 

CONTROL OF VOLATILE ORGANIC COMPOUNDS AND 

VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS 

MANUFACTURING OPERATIONS 

35.1 Definitions 

Unless otherwise expressly defined in this section, the terms used in this regulation shall 

be defined by reference to the Rhode Island Air Pollution Control General Definitions 

Regulation. As used in this regulation, the following terms shall, where the context 

permits, be construed as follows: 

35.1.1. "Adhesive" means a chemical substance that is applied for the purpose of 

bonding two surfaces together other than by mechanical means. 

35.l.2 "Alternative method" means a method of sampling and analyzing for an 

air pollutant that is not a reference or equivalent EPA sampling method but that 

has been demonstrated to the EP A's satisfaction to, in specific cases, produce 

results adequate for a determination of compliance. 

35.1.3. "As applied" means the VOC, VHAP and solids content of the coating 

material as it is used for coating the substrate, including the contribution of 

thinners. 

35 .1.4. "Basecoat" means a coat of colored material, usually opaque, that is 

applied before graining inks, glazing coats, or other opaque finishing materials 

and is usually topcoated for protection. 

35.1.5. "Capture device" means a hood, enclosed room, floor sweep, or other 

means of collecting solvent emissions or other pollutants into a duct so that 

pollutants can be directed to a pollution control device such as an incinerator or a 

carbon adsorber. 

35.1.6. "Capture efficiency" means the fraction of all organic vapors generated 

by a process that are directed to a control device. 

35.1.7. "Certified product data sheet" or "CPDS" means documentation 

furnished by a coating supplier or an outside laboratory that provides the VHAP 

content, voe content, solids content, and density of a finishing material, 

strippable booth coating, adhesive, or solvent, measured using EPA Methods 24 

and 311, or an equivalent or alternative method (or formulation data if the coating 

Page I of 45 
meets the criteria specified in Subsection 35.8.l(b)). The purpose of the CPDS is 

to assist the facility in demonstrating compliance with the emission limitations 

presented in Sections 35.3, 35.4 and 35.5 of this regulation. Therefore, the VOC 

and VHAP content should represent the maximwn VOC and VHAP emission 

potential of the finishing material, strippable booth coating, or solvent. 

35.1.8. "Cleaning operations" means operations in which organic solvent is used to 

remove coating materials from equipment used in wood products manufacturing 

operations. 

35.1.9. "Coating" means a protective, decorative, or functional material applied 

in a thin layer to a surface. Such materials include, but are not limited to, paints, 

topcoats, varnishes, sealers, stains, washcoats, basecoats, adhesives, inks, 

enamels, and temporary protective coatings. 

35.1.10 "Coating solids or solids" means the part of a coating that remains after the 

coating is dried or cured; solids content is determined using data from EPA 

Method 24. 

35.1.11 "Compliant coating" means a finishing material, adhesive, or strippable booth 

coating that meets applicable emission limitations specified in Section 35.3 and 

35.4 of this regulation. 

35.1.12 "Contact adhesive" means an adhesive that is applied to two substrates, dried, 

and mated under only enough pressure to result in good contact. The bond is 

immediate and sufficiently strong to hold pieces together without further 

clamping, pressure, or airing. 

35.1.13 "Continuous coater" means a finishing system that continuously applies 

finishing materials onto wood parts moving along a conveyor system. Finishing 

materials that are not transferred to the part are recycled to the finishing material 

reservoir. Several types of application methods can be used with a continuous 

coater including spraying, curtain coating, roll coating, dip coating, and flow 

coating. 

35.1.14. "Continuous compliance" means that the facility is meeting the applicable 

emission limitations and other applicable requirements of this regulation at all 

times and is fulfilling all monitoring and recordkeeping provisions of the 

regulation in order to demonstrate compliance. 

35.1.15. "Control device11 means any equipment that reduces the quantity of a pollutant 

that is emitted to the air. The device may destroy or secure the pollutant for 

subsequent recovery. Control devices include, but are not limited to, incinerators, 

carbon adsorbers, and condensers. 

35.1.16. "Control device efficiency" means the ratio of the amount of pollutant released 

Page 2 of 45 
by a control device to the amount of pollutant introduced to the control device, 

expressed as a fraction. 

35.1.17. "Control system" means the combination of capture and control devices used 

to reduce emissions to the atmosphere. 

35.1.18. "Conventional air spray" means a spray coating method in which the coating 

is atomized by mixing it with compressed air at an air pressure greater than 10 

pounds per square inch (gauge) at the point of atomization. Airless, air assisted 

airless, and electrostatic spray technologies are not considered conventional air 

spray methods. 

3 5 .1.19. "Day" means a period of 24 consecutive hours beginning at midnight local time, 

or beginning at a time consistent with a facility's operating schedule. 

35.1.20. "Disposed offsite" means sending used organic solvent or coatings outside of 

the facility boundaries for disposal. 

3 5 .1.21. "Emission" means the release or discharge, directly or indirectly, of one or 

more air pollutants into ambient air. 

35.1.22. "Enamel" means a coat of colored, usually opaque material that is applied as a 

protective topcoat over a basecoat, primer, or previously applied enamel coats. In 

some cases, another finishing material may be applied as a topcoat over the 

enamel. 

35.1.23 "Equipment leak" means emissions ofVOC or VHAP from pumps, valves, 

flanges, or other equipment used to transfer or apply finishing materials, 

adhesives, or organic solvents. 

35.1.24 "Equivalent method" means a method of sampling and analyzing for an air 

pollutant that EPA has determined to have a consistent and quantitatively known 

relationship to the reference method, under specific conditions. 

35.1.25 "Filler" means a finishing material which is applied to a wood surface primarily 

to build up, or fill the voids and imperfections in, the wood surface to be coated. 

Edge filler is included in this definition. 

35.1.26 "Finishing application station" means the part of a finishing operation where 

the finishing material is applied, e.g., a spray booth. 

35 .1.27 "Finishing material" means a coating other than an adhesive. For the wood 

products manufacturing industry, such materials include, but are not limited to, 

basecoats, stains, washcoats, enamels, sealers, and topcoats. 

35.1.28 "Finishing operation" means those activities in which a finishing material is 

Page 3 of45 
applied to a substrate and is subsequently air-dried, cured in an oven, or cured by 

radiation. 

35.1.29 "Foam adhesive" means a contact adhesive used for gluing foam to fabric, foam 

to foam, and fabric to wood. 

35.1.30 "Gluing operation" means those operations in which adhesives are used to join 

components, for example to apply a laminate to a wood substrate or foam to 

fabric. 

35.1.31 "High-solids stains" means stains containing more than one pound of solids per 

gallon and includes wiping stains, glazes, and opaque stains. 

35.1.32 "Incinerator" means an enclosed combustion device that thennally oxidizes 

volatile organic compounds to CO and C02. This tenn does not include devices 

that burn municipal or hazardous waste material. 

35.1.33 "Ink" means a fluid that contains dyes and/or colorants and is used to make 

markings, but" not to protect surfaces. 

35.1.34 "Low-solids stains" means stains containing one pound of solids per gallon, or 

less. 

35.1.35 "Major source of Hazardous Air Pollutants" means a facility that emits or has 

the potential to emit, in the aggregate, 10 tons per year (tpy) or more of any 

Hazardous Air Pollutant (HAP), 25 tpy or more of any combination of HAPs, or 

such lesser quantity as the EPA may establish by rule. 

35 .1.36 "Malfunction" means any sudden, infrequent, and not reasonably preventable 

failure of air pollution control equipment, process equipment, or a process to operate in a 

nonnal or usual manner. Failures that are caused in part by poor maintenance or careless 

operation are not malfunctions. 

35.1.37 "Multi-colored coating" means a coating which exhibits more than one color 

when applied, and which is packaged in a single container and applied as a single 

coat. 

35.1.38 "Nonpermanent final finish" means a material such as a wax, polish, 

nonoxidizing oil, or similar substance that must be periodically reapplied to a 

surface over its lifetime to maintain or restore the reapplied material's intended 

effect. 

35.1.39 "Operating day" means a day, or any part of a day, in which a facility is 

engaged in manufacturing. 

35.1.40 "Operating parameter value" means a minimum or maximum value 

Page 4 of 45 
established for a control device or process parameter that, if achieved by itself or 

in combination with one or more other operating parameter values, determines 

that an owner or operator has complied with an applicable emission limitation. 

35.1.41 ''Organic solvent" means a liquid containing VOC that is used for dissolving or 

dispersing constituents in a coating, adjusting the viscosity of a coating, cleaning, 

or washoff. When used in a coating, the organic solvent evaporates during drying 

and does not become a part of the dried film. 

35.1.42 "Overall control efficiency" means the efficiency of a control system, 

calculated as the product of the capture and control device efficiencies, expressed 

as a percentage. 

35.1.43 "Permanent total enclosure" means a permanently installed enclosure that 

completely surrounds a source of emissions such that all emissions are captured 

and contained for discharge through a control device. The enclosure must meet 

applicable EPA criieria. 

35.1.44 "Pigmented coating" means an opaque coating which contains binders and 

colored pigments and which is formulated to hide the wood surface, either as an 

undercoat or topcoat. 

35.1.45 "Recycled onsite" means the reuse of an organic solvent at the facility in a 

process other than cleaning or washoff. 

35.1.46 "Sealer" means a finishing material used to seal the pores or grains of a wood 

substrate before additional coats of finishing material are applied. W ashcoats, 

which are used in some finishing systems to optimize aesthetics, are not sealers. 

