### 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 7March 1996 LastAmended 19July 2007

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

### § 42- 17.1-2(s) and 23-23, as amended, and have beenpromulgated 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 AIRRESOURCES
AIRPOLLUTION CONTROL REGULATION NO. 35 CONTROLOFVOLATILEORGANICCOMPOUNDSAND VOLATILE HAZARDOUS AIRPOLLUTANTS 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

35.7 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 AIRRESOURCES AIRPOLLUTION CONTROL REGULATION NO. 35 CONTROL OF VOLATILE ORGANIC COMPOUNDS AND VOLATILE HAZARDOUS AIRPOLLUTANTS FROM WOOD PRODUCTS MANUFACTURING OPERATIONS



### 35.1 Definitions Unless otherwise expressly defined in this section, the terms used inthis 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 ofsampling and analyzing for 

### an air pollutant that is not a reference or equivalent EPA sampling method butthat has been demonstrated to the EP A's satisfaction to, in specific cases, produce results adequate for a determination ofcompliance. 35.1.3

. 

### "As applied" means the 

### VOC, VHAP and solids content ofthe coating material as it is used for coating the substrate, including the contribution of thinners

. 35.1.4. 

### "Basecoat" means a coat ofcolored 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 sothat pollutants canbe directed to a pollution control device such as an incinerator or a carbon adsorber. 35.1.6. 

### "Capture efficiency" means the fraction ofall 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 ofa finishing material, strippable booth coating, adhesive, or solvent, measured using EPA Methods 24 and 311 , or an equivalent or alternative method (or formulation data ifthe coating Pa

ge I o f 45meets the criteriaspecified in Subsection 35.8

. l(b)). The purpose ofthe CPDS is to assist the facility in demonstrating compliance with the emission limitations presented in Sections 35.3, 35.4 and 35.5 ofthis regulation. Therefore, the VOC and VHAP content should represent the maximwn VOC and VHAP emission pote ntial ofthe finishing material, strippable booth coating, or solvent.
35.1.8. 

### "Cleaning oper ations" 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 ofa coating that remains after the coating is dried or cured; solids content is determined using data from EPA Method 24.
35.1. 1 1 

### "Compliant coating" means a finishing material, adhesive, or strippable booth coating that meets applicable emission limitations specified in Section 35.3 and 35.4 ofthis 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 ofapplication 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 ofthis regulation at all times and is fulfilling all monitoring and recordkeeping provisions ofthe regulation in order to demonstrate compliance

. 35.1.15. 

### "Control device 11 means any equipment that reduces the quantity ofa 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 ofthe amount ofpollutant released Page 2 of45by a control device to the amount ofpollutant introduced to the control device, expressed as a fraction. 35.1.17. "Control system" means the combination ofcapture 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 ofatomization. Airless, air assisted airless, and electrostatic spray technologies are not considered conventional air spray methods. 3 5.1.19. "Day" means a period of24 consecutive hours beginning at midnight local time, orbeginning 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, ofone or more air pollutants into ambient air. 35

. 1.22. "Enamel" means a coat ofcolored, usually opaque material that is applied as a protective topcoat over a basecoat, primer, orpreviously 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 orVHAP 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 ofsampling and analyzing for an air pollutant that EPAhas 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 inthis definition. 35.1.26 "Finishing application station" means the part ofa finishing opera tion 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 Pa

ge 3 of45applied 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 tojoin components, for example to apply a laminate to a wood substrate orfoam to fabric. 35.1.31 "High-solids stains" means stains containing more than one pound ofsolids per gallon and includes wiping stains, glazes, and opaque stains. 35.1.32 "Incinerator" means an enclosed combustion device th at thennally oxidizes volatile organic compounds to CO and C02. This tenn does not include devices that burn municipal orhazardous 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 ofsolids per gallon, or less. 35.1.35 "Major source ofHazardous Air Pollutants" means a facility that emits orhas the potential to emit, in the aggregate, 10 tons per year (tpy) or more ofany Hazardous Air Pollutant (HAP), 25 tpy or more ofany combination ofHAPs, or such lesser quantity as the EPA may establish by rule. 35 .1.36 "Malfunction" means any sudden, infrequent, and not reasonably preventable failure ofair pollution control equipment, process equipment, or a process to operate in a nonnal orusual manner. Failures that are caused inpart 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 ispackaged 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 orrestore the reapplied material's intended effect. 35.1.39 "Operating 