35.1.47 "Shutdown" means the cessation of operation of wood products manufacturing 

operations for any purpose. 

35.1.48 "Solvent" means a liquid used in a coating for dissolving or dispersing 

constituents in a coating, adjusting the viscosity of a coating, cleaning, or 

washoff. When used in a coating, it evaporates during drying and does not 

become a part of the dried film. 

35.1.49 "Stain" means any color coat having a solids content by weight of not more than 

8.0 percent that is applied in single or multiple coats directly. to the substrate. 

Stains include, but are not limited to, nongrain raising stains, equalizer stains, 

prestains, sap stains, body stains, no-wipe stains, penetrating stains, and toners. 

35.1.50 "Startup" means the setting in operation of wood products manufacturing 

operations for any purpose. . 

3 5 .1.51 "Strippable booth coating" means a coating that: (I) is applied to a booth wall 

Page 5 of 45 
to provide a protective film to receive overspray during finishing operations; (2) is 

subsequently peeled off and disposed; and (3) by achieving (1) and (2), reduces or 

eliminates the need to use organic solvents to clean booth walls. 

35.1.52 "Substrate" means the surface onto which coatings are applied or into which 

coatings are impregnated. 

35.1.53 "Thinner" means a volatile liquid that is used to dilute coatings to reduce 

viscosity, color strength, and solids, or to modify drying conditions. 

35.1.54 "Toner" means a stain which contains binders and dyes or pigments to add tint 

to a coated surface or to even the color of an initial application of stain. 

35.1.55 "Topcoat" means the last film-building finishing material applied in a finishing 

system. 

35. l .56 "Touch-up and repair" means the application of finishing materials to cover 

minor finishing imperfections. 

35.1.57 "Volatile Hazardous Air Pollutant" and 11VHAP" means any of the substances 

listed in Table 1. 

35.1.58 "Washcoat" means a transparent special purpose coating having a solids content 

by weight of 12.0 percent or less. Washcoats are applied over initial stains to 

protect and control uniformity of color, to stiffen the wood fibers, to prepare the 

wood surface for sanding, and to partially seal the wood from subsequent staining 

operations. 

35.1.59 "Washoff operations" means those operations in which organic solvent is used 

to remove coating from a substrate. 

35.1.60 "Wood products facility" means a facility which is engaged in coating the 

surface of products manufactured of wood or wood products, including, but not 

limited to, particle board, reed, rattan and wicker. Wood product coating does not 

include coating of flat wood panels, as defined in Air Pollution Control 

Regulation No. 19. 

35.1.61 "Wood products manufacturing operations" means the finishing, gluing, 

cleaning and wash off operations conducted at a wood products facility. 

Page 6 of 45 
35.2 Applicability 

35 .2.1 The provisions of this regulation apply to any wood products facility which has 

the potential to emit 25 tons per year or more of volatile organic compounds 

(VOC) from wood products manufacturing operations or which is located at a 

major source of Hazardous Air Pollutants (HAP). 

35.2.2 The owner or operator of a wood products facility which has emissions 

below the applicability thresholds specified in Subsection 3 5 .2.1 but above 15 

pounds of voe in any day shall comply with the record.keeping and reporting 

requirements in Paragraphs (a) and (c) of Subsection 35.7.1 but the facility shall 

not be subject to any other provisions of this regulation. If the facility becomes 

subject to the regulation at a future date due to an increase in emissions ofVOC 

or VHAP, the facility shall be subject to applicable requirements in this regulation 

on and after the date that the applicability thresholds are reached or the date that 

the applicable requirement becomes effective, whichever is later. 

35.2.3 Where ever the term Volatile Organic Compound or VOC is used in 

Seetioas 35.2 through 35.8 and Subseetioas 35.1.3, 35.1.7, 35.1.23, aad 35.l.4 l , 

this term shoa.Jel be read as Volatile Organic Compounel and Halogeaated Organic 

Compol:H'ld or VOG and HOC. 

35.2.4 The owner or operator of a facility which is a major source of Hazardous 

Air Pollutants (HAP) but which has not emitted more than 10 tons of any one 

HAP or more than 25 tons of any combination of l-IAP, including emissions from 

source categories other than wood products, in any 12 month period since 

December 1994 may apply to the Director for an exemption from the VHAP 

emissions limitations in Subsections 35.3.2, 35.3.3, 35.4.2 and 35.4.3 of this 

regulation. Exemption will be given in the form of an enforceable document, and 

will include the following conditions: 

(a) Average monthly emissions from the facility in any 

consecutive twelve month period shall not exceed 1,666 pounds of any 

one HAP or 4,166 pounds of any combination of HAP; and 

(b) The following records shall be maintained at the facility for 

a period of five years and made available to the Department or the EPA 

upon request: 

(1) The name, identification number, and amount of 

each finishing, gluing and washoff material used each month at the 

facility; and 

(2) Certified Product Data Sheets showing the VOC 

and VHAP content of each finishing, gluing, and washoff material 

used at the facility; and 

Page 7 of 45 
(3) The type and amount of solvent used as thinners 

and in cleaning operations each month at the facility; 

( 4) The average monthly emissions of each HAP from 

the facility, calculated monthly for the previous twelve month 

period. 

(c) If the limit in Paragraph 35.2.4.(a) is exceeded, applicable 

VHAP emission limitations specified in Sections 35.3 and 35.4 shall 

immediately apply. 

35.3 Emission Limitations for Finishing Operations 

35.3.l voe Emission Limitations for Finishing Operations 

(a) On and after March 7, 1996, the owner or operator of a 

facility subject to this regulation which has the potential to emit greater 

than or equal to 25 tons per year of volatile organic compounds (VOe) 

shall limit voe emissions from wood products finishing operations by: 

(1) Using finishing materials which comply with the 

emissions limitations in pounds ofVOe per gallon of coating 

minus water and exempt compounds listed in Table 2; or 

(2) Using a control system that achieves the emissions 

limitations in pounds of voe per pound of solids listed in Table 2; 

or 

(3) Using finishing materials with a weighted average 

voe content, within a particular category of coatings as identified 

in Table 2, which conforms with the provisions specified in 

Subsection 35.6.2(a); or 

(4) Using a combination of the methods presented in 

Paragraphs 35.3.l(a)(I), 35.3.l(a)(2), and 35.3.l(a)(3) which is 

approved by the Department. 

Page 8 of 45 
T a e bl 2 E . . rmss1ons L' 1m1tations . . f; or F" . bin M 'al llllS Lg a ten s 

COATING CATEGORY lbs VOCI lbs VOCI 

gal coating lb solids 

minus water 

and exempt 

compounds 

clear topcoats containing HOC 4.6 1.2 

clear topcoats not containing HOC 5.7 2.5 

fillers 4.2 1.0 

high-solids stains 5.8 2.7 

low-solids stains, toners and 4.0 0.9 

washcoats containing HOC 

low-solids stains, toners and 6.7 7.5 

washcoats not containing HOC 

inks 4.2 1.0 

multi-colored coatings 5.7 2.5 

pigmented coatings 5.0 1.6 

sealers containing HOC 4.6 1.2 

sealers not containing HOC 5.7 2.5 

(b) In addition to complying with the limitations in Table 2, on 

and after March 7, 1998, the owner or operator of a facility subject to this 

regulation which has the potential to emit greater than or equal to 25 tons 

per year ofVOC shall: 

(I) Use topcoats containing no more than 1.8 lbs 

VOC/lb solids, as applied, and sealers containing no more than 1.9 

lbs VOC/lb solids, as applied; or 

(2) Use waterborne topcoats with a VOC content no 

greater than 0.8 lb VOC/lb solids, as applied; or 

(3) Use a control system that achieves equivalent 

reductions in voe emissions from topcoats and sealers. 

(c) A facility subject to the emissions limits in Table 2 may be 

required, at the discretion of the Department, to undergo a review every 

two years to determine whether the limitations in Paragraphs (a) and (b) of 

Page 9 of 45 
this subsection represent Reasonably Available Control Technology 

(RACT) for the finishing operations at that facility at that time. Facilities 

shall comply with emissions limitations determined to be RACT within 

one year of that determination and shall thereafter operate in compliance 

with those limitations. 

35.3.2 VHAP Emission Limitations for Finishing Operations at Existing Facilities 

(a) On and after March 7, 1998, the owner or operator of a 

facility subject to this regulation which is a major source of HAP and 

which began operations before December 6, 1994 shall limit VHAP 

emissions from wood products finishing operations by: 

(1) Using stains, washcoats, sealers, topcoats, 

basecoats, and enamels with VHAP contents no higher than 1.0 lb 

VHAP/lb solids, as applied; thinners for stains, sealers, and 

topcoats that contain no more than 10% VHAP by weight; and 

thinners for washcoats, basecoats and enamels that contain no 

more than 3% VHAP by weight; or 

(2) Using finishing materials with a weighted average 

VHAP content of no greater than 1.0 lb VHAP/lb solids, as 

applied, calculated using the procedures in Subsection 35.6.2(b), 

and thinners with VHAP contents as specified in Paragraph 

35.3.2(a)(l); or 

(3) Using a control system that achieves a reduction in 

emissions equivalent to that which would be achieved by 

complying with the requirements of Paragraph (1) or (2) of this 

subsection, calculated according to the procedures in Subsection 

35.6.3(c) of this regulation; or 

(4) Using a combination of the methods presented in 

Paragraphs (1) and (3) of this subsection which is approved by the 

Department. 

(b) The formaldehyde content of a finishing material shall be 

calculated as the amount of free formaldehyde present in the finishing 

material when it is applied. 