### day" means a day, or any part ofa day, in which a facility is engaged in manufacturing. 35.1.40 "Operating parameter value" means a minimum or maximum value Page 4 of45established for a control device orprocess parameter that, ifachieved by itselfor in combination with one ormore 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 ofa coating, cleaning, or washoff. When used in a coating, the organic solvent evaporates during drying and does not become a part ofthe dried film. 35.1.42 "Overall control efficiency" means the efficiency ofa control system, calculated as the product ofthe 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 ofemissions 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 ofan 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 ofa wood substrate before additional coats offinishing material are applied. Washcoats, which are used in some finishing systems to optimize aesthetics, are not sealers. 35.1.47 "Shutdown" means the cessation ofoperation ofwood 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 ofa coating, cleaning, or washoff. When used in a coating, it evaporates during drying and does not become a part ofthe dried film. 35.1.49 "Stain" means any color coat having a solids content by weight ofnot more than 8.0 percent that is applied in single ormultiple 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 ofwood products manufacturing operations for any purpose. . 35.1.51 "Strippable booth coating" means a coating that: (I) is applied to a booth wall Page 5 of45to provide a protective film to receive overspray during finishing operations; (2) is subsequently peeled offand 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, orto modify drying conditions. 35.1.54 

### "Toner" means a stain which contains binders and dyes orpigments to add tint to a coated surface orto even the color ofan initial application ofstain. 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 offinishing materials to cover minor finishing imperfections. 35.1.57 

### "Volatile Hazardous Air Pollutant" and 11VHAP" means any ofthe 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 ofcolor, 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 

### "Washoffoperations" 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 ofproducts manufactured ofwood or wood products, including, but not limited to, particle board, reed, rattan and wicker. Wood product coating does not include coating offlat 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 offoperations conducted at a wood products facility

.

Page 6 of45

### 35.2 Applicability 35 .2

. 1 The provisions ofthis regulation apply to any wood products facility which has the potential to emit 25 tons per year or more ofvolatile organic compounds (VOC) from wood products manufacturing operations or which is located at a major source ofHazardous Air Pollutants (HAP). 35.2.2 The owner or operator ofa 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) ofSubsection 35.7.1 but the facility shall not be subject to any other provisions ofthis 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 orthe 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 ofa facility which is a major source ofHazardous Air Pollutants (HAP) but which has not emitted more than 10 tons ofany one HAP or more than 25 tons ofany combination ofl-IAP, including emissions from source categories otherthan 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 ofthis regulation. Exemption will be given in the form ofan 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 ofany one HAP or 4, 166 pounds ofany combination ofHAP; and (b) 

### The following records shall be maintained at the facility for a period offive years and made available to the Department or the EPA upon request: (1) The name, identification number, and amount of each finishing, gluing and washoffmaterial used each month at the facility; and (2) Certified Product Data Sheets showing the VOC and VHAP content ofeach finishing, gluing, and washoffmaterial used at the facility; and Page 7 of45(3) The type and amount ofsolvent used as thinners and in cleaning operations each month at the facility; (4) The average monthly emissions ofeach HAP from the facility, calculated monthly for the previous twelve month period. (c) 

### Ifthe limit inParagraph 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 ofa facility subject to this regulation which has the potential to emit greater than orequal to 25 tons per year ofvolatile organic compounds (VOe) shall limit voe emissions from wood products finishing operations by: 

### (1) Using finishing materials which comply with the emissions limitations inpounds ofVOe per gallon ofcoating minus water and exempt compounds listed 

### in Table 2; or (2) Using a control system that achieves the emissions limitations inpounds ofvoe per pound ofsolids listed in Table 2; or (3) Using finishing materials with a weighted average voe content, within a particular category ofcoatings as identified in Table 2, which conforms with the provisions specified in Subsection 35.6.2(a); or (4) Using a combination ofthe 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 of45T bl 2 E . . L'

. . f; 