( c) The styrene content of a finishing material shall be based 

on an estimate of unreacted styrene, which shall be calculated by 

multiplying the amount of styrene monomer in the finishing material when 

it is applied by a factor of 0.16. 

Page 10 of 45 
35.3.3 VHAP Emission Limitations for Finishing Operations at New Facilities 

(a) On and after March 7, 1996, the owner or operator of a 

facility subject to this regulation which is a major source of HAP and 

began operation on or after December 6, 1994 shall limit VHAP emissions 

from wood products finishing operations by: 

( 1) Using stains with VHAP contents no greater than 

1.0 lb VHAP/lb solids, as applied; washcoats, sealers, topcoats, 

basecoats, and enamels with VHAP contents no greater than 0.8 lb 

VHAP/lb solids, as applied; thinners for stains, sealers, and 

topcoats that contain no more than 10% VHAP by weight; and 

thiJiJ.Ders for washcoats, basecoats and enamels that contain no 

more than 3% VHAP by weight; or 

(2) Using finishing materials with a weighted average 

VHAP content of no greater than 0.8 lb VHAP/lb solids, as 

applied, calculated using the procedures in Subsection 35.6.2(b), 

and thinners with VHAP contents as specified in Paragraph 

35.3.3(a)(l); or 

(3) Using a control system that achieves a reduction in 

emissions equivalent to that which would be achieved by 

complying with the requirements of Paragraph (1) or (2) of this 

subsection, calculated according to the procedures in provisions in 

Subsection 35.6.3(c) of this regulation; or 

(4) Using a combination of the methods presented in 

Paragraphs (1) and (3) of this subsection which is approved by the 

Department. 

(b) The formaldehyde content of a finishing material shall be 

calculated as the amount of free formaldehyde present in the finishing 

material when it is applied. 

( c) The styrene content of a finishing material shall be based 

on an estimate of unreacted styrene, which shall be calculated by 

multiplying the amount of styrene monomer in the finishing material when 

it is applied by a factor of 0 .16. 

Page 11 of45 
35.4 Emission Limitations for Cleaning and Gluing Operations 

35.4.1 VOC Emission Limitations for Cleaning Operations 

On and after March 7, 1996, any strippable booth coating used at a facility subject to this 

regulation must contain no more than 0.8 lb VOC/lb solids, as applied. 

35.4.2 VHAP Emission Limitations for Existing Gluing Operations 

On and after March 7, 1996, the owner or operator of a facility subject to this regulation 

which is a major source of HAP and which began operation before December 6, 1994 

shall limit VHAP emissions from contact adhesives used in gluing operations as follows: 

(a) For foam adhesives used in products that meet the 

upholstered seating flammability requirements of California Technical 

Bulletin 116, 117, or 133, the Business and Institutional Furniture 

Manufacturers Association's (BIFMA's) X5.7, UFAC flammability testing, 

or·any similar requirements from local, State, or Federal fire regulatory 

agencies, the VHAP content of the adhesive shall not exceed 1.8 lb 

VHAP/lb solids, as applied; 

(b) For all other contact adhesives, including foam adhesives 

used in products that do not meet the standards presented in Paragraph (a) 

of this subsection, the VHAP content of the adhesive shall not exceed 

1.0 lb VHAP/lb solids, as applied; or 

( c) By using a control system that will achieve a reduction in 

VHAP emissions equivalent to that which would be achieved by 

complying with the requirements of Paragraph (b) of this subsection, as 

calculated using the procedures in Subsection 35.6.3(d) of this regulation. 

35.4.3 VHAP Emission Limitations for New Gluing Operations 

On and after March 7, 1996, the owner or operator of a facility subject to this regulation 

which is a major source of HAP and which began operation on or after December 6, 1994 

shall not use contact adhesives which have VHAP contents higher than 0.2 lb VHAP/lb 

solids, as applied or shall use a control system that achieves an equivalent reduction in 

emissions ofVHAP, as calculated using the procedures in Subsection 35.6.3(d). 

35.5 Work Practice Standards 

The owner or operator of a facility subject to this regulation shall implement the 

following work practice standards by March 7, 1996, except where another date is 

specified. 

Page 12 of45 
35.5.1 Work Practice Implementation Plan 

(a) The owner or operator of a facility subject to this regulation 

shall prepare and maintain a written work practice implementation plan 

that defines work practices for each wood products manufacturing 

operation and addresses each of the topics specified in Subsections 35.5.2 

through 35.5.10. 

(b) The work practice implementation plan shall be developed 

by May 6, 1996 and shall be subject to the approval of the Department. 

( c) The owner or operator of the facility shall comply with 

each provision of the work practice implementation plan. 

( d) The work practice implementation plan shall be available 

for inspection by the EPA or the Department upon request and shall be 

modified by the facility if found to be inadequate. 

35.5.2 Operator Training Course 

(a) Each owner or operator of a facility subject to this 

regulation shall train all new and existing personnel, including contract 

personnel, who are involved in finishing, gluing, cleaning, or washoff 

operations, use of manufacturing equipment, or implementation of the 

requirements of this regulation. 

(b) All personnel shall be trained by November 6, 1996, or 

upon hiring, whichever is later. All personnel shall be given refresher 

training annually. 

( c) Initial and refresher trainings shall include, at a minimum, 

the following topics: 

(1) Appropriate application techniques; 

(2) Appropriate cleaning and washoff procedures; 

(3) Appropriate equipment setup and adjustment to 

minimize finishing material usage and overspray; and 

( 4) Appropriate management of cleanup wastes. 

( d) The facility shall maintain records of the training program. 

Records shall include, at a minimum, the following: 

(1) A list of all current personnef by name and job 

Page 13 of 45 
description who are required to be trained and a record of the date 

that each employee was trained; 

(2) An outline of the subjects covered in the initial and 

refresher training for each position, or group of personnel; 

(3) Lesson plans for courses to be given at the initial 

and the annual refresher training that include, at a minimum, the 

topics specified in Paragraph (c) of this subsection; and 

( 4) A description of the methods to be used to 

demonstrate successful completion of initial and refresher training. 

35.5.3 Equipment Operation, Maintenance, Inspection and Repair 

(a) Equipment Leak Inspection and Repair 

( 1) After March 6, 1996, all equipment used to transfer 

or apply finishing materials, adhesives, or organic solvents shall be 

visually inspected for leaks at least once per month. 

(2) A first attempt at repair shall be made no later than 

3 calendar days after a leak is detected and final repairs shall be 

made within 10 calendar days, unless the leaking equipment is to 

be replaced by a new purchase, in which case repairs shall be 

completed within 3 months. 

(3) Each owner or operator of a source subject to this 

regulation shall prepare and maintain a written leak inspection and 

maintenance plan that includes: 

(i) A schedule for conducting visual inspections 

required in Paragraph (a) of this subsection; and 

(ii) A log documenting the date and results of 

each inspection and any repairs that are made. 

(b) Operation and Maintenance Requirements 

(1) At all times, including periods of startup, shutdown, 

and malfunction, owners or operators shall operate and maintain 

any equipment associated with wood products manufacturing 

operations, including associated air pollution control equipment, in 

a manner consistent with good air pollution control practices for 

minimizing emissions. 

Page 14 of 45 
(2) Malfunctions shall be corrected as soon as 

practicable after their occurrence in accordance with the startup, 

shutdown, and malfunction plan required in Paragraph (b)(4) of 

this subsection. 

(3) The Department wiU determine whether acceptable 

operation and maintenance procedures are being used, based on 

information which may include, but is not limited to, monitoring 

results, review of operation and maintenance procedures (including 

the startup, shutdown, and malfunction plan required in 

Paragraph (b)(4) of this subsection), review of operation and 

maintenance records, and inspection of the facility. 

(4) The owner or operator of a facility subject to this 

regulation shall develop and implement a written startup, 

shutdown, and malfunction plan that describes, in detail, 

procedures for operating and maintaining equipment associated 

with wood products manufacturing operations during periods of 

startup, shutdown, and malfunction and a program of corrective 

action for malfunctioning process and air pollution control 

equipment used to comply with this regulation. The facility's 

standard operating procedures (SOP) manual, an Occupational 

Safety and Health Administration (OSHA) or another plan can be 

used to fulfill this requirement, provided the plan meets all the 

requirements of this 

paragraph. Startup, shutdown, and malfunction 

plans shall be maintained at the facility and made available to the 

Department or the EPA for review upon request and shall be 

revised if determined to be unacceptable. 

(5) During periods of startup, shutdown, and 

malfunction, the owner or operator of a facility subject to this 

regulation shall operate and maintain equipment associated with 

wood products manufacturing operations (including associated air 

pollution control equipment) in accordanc~ with the procedures 

specified in the startup, shutdown, and malfunction plan developed 

according to the provisions of Paragraph (b)(4) of this subsection. 

(6) The owner or operator of a facility subject to this 

regulation shall keep records of action taken during startups, 

shutdowns, and malfunctions, including actions taken to correct 

malfunctions and shall certify, in the semi-annual reports required 

in Subsection 35.7.7, that all such actions were consistent with the 

procedures specified in the facility's startup, shutdown and 

malfunction plan developed under Paragraph (b )( 4) of this 

Page 15 of45 
subsection 

(7) If actions taken by the owner or operator during a 

startup, shutdown, or malfunction (including an action taken to 

correct a malfunction) are not consistent with the procedures 

specified in the facility's startup, shutdown, and malfunction plan, 

the owner or operator shall record the actions taken and report such 

actions to the Office of Air Resources within 2 working days after 

beginning actions inconsistent with the plan, followed by a letter 

within 7 working days after the end of the event. 

(8) If a malfunction occurs that was not adequately 

addressed in the startup, shutdown, and malfunction plan, the 

owner or operator shall revise the plan within 45 days after the 

event to include detailed procedures for operating and maintaining 

the source during similar malfunction events and a program of 

corrective action for similar malfunctions of process or air 

pollution control equipment. 

35.5.4 Cleaning and Washoff Solvent Requirements 

(a) The owner or operator of a facility subject to this regulation 

shall account for organic solvent use in cleaning and washoff operations 

by recording the following information: 

(1) The quantity and types of organic solvent used in 

washoff and cleaning operations each month; 

(2) The number of pieces washed off, and the reason 

for the washoff; and 

(3) The quantity of spent organic solvent generated 

from each washoff and cleaning activity each month, and whether 

it is recycled onsite or disposed offsite. 

(b) Facilities subject to this regulation shall not use cleaning or 

washoff solvents that contain any of the pollutants listed in Table 3 in 

concentrations greater than 0.1 %. 

Page 16 of45 
35.5.5 Spray Booth Cleaning 

Facilities subject to this regulation shall not use compounds.containing more than 

8.0 percent by weight of voe for cleaning spray booth components other than 

conveyors, continuous coaters and their enclosures, or metal filters, unless the spray 

booth is being refurbished. If the spray booth is being refurbished, that is, the spray 

booth coating or other material used to cover the booth is being replaced, the facility shall 

use no more than 1.0 gallon of organic solvent per booth to prepare the booth prior to 

applying the booth coating. 

35.5.6 Storage Requirements 

All finishing, gluing, cleaning, and washoff materials shall be stored in containers that are 

closed at all times except when material is being added or removed. 

35.5.7 Application Equipment Requirements 

Conventional air spray guns shall not be used to apply finishing materials, except in the 

following situations: 

(a) When applying finishing materials before March 6, 1998 at 

a facility which is not a major source of HAP or which began operation 

prior to December 6, 1994; 

(b) When applying finishing materials that have a VOC content 

no greater than 1.0 lb VOC/lb solids, as applied; 

( c) Touch-up or repair that occurs after the completion of a 

finishing operation; 

(d) Touch-up or repair that occurs after the stain and before 

any other type of finishing material is applied, provided that the touch-up 

finishing materials are applied from a container that has a volume of no 

more than 2.0 gallons; 

(e) If the spray gun is aimed and triggered automatically, not manually; 

( f) If emissions from the finishing application station are 

directed to a control device; 

(g) For application of a finishing material if the total usage of 

that finishing material is no more than 5.0 percent of the total gallons of 

all finishing materials used at that facility during that semi-annual 

reporting period, as specified in Subsection 35.7.7(a).; or 

(h) The application of stain on a part for which it is technically 

Page 17 of45 
or economically infeasible to use any other spray application technology. 

The facility must demonstrate teclmical or economic infeasibility by 

submitting documentation to the Department that the following criteria, 

either independently or in combination, are met: 

35.5.8 Line Cleaning 

(1) The production speed is too high or the part shape is 

too complex for one operator to coat the part and the application 

station is not large enough to accommodate an additional operator; 

or 

(2) The excessively large vertical spray area of the part 

makes it difficult to avoid sagging or runs in the stain. 

All organic solvent used for line cleaning shall be pumped or drained into a container that 

is closed at all times except when material is being added or removed. 

35.5.9 Gun Cleaning 

All organic solvent used to clean spray guns shall be collected in a container that is 

closed at all times except when material is being added or removed. 

35.5.10 Washoff operations 

Emissions from washoff operations shall be controlled by: 

(a) Using tanks for washoff that are closed at all times except 

when material is being added or removed; and 

(b) Minimizing dripping by tilting or rotating the part to drain 

as much organic solvent as possible. 

35.5.11 Formulation Assessment Plan 

Each owner or operator of a facility that is subject to this regulation and that is a major 

source of Hazardous Air Pollutants shall prepare and maintain a formulation assessment 

plan that: 

(a) Lists all VHAP from Table 1 that are being used in 

finishing operations at the facility. 

(b) Establishes a baseline level of usage by the facility for each 

VHAP as follows: 

( 1) The baseline usage level shall be the annual usage 

Page 18 of 45 
from the calendar year 1994 for each VHAP; 

(2) For formaldehyde, the baseline level of usage shall 

be based on the amount of free formaldehyde present in the 

finishing material when it is applied; 

(3) For styrene, the baseline level of usage shall be an 

estimate of unreacted styrene, which shall be calculated by 

multiplying the amount of styrene monomer in the finishing 

material when it is applied by a factor of0.16; and 

(4) Facilities using a control device to reduce emissions 

may adjust their baseline usage based on the overall control 

efficiency of the control system, calculated using Equation 5 in 

Paragraph 35.6.3(c). 

(5) The baseline levels for a VHAP that was not used in 

1994 shall be established as 20% of the Reportable Quantity for 

that substance specified in Table III of Regulation No. 22. 

(c) Tracks the annual usage of each VHAP used by the facility. 

( d) If, beginning with the calendar year 1998, the usage of a 

VHAP in any year exceeds its baseline level, then the owner or operator of 

the facility shall provide a written notification to the Division by 31 

January of the following year that specifies the amount of the increase and 

explains the reasons for the increase. The Department will determine 

whether the increase would cause an exceedance of the Acceptable 

Ambient Levels specified in Air Pollution Control Regulation No. 22. If 

Regulation No. 22 limits are exceeded, the Department will develop a 

timetable for the facility to achieve compliance and a schedule for 

submitting notification of progress. 

35.6 Compliance Procedures and Monitoring Requirements 

35.6. l Compliance Using Compliant Coatings 

Compliance with the emissions limitations in Sections 35.3 and 35.4 of this regulation 

through the use of compliant coatings shall be demonstrated by the following methods: 

(a) Maintaining Certified Product Data Sheets (CPDS) 

documenting that the VOC and/or VHAP content of each topcoat, filler, 

stain, toner, ink, multi-colored coating, pigmented coating, sealer, 

washcoat, enamel, basecoat, thinner, adhesive and strippable booth coating 

meets the applicable emissions limitations in Sections 35.3 and 35.4 in lb 

Page 19 of 45 
VOC/gallon of coating or lb VHAP/lb of solids; and 

(b) Maintaining formulation data and related calculations 

showing that the VOC and VHAP content of each topcoat, filler, stain, 

toner, ink, multi-colored coating, sealer, washcoat, enamel, basecoat, 

adhesive and strippable booth coating diluted onsite, as applied, meets the 

applicable emissions limitations in Sections 35.3 and 35.4 in lb 

VOC/gallon of coating or lb VHAP/lb of solids; and 

(c) For facilities with continuous coaters, using one of the 

following procedures: 

(1) Calculating the VOC and VHAP content, as 

applicable, of the finishing material in the reservoir from 

information on the CPDS and records of materials added to the 

reservoir; or 

(2) Monitoring the viscosity of the finishing material in 

the reservoir with a viscosity meter or testing the viscosity of the 

initial finishing material and retesting the material in the reservoir 

each time solvent is added. If this option is chosen, the facility 

shall maintain data that demonstrates the correlation between the 

viscosity of the finishing material and the VOC and VHAP 

content, as applicable, of the finishing material; and 

( d) The Department or EPA will determine compliance either 

by reviewing the records specified in Paragraphs (a), (b) and (c) of this 

subsection or by conducting a performance test according to the 

specifications in Subsections 35.8.l and 35.8.2. If the VOC or VHAP 

content of a coating determined by a performance test using the 

procedures specified in Subsections 35.8.1 and 35.8.2 is greater than that 

indicated on a CPDS or by the facility's formulation or viscosity data, the 

performance test results shall govern. 

35.6.2 Compliance Using Averaging 

(a) To demonstrate compliance with the VOC emission 

limitations in Subsection 3 5. 3 .1 for a particular coating category through 

the use of averaging, the owner or operator of a facility shall, each week: 

(1) Calculate the average VOC content for all coatings in that category used 

at the facility using Equation 1: 

n n 

Evoc= (L ViCi) I L Vi Equation 1 

i=I i=I 

Page20 of45 
Where:Evoc = the average VOC content of coatings in a particular coating 

category, in lb VOC/gal coating, as applied; 

c = the voe content of a coating in the coating category, in lb 

VOC/gal coating minus water and exempt compounds, as applied; 

i = subscript denoting an individual coating; 

V = the volume of coating, in gallons, as applied, of a particular 

coating in the coating category used during the weekly averaging 

period; 

(2) Demonstrate that the value calculated for Evoc is no 

greater than 0.9 times the emission limitation, in lbs VOC/gallon 

coating minus water and exempt compounds, as applied, for that 

coating category, as listed in Table 2. 

(b) To demonstrate compliance with the VHAP emission 

limitations in Subsections 35.3.2 and 35.3.3 through the use of averaging, 

the owner or operator of a facility shall, each month: 

(1) Calculate the average VHAP content for all 

finishing materials used at the facility using Equation 2: 

n n n 

Equation 2 

i=l i=l i=l 

Where:EVHAP = the average VHAP content of finishing materials, in lb VHAP/lb 

solids; 

C =the VHAP content of a coating, in lb VHAP/lb solids, as 

applied; 

i = subscript denoting an individual coating; 

M = the mass of solids, in pounds, in a particular finishing 

material used during the monthly averaging period; 

S = the VHAP content of a solvent, expressed as a weight 

fraction, added to finishing materials; and 

W = the amount of solvent, in pounds, added to finishing 

Page21 of45 
materials during the monthly averaging period. 