### F"

. bin M 'al a e rmss1ons 1m1tations or llllS Lg aten 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 ofa 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 ofthe Department, to undergo a review every two years to determine whether the limitations in Paragraphs (a) and 

### (b) of Page 9 of 45this subsection represent Reasonably Available Control Te chnology (RACT) for the finishing operations at that facility at that time. Facilities shall comply with emissions limitations determined to be RACT within one year ofthat determination and shall thereafter operate in compliance with those limita tions. 35.3.2 VHAP Emission Limitations for Finishing Operations at Existing Facilities (a) On and after March 7, 1998, the owner or operator ofa facility subject to this regulation which is a major source ofHAP and which began operations before December 6, 1994 shall limit VHAP emissions from wood produc ts 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 ofno 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 ofParagraph (1) or (2) ofthis subsection, calculated according to the procedures in Subsection 35.6.3(c) ofthis regulation; or (4) Using a combination ofthe methods presented in Paragraphs (1) and (3) ofthis subsection which is approved bythe Department. (b) The formaldehyde content ofa finishin g material shall be calculated as the amount offree formaldehyde present inthe finishing material when it is applied

. (c) The styrene content ofa finishing material shall be based on an estimate ofunreacted styrene, which shall be calculated by multiplying the amount ofstyrene monomer inthe finishing material when it is applied by a factor of0.16.

Page 10 of4535.3.3 VHAP Emission Limitations for Finishing Operations atNewFacilities (a) On and after March 7, 1996, the owner or operator ofa facility subject to this regulation which is a major source ofHAP and began operation on or afte r 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 ofno 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 withthe requirements ofParagraph (1) or (2) ofthis subsection, calculated according to the procedures inprovisions in Subsection 35.6.3(c) ofthis regulation; or (4) Using a combination of the methods presented in Paragraphs (1) and (3) ofthis subsection which is approved by the Department. 

### (b) The formaldehyde content ofa finishing material shall be calculated as the amount offree formaldehyde present in the finishing material when it is applied. (c) The styrene content ofa finishing material shall be based on an estimate ofunreacted styrene, which shall be calculated by multiplying the amount ofstyrene monomer in the finishing material when it is applied by a factor of0.16.

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 ofa facility subject to this regulation which is a major source ofHAP 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 inproducts that meet the upholstered seating flammability requirements ofCalifornia 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 ofthe 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) ofthis subsection, the VHAP content ofthe adhesive shall not exceed 1.0 lb VHAP/lb solids, as applied; or (c) Byusing a control system that will achieve a reduction in VHAP emissions equivalent to that which would be achieved by complying with the requirements ofParagraph (b) ofthis subsection, as calculated using the procedures in Subsection 35.6.3(d) ofthis regulation. 35.4.3 VHAP Emission Limitations for New Gluing Operations
On and after March 7, 1996, the owner or operator ofa facility subject to this regulation which is a major source ofHAP 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 

### WorkPractice Standards The owner or operator ofa facility subject to this regulation shall implement the following work practice standards by March 7, 1996, except where another date is specified.

Page 12 of4535.5.1 Work Practice Implementation Plan (a) The owner or operator ofa 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 ofthe 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 ofthe Department. (c) The owner or operator ofthe facility shall comply with each provision ofthe work practice implementation plan. (d) The work practice implementation plan shall be available for inspection bythe EPA orthe Department upon request and shall be modified bythe facility iffound to be inadequate. 35.5.2 Operator Training Course (a) Each owner or operator ofa facility subject to this regulation shall train all new and existing personnel, including contract personnel, who are involved infinishing, gluing, cleaning, or washoff operations, use ofmanufacturing equipment, or implementation ofthe requirements ofthis 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 washoffprocedures; (3) Appropriate equipment setup and adjustment to minimize finishing material usage and overspray; and (4) Appropriate management ofcleanup wastes. (d) The facility shall maintain records ofthe training program. Records shall include, at a minimum, the following: (1) A list ofall current personnefby name andjob Page 13 of45description who are required to be trained and a record ofthe date that each employee was trained; (2) An outline ofthe subjects covered in the initial and refresher training for each position, or group ofpersonnel; (3) Lessonplans for courses to be given at the initial and the annual refresher training that include, at a minimum, the topics specified in Paragraph (c) ofthis subsection; and (4) A description ofthe methods to be used to demonstrate successful completion ofinitial 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 ap ply finishing materials, adhesives, or organic solvents shall be visually inspected for leaks at least once per month. (2) A first attempt atrepair 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 ofa 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) ofthis 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 ofstartup, 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 of45(2) Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction planrequired 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 ofoperation and maintenance procedures (including the startup, shutdown, and malfunction plan required 

### in Paragraph (b)(4) ofthis subsection), review ofoperation and maintenance records, and inspection ofthe facility. (4) The owner or operator ofa 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 ofcorrective 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 canbe used to fulfill this requirement, provided the plan meets all the requirements ofthis 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 ifdetermined to be unacceptable. (5) During periods ofstartup, shutdown, and malfunction, the owner or operator ofa 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 ofParagraph (b)(4) ofthis subsection. (6) The owner or operator ofa facility subject to this regulation shall keep records ofaction taken during startups, shu tdowns, 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 inthe facility's startup, shutdown and malfunction plan developed under Paragraph (b )(

4) ofthis Page 15 of45subsection (7) 

### Ifactions taken bythe owner or operator during a startup, shutdown, ormalfunction (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 ofAir 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) 

### Ifa 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 malfunct ion events and a program of corrective action for similar malfunctions ofprocess or air pollution control equipment. 35.5.4 Cleaning and WashoffSolvent Requirements (a) The owner or operator ofa facility subject to this regulation shall account for organic solvent use in cleaning and washoffoperations by recording the following information: (1) The quantity and types oforganic solvent used in washoffand cleaning operations each month; (2) The number ofpieces washed off , an d the reason for the washoff; and (3) The quantity ofspent organic solvent generated from each washoffand cleaning activity each month, and whether itis recycled onsite or disposed offsite. (b) Facilities subject to this regulation shall not use cleaning or washoffsolvents that contain any ofthe pollutants listed inTable 3 in concentrations greater than 0.1%.

Page 16 of4535.5.5 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, ormetal filters, unless the spray booth is being refurbished. 

### Ifthe 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 oforganic solvent per booth to prepare the booth prior to applying the booth coating. 35.5.6 Storage Requirements All finishing, gluing, cleaning, and washoffmaterials 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 inthe following situations: (a) When applying finishing materials before March 6, 1998 at a facility which is not a major source ofHAP 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 orrepair that occurs after the completion ofa finishing operation; (d) Touch-up orrepair that occurs after the stain and before any other type offinishing material is applied, provided that the touch-up finishing materials are applied from a container that has a volume ofno more than 2.0 gallons; (e) 

### Ifthe spray gun is aimed and triggered automatically, not manually; 

### (f) 

### Ifemissions from the finishing application station are directed to a control device; (g) For application ofa finishing material ifthe total usage of that finishing material is no more than 5.0percent ofthe 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 ofstain on a part for which it is technically Page 17 of45or 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 coatthe part and the application station is not large enough to accommodate an additional operator; or (2) The excessively large vertical spray area ofthe part makes it difficult to avoid sagging orruns 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 isbeing added or removed.
35.5.10 Washoffoperations
Emissions from washoffoperations shall be controlled by: (a) Using tanks for washoffthat are closed at all times except when material is being added orremoved; and (b) Minimizing dripping by tilting orrotating the part to drain as much organic solvent as possible. 35.5.11 Formulation Assessment Plan
Each owner or operator ofa facility that is subject to this regulation and that is a major source ofHazardous 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 ofusage bythe facility for each VHAP as follows: ( 1) The baseline usage level shall bethe annual usage Page 18 of45

### from the calendar year 1994 for each VHAP; (2) For formaldehyde, the baseline level ofusage shall be based on the amount offree formaldehyde present in the finishing material when it is applied; (3) For styrene, the baseline level ofusage shall be an estimate ofunreacted styrene, which shall be calculated by multipl ying the amount ofstyrene 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 ofthe 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% ofthe Reportabl e Quantity for that substance specified in Table III ofRegulation No

. 22. (c) Tracks the annual usage ofeach 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 notifica tion to the Division by 31 January ofthe following year that specifies the amount ofthe increase and ex plains the reasons for the increase. The Department will determine whether the increase would cause an exceedance ofthe 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 ofprogress.