(2) Demonstrate that the value calculated for EvHAP is 

no greater than 1.0 if the facility is complying with Subsection 

35.3.2 and is no greater than 0.8 if the facility is complying with 

Subsection 35.3.3. 

35.6.3 Initial Compliance Using Control Equipment 

(a) The owner or operator of a facility which uses control 

equipment to comply with the VOC emission limitations in Table 2 or the 

VHAP limitations in Subsections 35.3.3 and/or 35.4.3 shall conduct an 

initial performance test to measure the capture and control efficiency of 

the control system using the procedures specified in Subsection 35.8.3 by 

June 4, 1996. Initial performance tests for control equipment which is 

being used to comply with the VHAP emission limitations in Subsections 

35.3.2 andior 35.4.2 or the voe emissions limitations for sealers and clear 

topcoats in Paragraph 35.3.l(b) shall be conducted by September 8, 1998. 

(b) Initial compliance with VOC emission limitations for 

finishing materials through the use of a control system shall be determined 

as follows: 

(1) Calculate the overall control efficiency needed (Rn) 

for each finishing material which will be controlled by the control 

equipment using the following equation: 

Rn= [(C - EL)/C](lOO) Equation 3 

Where: Rn = the overall efficiency of the control system needed, expressed as a 

percentage. 

C = the VOC content of a coating, in lb VOC/lb solids, as applied; 

EL = the emission limitation required for the coating, from Table 

2, in lb VOC/lb solids. 

(2) Document that the value of C used in Equatfon 3 

was calculated from the voe and solids content of the as-applied 

finishing material. 

(3) Demonstrate, for all applicable coatings, that the 

value of Rn calculated using Equation 3 is less than or equal to the 

actual overall control efficiency (Ra) calculated by substituting the 

capture efficiency (N) and control efficiency (F) of the control 

system measured in the initial performance test into Equation 4. 

Page 22 of 45 
Ra = (F x N)(IOO) Equation 4 

( c) Initial compliance with VHAP emission limitations for 

finishing materials through the use of a control system shall be determined 

as follows: 

( 1) Calculate the overall control efficiency needed, Rn, 

so that the value ofEae in Equation 5 is no greater than 1.0 if 

complying with Subsection 35.3.2 and so that the value ofEae in 

Equation 5 is no greater than 0.8 if complying with Subsection 

35.3.3; 

Rn= (1 OO)(Ebe - Eae)/fac Equation 5 

Where: Rn = the overall efficiency of the control system needed, expressed as 

a percentage; 

Eac = emissions from an emission point or a set of emission points 

after control equipment is in operation, in lb VHAP/lb solids; and 

Ebe = emissions from an emission point or set of emission points 

before controls, calculated as EVHAP in Equation 2. 

(2) Demonstrate that the value of Rn calculated using 

Equation 5 is less than or equal to the actual overall control 

efficiency (Ra) calculated using the capture efficiency (N) and 

control efficiency (F) of the control system measured in the initial 

performance test and Equation 4. 

( d) Initial compliance with VHAP emission limitations for 

gluing materials through the use of a control system shall be determined as 

follows: 

(1) Calculate the overall control efficiency of the 

control system needed (Rn) so that the value of Gae in Equation 6 is 

no greater than 1.0 if complying with Subsection 35.4.2 and 0.2 if 

complying with Subsection 35.4.3; 

Rn = (1 OO)(Gbe - Gac)/Gbe) Equation 6 

Where:Rn = the overall efficiency of the control system needed, expressed as 

a percentage; 

Gae = emissions from the gluing operation after control equipment, 

in lb VHAP/lb solids; and 

Page 23 of45 
Gbc = emissions from the gluing operation before controls, in lb 

VHAP/lb solids. 

(2) Demonstrate that the value of Rn calculated using 

Equation 6 is less than or equal to the actual overall control 

efficiency (Ra) calculated using the capture efficiency (N) and 

control efficiency (F) of the control system measured in the initial 

performance test and Equation 4. 

35.6.4 Continuous Compliance Using Control Equipment 

(a) The owners or operator of a facility that is complying with 

the emission limitations in this regulation through the use of a control 

system shall demonstrate continuous compliance by installing, calibrating, 

maintaining, and operating appropriate monitoring equipment according to 

manufacturers' specifications. 

(b) The monitoring equipment installed pursuant to Paragraph 

(a) ofthis subsection shall measure operating parameters which indicate 

ongoing compliance with the control efficiency requirements in this 

regulation. 

( c) Where a thermal incinerator is used, the operating 

parameter to be monitored shall be minimum combustion temperature, and 

a temperature monitoring device equipped with a continuous recorder 

shall be installed in the firebox or in the ductwork immediately 

downstream of the firebox in a position before any substantial heat 

exchange occurs. 

( d) Where a catalytic incinerator equipped with a fixed catalyst 

bed is used, the operating parameter to be monitored shall be the minimum 

gas temperature upstream and downstream of the catalyst bed and 

temperature monitoring devices equipped with continuous recorders shall 

be installed in the gas stream immediately before and after the catalyst 

bed. 

( e) Where a catalytic incinerator equipped with a fluidized 

catalyst bed is used, the operating parameters to be monitored shall be the 

minimum gas temperature upstream of the catalyst bed and the pressure 

drop across the catalyst bed, and temperature monitoring devices equipped 

with continuous recorders shall be installed in the gas stream immediately 

before the bed. In addition, a pressure monitoring device shall be installed 

to determine the pressure drop across the catalyst bed. A constant 

pressure drop, as measured monthly at a constant flow rate, shall be 

maintained. 

Page 24 of45 
(t) Where a carbon adsorber is used, the operating parameters 

to be monitored shall be either the total regeneration mass stream flow for 

each regeneration cycle and the carbon bed temperature after each 

regeneration, or the concentration level of organic compounds exiting the 

adsorber, unless the owner or operator requests and receives approval 

from the Department and the EPA to establish other operating parameters. 

One of the following devices is required to monitor these parameters: 

(1) An integrating regeneration stream flow monitoring 

device having an accuracy of ±10 percent, capable of recording the 

total regeneration stream mass flow for each regeneration cycle; 

and a carbon bed temperature monitoring device having an 

accuracy of ±1 percent of the temperature being monitored 

expressed in degrees Celsius or ±0.5° C, whichever is greater, 

capable of recording the carbon bed temperature after each 

regeneration and within 15 minutes of completing any cooling 

cycle; 

(2) An organic monitoring device, equipped with a 

continuous recorder, to indicate the concentration level of organic 

compounds exiting the carbon adsorber; or 

(3) Another monitoring device that has been approved 

by the Department and the EPA. 

(g) A facility using a control device not listed in this section to 

comply with this regulation shall submit to the Office of Air Resources a 

description of the device, test data verifying the performance of the 

device, and appropriate operating parameter values that will be monitored 

to demonstrate continuous compliance with the standard. Compliance 

using this device is subject to the approval of the Department and the 

EPA. 

(h) Operating parameter values indicating compliance shall be 

calculated as the arithmetic average of the maximum or minimum value of 

those parameters, as appropriate, measured during the three test runs of the 

initial performance test, provided that the initial performance test 

demonstrated compliance. 

(i) The capture or control device shall be operated so that the 

average of all values for a monitored parameter recorded during each 

operating day is in compliance with the operating parameter value 

calculated according to the procedures in Paragraph (h) of this subsection. 

Page 25 of45 
35. 7 Recordkeeping and Reporting 

3 5. 7 .1 The owner or operator of a facility subject to this regulation shall maintain 

the following records for a period of five years: 

(a) A certified product data sheet (CPDS) for each finishing 

material, thinner, adhesive, and strippable booth coating subject to the 

emission limitations in this regulation; 

(b) As applicable, the voe content in lb voe/gallon of 

coating, as applied and the VHAP content, in lb VHAP/lb of solids, as 

applied, of each coating subject to the emission limitations in this 

regulation, and copies of calculations docwnenting how the as-applied 

values were determined. The voe content of strippable booth coatings 

shall be expressed in units oflb VOC/lb solids, as applied. 

( c) The amount and type of each coating and thinner used at 

the facility each month. 

(d) If viscosity measurements are used to track voe and/or 

VHAP concentrations: 

(1) Records of dates and amounts of solvent and 

· finishing material added to the continuous coater reservoir; 

(2) Records of dates and results of viscosity measurements; and 

(3) Data demonstrating that viscosity is an appropriate 

parameter for demonstrating compliance. 

35.7.2 The owner or operator of a facility using weekly averaging to comply with 

the VOC emissions limitations in Subsection 35.3. l or monthly averaging to 

comply with the VHAP emissions limitations in Subsection 35.3.2 or 35.2.3 shall 

maintain the calculations ofEvoc and EvttAP required in Subsection 35.6.2 for a 

period of 5 years. 

35.7.3 The owner or operator of a source using control equipment to comply with 

the emissions limitations in this regulation shall maintain the following records 

for a period of five years: 

(a) Copies of calculations ofEVHAP from Equation 2 and Rn 

from Equation 3, 5 and 6, as applicable; 

(b) Records of the daily average value of each continuously 

monitored operating parameter for each operating day. If all recorded 

values for a monitored parameter during an operating day are within the 

Page26of45 
range established during the initial performance test, the owner or operator 

may record that all values were within the range rather than calculating 

and recording an average for that day; and 

( c) Records of the pressure drop across the catalyst bed for 

facilities complying with the emission limitations using a catalytic 

incinerator with a fluidized catalyst bed. 