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 ofthis regulation through the use ofcompliant coatings shall be demonstrated by the following methods: (a) Maintaining Certified Product Data Sheets (CPDS) documenting that the VOC and/or VHAP content ofeach topcoat, filler, stain, toner, ink , multi-colored coating, pigmented coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and s trippable booth coating meets the applicable emissions limitations in Sections 35.3 and 35.4 in lb P age 19 of45VOC/gallon ofcoating or lb VHAP/lb ofsolids; and (b) Maintaining formulation data and related calculations showing that the VOC and VHAP content ofeach 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 ofcoating or lb VHAP/lb ofsolids; and (c) For facilities with continuous coaters, using one ofthe following procedures: (1) Calculating the VOC and VHAP content, as applicable, ofthe finishing material in the reservoir from information onthe CPDS and records ofmaterials added to the reservoir; or (2) Monitoring the viscosity ofthe finishing material in the reservoir with a viscosity meter or testing the viscosity ofthe initial finishing material and retesting the material in the reservoir eachtime solvent is added. 

### If this option is chosen, the facility shall maintain data that demonstrates the correlation between the viscosity ofthe finishing material and the VOC and VHAP content, as applicable, ofthe finishing material; and (d) The Department orEPA will determine compliance either byreviewing the records specified in Paragraphs (a), (b) and (c) ofthis subsection or by conducting a performance test according to the specifications in Subsections 35.8.l and 35.8.2. 

### Ifthe VOC or VHAP content ofa 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 orby 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 35.3.1 for a particular coating category through the use ofaveraging, the owner or operator ofa 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 of45Where:Evoc = the average VOC content ofcoatings in a particular coating category, in lb VOC/gal coating, as applied; 

## c = the 

## voe content ofa 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 ofcoating, in gallons, as applied, ofa particular coating inthe coating category used during the weekly averaging period; (2) Demonstrate that the value calculated for Ev oc 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 ofaveraging, the owner or operator ofa 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 offinishing materials, in lb VHAP /lb solids; C =the VHAP content ofa coating, inlb VHAP/lb solids, as applied; i = subscript denoting an individual coating;
M = the mass ofsolids, in pounds, in a particular finishing material used during the monthly averaging period; S = the VHAP content ofa solvent, expressed as a weight fraction, added to finishing materials; and
W = the amount ofsolvent, inpounds, added to finishing Page21 of45materials during the monthly averaging period. (2) Demonstrate that the value calculated for EvHAP is no greater than 1.0 

### ifthe facility is complying with Subsection 35.3.2 and is no greater than 0.8 ifthe facility is complying with Subsection 35.3.3.
35

.6.3 Initial Compliance Using Control Equipment (a) The owner or operator ofa 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 orthe 

## 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 ofa 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 ofthe control system needed, expressed as a percentage. C = the VOC content ofa 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 ofC used in Equatfon 3 was calculated from the 

## voe and solids content ofthe as-applied finishing material. (3) Demonstrate, for all applicable coatings, that the value ofRn 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) ofthe control system measured in the initial performance test into Equation 4. Page 22 of45

### Ra = (F 

### x N)(IOO) Equation 4 (c) Initial compliance with 

### VHAP emission limitations for finishing materials through the use ofa 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 ifcomplying with Subsection 35.3.3;
Rn= (1 OO)(Ebe

- Eae)/fac Equation 5 Where:Rn = the overall efficiency ofthe control system needed, expressed as a percentage; Eac = emissions from an emission point or a set ofemission points after control equipment is in operation, in lb VHAP/lb solids; and Ebe = emissions from an emission point or set ofemission points before controls, calculated as EVHAP inEquation 2. (2) Demonstrate that the value ofRn calculated using Equation 5 is less than orequal to the actual overall control efficiency 

### (Ra) calculated using the capture efficiency (N) and control efficiency (F) ofthe control system measured inthe initial performance test and Equation 4. (d) Initial compliance with VHAP emission limitations for gluing materials through the use ofa control system shall be determined as follows: (1) Calculate the overall control efficiency ofthe control system needed (Rn) so that the value ofGae in Eq uation 6 is no greater than 1.0 ifcomplying 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 ofthe control system needed, expressed as a percentage; Gae 

### = emissions from the gluing operation after control equipment, in lb VHAP/lb solids; and Page 23 of45Gbc 

## =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) ofthe control system measured inthe initial performance test and Equation 4. 35.6.4 Continuous Compliance Using Control Equipment (a) The owners or operator ofa facility that is complying with the emission limitations inthis regulation through the use ofa 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 inthis 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 inthe ductwork immediately downstream ofthe 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 ofthe 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 bethe minimum gas temperature upstream ofthe catalyst bed and the pressure drop across the catalyst bed, and temperature monitoring devices equipped with continuous recorders shall be installed inthe 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 oforganic 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 ofthe following devices is required to monitor these parameters: (1) An integrating regeneration stream flow monitoring device having an accuracy of±10 percent, capable ofrecording the total regeneration stream mass flow for each regeneration cycle; and a carbon bed temperature monitoring device having an accuracy of±1 percent ofthe temperature being monitored expressed in degrees Celsius or ±0.5° C, whichever is greater, capable ofrecording the carbon bed temperature after each regeneration and within 15 minutes ofcompleting any cooling cycle; (2) An organic monitoring device, equipped with a continuous recorder, to indicate the concentration level oforganic 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 ofAir Resources a description ofthe device, test data verifying the performance ofthe 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 ofthe Department and the EPA. (h) Operating parameter values indicating compliance shall be calculated as the arithmetic average ofthe maximum or minimum value of those parameters, as appropriate, measured during the three test runs ofthe initial performance test, provided that the initial performance test demonstrated compliance. (i) The capture or control device shall be operated so that the average ofall 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) ofthis subsection.

Page 25 of45

### 35.7 Recordkeeping and Reporting 35.7.1 The owner or operator ofa facility subject to this regulation shall maintain the following records for a period offive years: (a) A certified product data sheet (CPDS) for each finishing material, thinner, adhesive, and strippable booth coating subject to the emission limitations inthis regulation; (b) As applicable, the voe content in lb voe/gallon of coating, as applied and the VHAP content, in lb VHAP/lb ofsolids, as applied, ofeach coating subject to the emission limitations inthis regulation, and copies ofcalculations docwnenting how the as-applied values were determined. The voe content ofstrippable booth coatings shall be expressed in units oflb VOC/lb solids, as applied. (c) The amount and type ofeach coating and thinner used at the facility each month. (d) 

### Ifviscosity measurements are used to track 

## voe and/or VHAP concentrations: (1) Records ofdates and amounts ofsolvent and

· finishing material added to the continuous coater reservoir; (2) Records ofdates and results ofviscosity measurements; and (3) Data demonstrating that viscosity is an appropriate parameter for demonstrating compliance. 35.7.2 The owner or operator ofa facility using weekly averaging to comply with the VOC emissions limitations in Subsection 35.3. l ormonthly 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 of5 years. 35.7.3 The owner or operator ofa source using control equipment to comply with the emissions limitations inthis regulation shall maintain the following records for a period offive years: (a) Copies ofcalculations ofEVHAP from Equation 2 and 

### Rn from Equation 3, 5 and 6, as applicable; (b) Records ofthe daily average value ofeach continuously monitored operating parameter for each operating day. 

### Ifall 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 ofthe 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 ofa 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 ofthat plan, as specified in Section 35.5, including, but not limited to: (a) Records demonstrating that the operatortraining 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 offinishing 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 ofcompounds used for cleaning booth components, except for solvent used to clean conveyors, continuous coaters and their enclosures, and/or metal filters; (g) A copy oflogs and other documentation developed to demonstrate th a