35.7.4 The owner or operator of a facility subject to this regulation shall maintain 

onsite the work practice implementation plan and for five years shall maintain 

onsite all records associated with fulfilling the requirements of that plan, as 

specified in Section 35.5, including, but not limited to: 

(a) Records demonstrating that the operator training program is in place; 

(b) Records maintained in accordance with the equipment leak 

inspection and maintenance plan and startup, shutdown, and malfunction 

plan; 

( c) Records associated with the cleaning solvent accounting system; 

( d) Records associated with the limitation on the use of 

conventional air spray guns showing total finishing material usage and the 

percentage of finishing materials applied with conventional air spray guns 

for each reporting period; 

( e) Records associated with the formulation assessment plan; 

(f) Records showing the VOC content of compounds used for 

cleaning booth components, except for solvent used to clean conveyors, 

continuous coaters and their enclosures, and/or metal filters; 

(g) A copy of logs and other documentation developed to 

demonstrate that the provisions of the work practice implementation plan 

?Te followed; and 

(h) A copy of the compliance certifications, and periodic 

reports submitted in accordance with the requirements of this regulation. 

35.7.5 Initial Notifications 

(a) The owner or operator of a facility subject to this regulation 

which was constructed before December 7, 1995 and which is a major 

source of HAP shall submit a Initial Notification to the Division by 

September 2, 1996 or within 30 days of becoming a major source of HAP, 

whichever is later. Initial Notifications for facilities constructed before 

Page 27 of 45 
December 7, 1995 shall include the following information: 

( 1) The name and address of the owner or operator; 

(2) The address (i.e., physical location) of the facility; 

(3) An identification of the relevant standard, or other 

requirement, that is the basis of the notification and the facility's 

compliance date; 

( 4) A brief description of the nature, size, design, and 

method of operation of the facility, including its operating design 

capacity and an identification of each point of emission for each 

HAP, or, if a definitive identification is not yet possible, a 

preliminary identification of each point of emission for each HAP; 

(5) An estimate of the amount of each HAP used and 

emitted annually from the facility; and 

( 6) The number of hours per day and days per week 

that the facility operates. 

(b) The owner or operator of a facility subject to this regulation 

which was constructed or reconstructed on or after December 7, 1995 and 

which is a major source of HAP shall submit an Initial Notification in 

conjunction with its construction permit application. A facility 

constructed or reconstructed on or after December 7, 1995 which 

subsequently becomes a major source of HAP shall submit an Initial 

Notification within 30 days of becoming a major source of HAP. Initial 

Notifications for facilities constructed on or after December 7, 1995 shall 

include the following information: 

( 1) The date when construction or reconstruction began 

or is scheduled to begin; 

(2) The anticipated date of startup of the source; and 

(3) The information listed in paragraphs (a)(l) through 

(a)(6) of this subsection. 

( c) A facility subject to this regulation which was constructed 

or reconstructed after December 7, 1995 shall notify the Division of the 

actual date of startup of the facility by April 6, 1996 or within 15 calendar 

days after the startup date, whichever is later. 

35.7.6 Initial Compliance Certification 

Page 28 of 45 
(a) The owner or operator of a facility subject to the VHAP 

emission limitations in this regulation shall submit an Initial Compliance 

Certification for VHAP to the Division. Initial Compliance Certifications 

for VHAP for facilities which began operation on or after December 6, 

1994 shall be submitted by May 6, 1996 or 60 days after beginning 

operation, whichever is later. Initial Compliance Certifications for VHAP 

for facilities which began operation before December 6, 1994 shall be 

submitted by May 6, 1998. The owner or operator of a facility that, due to 

an increase in emissions, becomes a major source of HAP after the 

effective date of the regulation, shall submit an Initial Compliance 

Certification to the Division no more than 60 days after becoming a major 

source of HAP. 

(b) The owner or operator of a facility subject to the voe 

emission limitations in this regulation shall submit an Initial Compliance 

Certification for VOC to the Division. Initial Compliance Certifications 

for VOC shall be submitted by May 6, 1998. 

( c) Initial Compliance Certifications shall include the following infonnation: 

(1) For a facility that is complying with emission 

limitations through the use of compliant materials, Initial 

Compliance Certifications shall state that each topcoat, filler, stain, 

toner, ink, multi-colored coating, pigmented coating, sealer, 

washcoat, enamel, basecoat, thinner, adhesive and strippable booth 

coating is in compliance with applicable emissions limitations in 

this regulation and identify the method used to detennine 

compliance. 

(2) For a facility monitoring viscosity to demonstrate 

compliance with emission limitations, the initial compliance report 

shall state that viscosity is an appropriate parameter for 

demonstrating compliance, that viscosity is being measured in 

accordance with the specifications in Paragraph 35.6.l(b)(2) and 

that viscosity measurements demonstrate that the VHAP and VOC 

content of the material in the coaters is in compliance with 

applicable emission limitations. 

(3) For a facility using weekly averaging to comply 

with the VOC emission limitations in Subsection 35.3.l or 

monthly averaging to comply with the VHAP emission limitations 

in Subsection 35.3.2 or 35.2.3, the Initial Compliance Certification 

shall state that Evoc and EVHAP, as calculated using Equation 1 and 

Equation 2, respectively, are no greater than the applicable 

emission limitations specified in Subsection 35.6.2. 

Page 29of45 
(4) For a facility using a control system to comply with 

the emission limitations in this regulation, the Initial Compliance 

Certification shall identify each control device installed, including 

the identification number, permit number, installation date and 

equipment controlled. In addition, the following information must 

be submitted no more than 60 days after completing the initial 

performance test of the control system: 

(i) The results of the initial performance test of 

the control system; 

(ii) The overall control efficiency needed (Rn), 

calculated using Equation 3 for VOC emissions from 

finishing operations, Equation 5 for VHAP emissions from 

finishing operations, and Equation 6 for VHAP emissions 

from gluing operations, as applicable; 

(iii) The actual overall control efficiency (Ra) 

calculated using the results of the initial performance test 

and Equation 4; and 

(iv) A plan for monitoring operating parameters 

which identifies the operating parameter values which 

indicate ongoing compliance, calculated as specified in 

Paragraph 35.6.4(h), discusses why those parameters are 

appropriate indicators of compliance, and specifies the 

frequency that those parameters will be monitored. 

(5) Initial Compliance Certifications shall state that a 

work practice implementation plan has been developed and 

procedures have been established for implementing the provisions 

of that plan. 

(6) Initial Compliance Certifications shall be signed by 

a responsible official of the company that owns or operates the 

facility. 

35.7.7 Periodic Reports 

The owner or operator of a facility subject to this regulation shall submit periodic reports 

to the Office of Air Resources according to the following specifications: 

(a) Periodic reports shall be submitted semi-annually by I 

February of each year for the reporting period of 1 July through 31 

December of the previous year and by 1 September for the reporting 

Page 30 of 45 
period of January 1 through June 30, which include the following: 

(1) The amount and type ofVOe and VHAP in each 

coating used at the facility during the reporting period, 

(2) A compliance certification, as specified in 

Paragraphs (b) through (g) of this subsection, and 

(3) Documentation of progress made during the 

reporting period toward reducing the voe and VHAP content of 

coatings used at the facility. 

(b) If the facility is using compliant coatings to comply with 

the emission limitations in Sections 35.3 and 35.4 of this regulation, 

periodic reports shall state that the voe and VHAP content of each 

topcoat, filler, stain, toner, ~ multi-colored coating, pigmented coating, 

sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth 

coating used each day at the facility was in compliance with applicable 

limitations in those sections throughout the reporting period, or should 

identify periods of noncompliance and the reasons for noncompliance. 

( c) If the facility uses viscosity to monitor compliance, the 

periodic report shall state that the viscosity of the finishing material in the 

reservoir was monitored according to the specifications in Paragraph 

35.6.l(b)(2) and that those measurements demonstrated compliance with 

applicable emission limitations throughout the reporting period, or should 

identify the days of noncompliance and the reasons for noncompliance. 

(d) If the facility is complying with the voe emissions 

limitations in Section 35.3 using averaging, the periodic report shall 

include the results of the voe averaging calculation (Equation 1) for each 

week in the reporting period and shall certify that the facility was in 

compliance with the applicable emission limitations in all weeks during 

that period, or identify the weeks that these limitations were exceeded and 

give reasons for those exceedances. 

( e) If the facility is complying with the VHAP emissions 

limitations in Section 3 5 .3 using averaging, the periodic report shall 

include the results of the VHAP averaging calculation (Equation 2) for 

each month in the reporting period and shall certify that the facility was in 

compliance with the applicable emission limitations in all months during 

that period, or identify the months that these limitations were exceeded 

and give reasons for those exceedances. 

(f) If the facility is complying with the emission limitations in 

this regulation using a control system, the periodic report shall state that 

Page 31 of 45 
the daily average value of each continuously monitored operating 

parameter was within the acceptable range on each operating day, or 

identify the days of noncompliance and the reasons for the 

noncompliance. 

(g) Periodic reports shall include a statement certifying that the 

work practice implementation plan and startup, shutdown, and 

malfunction plan were followed throughout the reporting period, or 

otherwise identify the periods of noncompliance with the work practice 

standards. 

(h) The periodic report shall be signed by a responsible official 

of the company that owns or operates the facility. 

(i) If an exceedance occurs, periodic reports must be submitted 

quarterly until a request to reduce the reporting frequency has been 

approved. Submittal frequencies may be reduced to semi-annual provided 

that the following conditions have been satisfied: 

(1) The facility has demonstrated a full year of 

compliance without an exceedance; and 

(2) The owner or operator of the facility continues to 

comply with the recordkeeping and monitoring requirements 

specified in this regulation. 

35.8 Performance Test Methods 

35.8.l voe and Solids Content 

(a) voe and solids content, by weight, of coatings shall be 

demonstrated with EPA Method 24 or an alternative procedure approved 

by EPA and the Department. Sampling procedures shall follow the 

guidelines presented in "Standard Procedures for Collection of Coating 

and Ink Samples for VOC Content Analysis by Reference Method 24 and 

Reference Method 24A," EPA-340/1-91-010. 

(b) The owner or operator of a facility that uses a finishing 

material that does not release voe reaction byproducts during the cure; 

for example, if all voe is solvent; may re.quest permission to use batch 

formulation information to demonstrate compliance. If the voe content 

of a coating determined by an EPA Method 24 test is greater than that 

indicated by the facility's formulation data, the EPA Method 24 test shall 

govern. 

Page 32 of45 
35.8.2 VHAP and Solids Content 

(a) EPA Method 311 of Part 63, Appendix A, or an alternative 

method, if approved by EPA and the Department, shall be used in 

conjunction with formulation data to determine the VHAP content of the 

liquid coating. Formulation data shall be used to identify VHAP present 

in the coating, and Method 311 or an approved alternative method shall be 

used to quantify the VHAP identified through the formulation data. EPA 

method 311 shall not be used to quantify VHAP such as styrene and 

formaldehyde that are emitted during the cure. 

(b) EPA Method 24 ( 40 CFR part 60) shall be used to 

determine the solids content by weight and the density of coatings for the 

purpose of showing compliance with VHAP emission limitations. 

( c) The owner or operator of a facility that uses a finishing 

material that does not release VOC or VHAP byproducts during the cure; 

for example, if all VOC and VHAP present in the coating is solvent; may 

request permission to use batch formulation information to demonstrate 

compliance. 

( d) If the VOC content of a coating as determined by EPA 

Method 24/311 test is higher than that indicated by a facility's formulation 

data, the EPA Method 24/311 test shall govern, unless the facility can 

demonstrate to the satisfaction of the Department that formulation data are 

correct. 

( e) Sampling procedures sham follow the guidelines presented 

in "Standard Procedures for Collection of Coating and Ink Samples for 

VOC Content Analysis by Reference Method 24 and Reference 

Method 24A," EPA-340/1-91-010. 

35.8.3 Control Equipment Efficiency 

(a) EPA Method 18, 25, or 25A shall be used to determine the 

VOC concentration of gaseous air streams. EPA Method 18 shall be used 

to determine the VHAP concentration of gaseous air streams. The test 

shall consist of three separate runs, each lasting a minimum of 30 minutes. 

(b) EPA Method 1 or lA shall be used for sample and velocity traverses. 

( c) EPA Method 2, 2A, 2C, or 2D shall be used to measure 

velocity and volumetric flow rates. 

(d) EPA Method 3 shall be used to analyze exhaust gases. 

Page 33 of45 
where: 

( e) EPA Method 4 shall be used to measure the moisture 

content of stack gas when required. 

(f) EPA Methods 2, 2A, 2C, 2D, 3, and 4 shall be performed, 

as applicable, at least twice during each test run. 

(g) VOC and VHAP control systems must be constructed so 

that volumetric flow rates and VOC and/or total VHAP concentrations, as 

applicable, can be determined by the test methods specified in Paragraphs 

(a) through (f) of this subsection, as applicable. 

(h) Capture efficiency shall be measured using measures 

approved by the EPA. 

(i) Testing shall be performed while all affected emission 

points are connected and operating at maximum production rate. 

(j) The efficiency (F) of the control device shall be determined 

using Equation 7: 

n p 

l: Qbi cbi - l: Qaj Caj 

i- 1 j=I 

F= Equation 7 

N 

l: Qbi Cbi 

F =control device efficiency, expressed as a fraction. 

Cbi = the concentration ofVOC or VHAP, as applicable, in gas stream (i) 

entering the emission control device, in parts per million by volume. 

Caj = the concentration ofVOC or VHAP, as applicable, in gas stream G) 

exiting the emission control device, in parts per million by volume. 

Qaj = the volumetric flow rate of gas stream (j) exiting the emission 

control device, in dry standard cubic meters per hour. 

Qbi = the volumetric flow rate of gas stream (i) entering the emission 

control device, in dry standard cubic meters per hour. 

(k) Determine the efficiency (N) of the capture system using Equation 8: 

Page 34 of 45 
N = Equation 8 

n P 

where: N = the capture system efficiency, expressed as a fraction. 

Cdi = the concentration ofVOC or VHAP, as applicable, in gas stream (i) 

entering the emission control device from the affected emission point(s), 

in parts per million by volume. 

Ctk = the concentration ofVOC or VHAP, as applicable, in each 

uncontrolled gas stream (k) emitted directly to the atmosphere from the 

affected emission point(s), in parts per million by volume. 

Qdi = the volumetric flow rate of gas stream (i) entering the emission 

control device from the affected emission point(s), in dry standard cubic 

meters per hour. 

Qfk = the volumetric flow rate of each uncontrolled gas stream (k) emitted 

directly to the atmosphere from the affected emission point(s), in dry 

standard cubic meters per hour. 

(l) If all effected emissions points are surrounded by a 

permanent enclosure that is demonstrated to be total by procedures 

acceptable to the Department and the EPA, the control device capture 

efficiency, N, is equal to 1. 

35.9 General Provisions 

35.9.1 Purpose 

35.9.2 

The purpose of this regulation is to limit emissions of volatile organic 

compounds and hazardous air pollutants from wood products manufacturing 

operations. 

Authority 

These regulations are authorized pursuant to R.I. Gen. Laws§ 42-l 7.1-2(s) 

Page 35 of 45 
35.9.3 

35.9.4 

35.9.5 

and 23-23, as amended, and have been promulgated pursuant to the 

procedures set forth in the R.I. Administrative Procedures Act, R.I. Gen. 

Laws Chapter 42-35 

:ApplieatioB 

The terai.s aad fH'E>'•~sioas of this regH:lation shall be liberally constraeEi te 

permit the Department to effectuate the purposes of state Wlt', goals and 

policies. 

Severability 

If any provision of this regulation or the application thereof to any person or 

circumstance, is held invalid by a court of competent jurisdiction, the 

validity of the remainder of the regulation shall not be affected thereby. 

Effective Date 

The foregoing regulation, "Control of Volatile Organic Compounds and 

Volatile Hazardous Air Pollutants from Wood Products Manufacturing 

Operations'', as amended, after due notice, is hereby adopted and filed with 

the Secretary of State this 29th day of June , 2007 to become 

effective twenty (20) days thereafter, in accordance with the provisions of 

Chapters 23-23, 42-35, 42-17.1, 42-17.6, of the General Laws of Rhode 

Island of 1956, a5 amended. 

W. Michael Sullivan, PhD., Director 

Department of Environmental Management 

Page 36 of45 
Notice Given on: February 21, 2007 

Public Hearing held: March 23, 2007 

Filing Date: June 29, 2007 

Effective Date: July 19, 2007 

Page 37 of45 
TABLE 1. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS 

Chemical name 

Acetaldehyde 

Acetamide 

Acetonitrile 

Acetophenone 

2-Acetylaminofl uorine 

Acrolein 

Acrylamide 

Acrylic acid 

Acrylonitrile 

Allyl chloride 

4-Aminobiphenyl 

Aniline 

o-Anisidine 

Benzene 

Benzi dine 

Benzotrichloride 

Benzyl chloride 

Biphenyl 

Bis(2-ethylhexyl)phthalate (DEHP) 

Bis( chloromethyl)ether 

Bromoform 

1,3-Butadiene 

Caprolactam 

Carbon disulfide 

Carbon tetrachloride 

Carbonyl sulfide 

Catechol 

Chloroacetic acid 

2-Chloroacetophenone 

Chloro benzene 

Chloroform 

Chloromethyl methyl ether 

Chloroprene 

Cresols (isomers and mixture) 

o-Cresol 

m-Cresol 

p-Cresol 

Cumene 

2A-D (2,4-Dichlorophenoxyacetic acid, including 

salts and esters) 

DDE (1, l-Dichloro-2,2-bis(p-chlorophenyl)ethylene) 

Page 38 of 45 

CASNo. 