t the provisions ofthe work practice implementation plan ?Te followed; and (h) A copy ofthe compliance certifications, and periodic reports submi tted in accordance with the requirements of this regulation. 35.7.5 Initial Notifications (a) The owner or operator ofa facility subject to this regulation which was constructed before December 7, 1995 and w hich is a major source ofHAP shall submit a Initial Notification to the Division by September 2, 1996 or within 30 days of becoming a major source ofHAP, whichever is later. Initial Notifications for facilities constructed before Pag e 27 of45December 7, 1995 shall include the following information: ( 1) The name and address ofthe owner or operator; (2) The address (i.e., physical location) ofthe facility; (3) An identification ofthe relevant standard, or other requirement, that is the basis ofthe notification and the facility's compliance date; (4) A briefdescription ofthe nature, size, design, and method ofoperation ofthe facility, including its operating design capacity and an identification ofeachpoint ofemission for each HAP, or, ifa definitive iden tification is not yet possible, a preliminary identification ofeach point ofemission for each HAP; (5) An estimate ofthe amount ofeach HAP used and emitted annually from the facility; and (6) The number ofhours per day and days per week that the facility operates. (b) The owner or operator ofa facility subject to this regulation which was constructed orreconstructed on or after December 7, 1995 and which is a major source ofHAP shall submit an Initial Notification 

### in conjunction with its construction permit application. A facility constructed orreconstructed on or after December 7, 1995 which subsequently becomes a major source ofHAP shall submit an Initial Notification within 30 days ofbecoming a major source ofHAP. Initial Notifications for facilities constructed on or after December 7, 1995 shall include the following information: ( 1) The date when construction orreconstruction began or is scheduled to begin; (2) The anticipated date ofstartup ofthe source; and (3) The information listed 

### inparagraphs (a)(l) through (a)(6) ofthis subsection. (c) A facility subject to this regulation which was constructed or reconstructed after December 7, 1995 shall notify the Division ofthe actual date ofstartup ofthe 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 of45(a) The owner or operator ofa 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 ofa facility that , due to an increase in emissions, becomes a major source ofHAP after the effective date ofthe regulation, shall submit an Initial Compliance Certification to the Division no more than 60 days after becoming a major source ofHAP. (b) The owner or operator ofa 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 ofcompliant 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 ofthe material 

### inthe 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 inthis 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 ofthe control system: (i) The results ofthe 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 ofthe 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 ofcompliance, 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 ofthat plan. (6) Initial Compliance Certifications shall be signed by a responsible official ofthe company that owns or operates the facility. 35.7.7 Periodic Reports The owner or operator ofa 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 ofeach year for the reporting period of 1 July through 31 December ofthe previous year and by 1 September for the reporting Page 30 of45period ofJanuary 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) ofthis subsection, and (3) Documentation ofprogress made during the reporting period toward reducing the voe and VHAP content of coatings used at the facility. (b) 

### Ifthe facility is using compliant coatings to comply with the emission limitations in Sections 35.3 and 35.4 ofthis regulation, periodic reports shall state that the voe and VHAP content ofeach 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 incompliance with applicable limitations in those sections throughout the reporting period, or should identify periods ofnoncompliance and the reasons for noncompliance. (c) 

### Ifthe facility uses viscosity to monitor compliance, the periodic report shall state that the viscosity ofthe 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 ofnoncompliance and the reasons for noncompliance. (d) 

### Ifthe facility is complying with the voe emissions limitations in Section 35.3 using averaging, the periodic report shall include the results ofthe 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) 

### Ifthe facility is complying with the VHAP emissions limitations in Section 3 5.3 using averaging, the periodic report shall include the results ofthe VHAP averaging calculation (Equation 2) for each month inthe 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) Ifthe facility is complying with the emission limitations in this regulation using a control system, the periodic report shall state that Page 31 of45the daily average value ofeach continuously monitored operating parameter was within the acceptable range on each operating day, or identify the days ofnoncompliance 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 ofnoncompliance with the work practice standards. (h) The periodic report shall be signed by a responsible official ofthe company that owns or operates the facility. (i) 

### Ifan 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 ofthe facility continues to comply with the recordkeeping and monitoring requirements specified inthis regulation.



### 35.8 Performance Test Methods 35.8.l 

## voe and Solids Content (a) 

## voe and solids content, by weight, ofcoatings 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 ofCoating 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 ofa facility that uses a finishing material that does not release 

## voe reaction byproducts during the cure; for example, ifall 

## voe is solvent; may re.quest permission to use batch formulation information to demonstrate compliance. 

### Ifthe 

## voe content ofa coating determined by an EPAMethod 24 test is greater than tha t indicated by the facility's formulation data, the EPA Method 24 test shall govern.
Page 32 of4535.8.2 VHAP and Solids Content (a) EPA Method 311 ofPart 63, Appendix A, or an alternative method, ifapproved by EPA and the Department, shall be used in conjunction with formulation data to determine the VHAP content ofthe liquid coating. Formulat ion data shall be used to identify VHAP present inthe 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 ofcoatings for the purpose ofshowing compliance with VHAP emission limitations. (c) The owner or operator ofa facility that uses a finishing material that does not release VOC orVHAP byproduc ts during the cure; for example, 

### ifall VOC and VHAP present inthe coating is solvent; may request permission to use batch formulation information to demonstrate compliance. (d) Ifthe VOC content ofa 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 ofthe Department that formulation data are correct.(e) Sampling procedures sham follow the guidelines presented in "Standard Procedures for Collection ofCoating 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 ofgaseous air streams. EPA Method 18 shall be used to determine the VHAP concentration ofgaseous air streams. The test shall consist ofthree separate runs, each lasting a minimum of30 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 of45where: (e) EPA Method 4 shall be used to measure the moisture content ofstack 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, canbe determined by the test methods specified in Paragraphs (a) through (f) ofthis subsection, as applicable. (h) Capture efficiency shall be measured using measures approved bythe EPA. (i) Testing shall be performed while all affected emission points are connected and operating at maximum production rate. (j) The efficiency (F) ofthe 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, inparts per million by volume. Caj = the conce ntration ofVOC or VHAP, as applicable, in gas stream 

### G) exiting the emission control device, inparts per million by volume. Qaj = the volumetric flow rate ofgas stream (j) exiting the emission control device, in dry standard cubic meters per hour

. Qbi = the volumetric flow rate ofgas stream (i) entering the emission control device, in dry standard cubic meters per hour. (k) Determine the efficiency (N) ofthe capture system using Equation 8:

Page 34 of45N = 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, ineach uncontrolled gas stream (k) emitted directly to the atmosphere from the affected emission point(s), inparts per million by volume. Qdi 

## =the volumetric flow rate ofgas 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 ofeach uncontrolled gas stream 

### (k) emitted directly to the atmosphere from the affected emission point(s), in dry standard cubic meters perhour. (l) 

### Ifall effected emissions points are surrounded by a permanent enclosure that is demonstrated to betotal 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 ofthis regulation is to limit emissions ofvolatile organic compounds and hazardous 

### air pollutants from woodproducts manufacturing operations.
Authority These regulations are authorized pursuantto 

### R.I. Gen. Laws§ 42-l7.1-2(s) Pa

ge 35 of45

### 35.9.3

35.9.4

35.9.5 and 23-23, as amended, and have been promulgatedpursuantto 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** 

### ofthis regH:lation shall be liberally constraeEi te permitthe Department to effectuate the purposes ofstate Wlt', goals and 

### policies. 

### Severability If

### any provision ofthis regulation or the application thereofto any person or circumstance, is held invalid by a court ofcompetentjurisdiction, the validity ofthe remainder ofthe regulation shall not be 

### affected thereby.

Effective Date

The foregoing regulation, "Control ofVolatile 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 ofState 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, ofthe General Laws ofRhode Island of 1956, a5 

### amended.

W. Michael Sullivan, PhD., Director Department ofEnvironmental 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 AIRPOLLUTANTS 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 of45 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 72559Table 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 Dimeth yl phthalate Dimeth yl 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 1211 42 123911 122667 106898 106887 140885 100414 51796 75003 106934 107062 107211 75218 96457 75343 50000 

### 0Table 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 of47Table 1 (continued) Chemical name CASNo. Polycychc Orgaruc Matter 0 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 ofethylene glycol, diethylene glycols and triethylene

glycol; R-(OCH2CH2 )RR-OR where: n= l,2,or3, Page 41of47Table 1 ( continued) R = alkyl or aryl groups R 1 

## = R, H, or groups which, when removed, yield glycol ethers with the structure: 

### R

-(OCH2CH 2)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 of47

### 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 beused.

Page 43 of47Chemical 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 Ethyle ne 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 of45 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 114261Chemical 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