75070 

60355 

75058 

98862 

53963 

107028 

79061 

79107 

107131 

107051 

92671 

62533 

90040 

71432 

92875 

98077 

100447 

92524 

117817 

542881 

75252 

106990 

105602 

75150 

56235 

463581 

120809 

79118 

532274 

108907 

67663 

107302 

126998 

1319773 

95487 

108394 

106445 

98828 

94757 

72559 
Table 1 (continued) 

Chemical name 

U1azomethane 

Dibenzofuran 

l ,2-Dibromo-3-chloropropane 

Dibutylphthalate 

1,4-Dichlorobenzene 

3,3'-Dichlorobenzidine 

Dichloroethyl ether (Bis(2-chloroethyl)ether) 

1,3-Dichloropropene 

Diethanolamine 

N,N-Dimethylaniline 

Diethyl sulfate 

3,3'-Dimethoxybenzidine 

4-Dimethylaminoazobenzene 

3,3'-Dimethylbenzidine 

Dimethylcarbamoyl chloride 

N ,N-Dimethylformamide 

1, 1-Dimethylhydrazine 

Dimethyl phthalate 

Dimethyl sulfate 

4,6-Dinitro-o-cresol, and salts 

2, 4-Dinitrophenol 

2, 4-Dinitrotoluene 

1, 4-Dioxane ( 1,4-Diethy leneoxide) 

1,2-Diphenylhydrazine 

Epichlorohydrin (1-Chloro-2,3-epoxypropane) 

1,2-Epoxybutane 

Ethyl acrylate 

Ethylbenzene 

Ethyl carbamate (Urethane) 

Ethyl chloride (Chloroethane) 

Ethylene di bromide (Dibromoethane) 

Ethylene dichloride ( 1,2-Dichloroethane) 

Ethylene glycol 

Ethylene oxide 

Ethylenethiourea 

Ethylidene dichloride ( 1, 1-Dichloroethane) 

Formaldehyde 

Glycol ethers 

Page 39of47 

CASNo. 

334883 

132649 

96128 

84742 

106467 

91941 

111444 

542756 

111422 

121697 

64675 

119904 

60117 

119937 

79447 

68122 

57147 

131113 

77781 

51285 

121142 

123911 

122667 

106898 

106887 

140885 

100414 

51796 

75003 

106934 

107062 

107211 

75218 

96457 

75343 

50000 

0 
Table 1 (continued) 

Chemical name CASNo. 

.Hexachlorobenzene 118741 

.Hexachloro-1,3-butadiene 87683 

Hexachloroethane 67721 

Hexamethylene-1,6-diisocyanate 822060 

Hexamethylphosphoramide 680319 

Hexane 110543 

Hydrazine 302012 

.Hydroquinone 123319 

Isophorone 78591 

Maleic anhydride 108316 

Methanol 67561 

Methyl bromide (Bromomethane) 74839 

Methyl chloride (Chloromethane) 74873 

Methyl chloroform (1, 1, I-Trichloroethane) 71556 

Methyl ethyl ketone (2-Butanone) 78933 

Methylhydrazine 60344 

Methyl iodide (Iodomethane) 74884 

Methyl isobutyl ketone (.Hexone) 108101 

Methyl isocyanate 624839 

Methyl methacrylate 80626 

Methyl tert-butyl ether 1634044 

4,4'-Methylenebis(2-chloroaniline) 101144 

Methylene chloride (Dichloromethane) 75092 

4,4'-Methylenediphenyl diisocyanate (MDI) 101688 

4,4'-Methylenedianiline 101779 

Naphthalene 91203 

Nitro benzene 98953 

4-Nitrobiphenyl 92933 

4-Nitrophenol 100027 

2-Nitropropane 79469 

N-Nitroso-N-methylurea 684935 

N-Nitrosodimethylamine 62759 

N-Nitrosomorpholine 59892 

Phenol 108952 

p-Phenylenediamine 106503 

Phosgene 75445 

Phthalic anhydride 85449 

Polychlorinated biphenyls (Aroclors) 1336363 

Page 40 of 47 
Table 1 (continued) 

Chemical name CASNo. 

Polycychc Orgaruc Matter0 0 

1,3-Propane sultone 1120714 

beta-Propiolactone 57578 

Propionaldehyde 123386 

Propoxur (Baygon) 114261 

Propylene dichloride (1,2-Dichloropropane) 78875 

Propylene oxide 75569 

1,2-Propylenimine (2-Methyl aziridine) 75558 

Quin one 106514 

Styrene 100425 

Styrene oxide 96093 

2,3, 7,8-Tetrachlorodibenzo-p-dioxin 1746016 

1, 1,2,2-Tetrachloroethane 79345 

Tetrachloroethylene (Perchloroethylene) 127184 

Toluene 108883 

2,4-Toluenediamine 95807 

Toluene-2,4-diisocyanate 584849 

o-Toluidine 95534 

1,2,4-Trichlorobenzene 120821 

1, 1,2-Trichloroethane 79005 

Trichloroethylene 79016 

2,4,5-Trichlorophenol 95954 

2,4,6-Trichlorophenol 88062 

Triethylamine 121448 

Trifluralin 1582098 

2,2,4-Trimethylpentane 540841 

Vinyl acetate 108054 

Vinyl bromide 593602 

Vinyl chloride 75014 

Vinylidene chloride (1, 1-Dichloroethylene) 75354 

Xylenes (isomers and mixture) 1330207 

o-Xylene 95476 

m-Xylene 108383 

p-Xylene 106423 

alncludes mono- and di-ethers of ethylene glycol, diethylene glycols and triethylene 

glycol; R-(OCH2CH2)RR-OR where: 

n= l,2,or3, 

Page 41of47 
Table 1 (continued) 

R = alkyl or aryl groups 

R1= R, H, or groups which, when removed, yield glycol ethers with the 

structure: R-(OCH2CH2)n - OH. Polymers are excluded from the glycol 

category. 

blncludes organic compounds with more than one benzene ring, and which have a boiling 

point greater than or equal to 100°C. 

Page 42 of 47 
TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING 

AND WASH OFF SOL VENTS 1 

Chemical Name 

4-Aminobiphenyl 

Styrene oxide 

Diethyl sulfate 

N-Nitrosomorpholine 

Dimethyl formamide 

Hexamethylphosphoramide 

Acetamide 

4,4'-Methylenedianiline 

o-Anisidine 

2,3,7 ,8-Tetrachlorodibenzo-p-dioxin 

Beryllium salts 

Benzi dine 

N-Nitroso-N-methylurea 

Bis( chloromethyl)ether 

Dimethyl carbamoyl chloride 

Chromium compounds (hexavalent) 

1,2-Propylenimine (2-Methyl aziridine) 

Arsenic and inorganic arsenic compounds 

Hydrazine 

1,1-Dimethyl hydrazine 

Beryllium compounds 

1,2-Dibromo-3-chloropropane 

N-Nitrosodimethylamine 

Cadmium compounds 

Benzo (a) pyrene 

Polychlorinated biphenyls (Aroclors) 

Heptachlor 

3,3'-Dimethyl benzidine 

Nickel subsulfide 

Acrylamide 

Hexachlorobenzene 

Chlordane 

1,3-Propane sultone 

1,3-Butadiene 

CASNo. 

92671 

96093 

64675 

59892 

68122 

680319 

60355 

101779 

90040 

1746016 

92875 

684935 

542881 

79447 

75558 

99999904 

302012 

57147 

7440417 

96128 

62759 

50328 

1336363 

76448 

119937 

12035722 

79061 

118741 

57749 

1120714 

106990 

1 Solvents containing these pollutants in concentrations less than or equal to 0. I% may be used. 

Page 43 of 47 
Chemical Name 

Nickel refinery dust 

2-Acetylaminoflourine 

3,3'-Dichlorobenzidine 

Lindane (hexachlorcyclohexane, gamma) 

2,4-Toluene diamine 

Dichloroethyl ether (Bis(2-chloroethyl)ether) 

1,2 - Diphenylhydrazine 

Toxaphene (chlorinated camphene) 

2,4-Dinitrotoluene 

3 ,3 '-Dimethoxybenzidine 

Formaldehyde 

4,4'-Methylene bis(2-chloroaniline) 

Acrylonitrile 

Ethylene dibromide(l ,2-Dibromoethane) 

DDE (1,1-p-chlorophenyl 1-2 dichloroethylene) 

Chlorobenzilate 

Dichlorvos 

Vinyl chloride 

Coke Oven Emissions 

Ethylene oxide 

Ethylene thiourea 

Vinyl bromide (bromoethene) 

Selenium sulfide (mono and di) 

Chloroform 

Pentachlorophenol 

Ethyl carbamate (Urethane) 

Ethylene dichloride ( 1,2-Dichloroethane) 

Propylene dichloride (1,2-Dichloropropane) 

Carbon tetrachloride 

Benzene 

Methyl hydrazine 

Ethyl acrylate 

Propylene oxide 

Aniline 

1,4-Dichlorobenzene(p) 

2,4,6-Trichlorophenol 

Bis(2-ethylhexyl)phthalate (DEHP) 

o-Toluidine 

Propoxur 

Page 44 of 45 

CASNo. 

53963 

53963 

58899 

95807 

111444 

122667 

8001352 

121142 

119904 

50000 

101144 

107131 

106934 

72559 

510156 

62737 

75014 

99999908 

75218 

96457 

593602 

7488564 

67663 

87865 

51796 

107062 

78875 

56235 

71432 

60344 

140885 

75569 

62533 

106467 

88062 

117817 

95534 

114261 
Chemical Name CASNo. 

Tnchloroethylene 79016 

1,4-Dioxane ( 1, 4-Diethyleneoxide) 123911 

Acetaldehyde 75070 

Bromoform 75252 

Captan 133062 

Epichlorohydrin 106898 

Methylene chloride (Dichloromethane) 75092 

Tetrachloroethylene (Perchloroethylene) 127184 

Dibenz (ah) anthracene 53703 

Chrysene 218019 

Dimethyl aminoazobenzene 60117 

Benzo (a) anthracene 56553 

Benzo (b) fluoranthene 205992 

Antimony trioxide 1309644 

2-Nitropropane 79469 

1,3-Dichloropropene 542756 

7, 12-Dimethylbenz(a)anthracene 57976 

Benz( c )acridine 225514 

Indeno(l ,2,3-cd)pyrene 193395 

1,2:7 ,8-Dibenzopyrene 189559 

Page 45of45