STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR RESOURCES 

Am POLLUTION CONTROL REGULATION NO. 19 

CONTROL OF VOLATILE ORGANIC COMPOUNDS 

FROM SURFACE COATING OPERATION 

Effective 13 November 1979 

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 RI. Administrative Procedures Act, R.I. Gen. Laws Chapter 

42-35. 
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR RESOURCES 

AIR POLLUTION CONTROL REGULATION NO. 19 

CONTROL OF VOLATILE ORGANIC COMPOUNDS 

FROM SURFACE COATING OPERATION 

TABLE OF CONTENTS 

19.l Definitions ....................................................................................................................................................... l 

19.2 Applicability ................................................................................................................................................... 5 

19.3 Emission Limitations ...................................................................................................................................... 6 

19.4 Alternative Standards Allowing Internal Offsets for Surface Coating Facilities (The Bubble 

Concept) ........................................................................................................................................................ I 0 

19.5 Compliance Certification, Recordkeeping and Reporting Requirements ...................................................... 12 

19.6 Registration ................................................................................................................................................... 21 

19.7 Compliance Demonstration/Testing .............................................................................................................. 22 

19.8 Compliance Schedules .................................................................................................................................. 22 

19.9 General Provisions ......................................................................................................................................... 24 

APPENDIX A ............................................................................................................................................... 26 
RHODE ISLAND DEPARTMENT OF ENVIRONMENT AL MANAGEMENT 

OFFICE OF AIR RESOURCES 

AIR POLLUTION CONTROL REGULATION NO. 19 

CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM 

SURFACE COATING OPERATIONS 

19.1 Defmitions 

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: 

19.1.1 "Actual Emissio.ns" means the quantity of volatile organic compounds emitted 

from a source during a particular time period. 

19 .1.2 "Air-dried coating" means a coating that is dried by the use of air or forced 

warm air at temperatures up to 90EC (194EF). 

19.1.3 "Class II hardboard paneling finish" means finishes that meet the 

specifications of Voluntary Product Standard PS-59-73 as approved by the 

American National Standards Institute. 

19.1.4 "Clear coating" means a coating that (1) either lacks color and opacity or is 

transparent and (2) uses the surface to which it is applied as a reflective base or 

undertone color. 

19.1.5 "Coating applicator" means a device, mechanism, or apparatus used to apply a 

surface coating. Common types of application techniques include knife, roll, 

spray or dip. 

19.1.6 "Coating line" means an operation or manufacturing process or device which 

may be comprised of one or more coating applicators, one or more flash-off areas 

and/or one or more ovens wherein a surface coating is dried and/or cured. 

19.1.7 "Drum" means any cylindrical metal shipping container of 13- to 110-gallon 

capacity. 

19.1 8 "Emission Baseline" means a level of emissions calculated by multiplying two 

factors: 

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(a) the lowest of the source's actual or allowable emission rate in emissions 

per unit of production; and 

(b) the source's actual capacity utilization, or units of production, over some 

representative time period. Generally, the time period is the preceding two year 

average unless the source can demonstrate that those years were not 

representative of historical production. 

19.1.9 "Extreme performance coatings" means coatings intended for exposure to any 

of the following; outdoor weather conditions all of the time, temperatures 

frequently above 95EC (203EF), detergents, abrasive and scouring agents, 

solvents, corrosive atmospheres, or similar environmental conditions. 

19.1.10 "Hardboard" is a panel manufactured primarily from inter-felted lignocellulosic fibers that are consolidated under heat and pressure in a hot press. 

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

19. l .12 "Metal Cans" means any cylindrical single walled container, with or without a 

top, cover, spout, and/or handle that is manufactured from metal sheets thiruier 

than 29 gauge (0.0141 inches) and into which solid or liquid materials are 

packaged. 

19 .1.13 "Multicomponent coating" means a coating which is packaged in two or more 

parts, which parts are combined before application, and where a coreactant from 

one part of the coating chemically reacts, at ambient conditions, with a coreactant 

from another part of the coating. 

19. l .14 "Natural finish hardwood plywood panels" means panels whose original grain 

pattern is enhanced by essentially transparent finishes frequently supplemented by 

fillers and toners. 

19 .1.15 "Oven" means a chamber within which heat is used to bake, cure or polymerize 

and/or dry a surface coating. 

19 .1.16 "Pail" means any cylindrical metal shipping container with a capacity of greater 

than or equal to 1 and less than 13 gallons and constructed of 29-gauge and 

heavier material. 

19 .1.17 "Prime Coat" means the first of two or more coatings applied to a surface. 

19 .1.18 "Printed interior panels" means panels whose grain or natural surface is 

obscured by fillers and basecoats upon which a simulated grain or decorative 

pattern is printed. 

19.1.19 "Refmishing" means the repainting of used equipment. 

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19.1.20 "Surface coating" means a process whereby a layer of one or more substances 

containing voe and solids are deposited on another material (substrate) in a 

uniform manner across the surface of the substrate. The layer of coating may be 

used for appearance, to decorate, bond, protect, strengthen, functionalize and/or 

impart stability, water or acid repellence or mildew resistance. For purposes of 

this regulation only, types of coating processes are defined as follows: 

(a) Paper coating - the application of a coating or coatings on paper, pressuresensitive tapes, plastic film or metal foil to impart any or all qualities above. 

(b) Fabric coating - the application of a coating or coatings on a textile 

substrate to impart any or all qualities above. 

( c) Vinyl coating - the application of a coating or coatings on a vinyl coated 

paper, vinyl coated fabric, or vinyl substrate or printing on vinyl-coated fabric or 

vinyl sheets to impart any or all qualities above. 

( d) Miscellaneous metal parts and products (MMP) coating means the 

application of a coating or coatings, including but not limited to adhesives, on any 

metal part or metal product, even if attached to or combined with a nonmetal part 

or product. Miscellaneous metal parts and products include, but are not limited 

to: 

(1) Large farm machinery (harvesting, fertilizing and planting 

machines, tractors, combines, etc.); 

(2) Small farm machinery (lawn and garden tractors, lawn mowers, 

rototillers, etc.); 

(3) Small appliances (fans, mixers, blenders, crock pots, 

dehumidifiers, vacuum cleaners, etc.); 

( 4) Commercial machinery (office equipment, computers and auxiliary 

equipment, typewriters, calculators, vending machines, etc.); 

(5) Industrial machinery (pumps, compressors, conveyor components, 

fans, blowers, transformers, etc.); 

(6) Fabricated metal products (metal covered doors, frames, etc.); 

(7) Any other industrial category that coats metal parts or products 

under the Standard Industrial Classification Codes of Major Group 33 

(primary metal industries), Major Group 34 (fabricated metal products), 

Major Group 35 (non-electric machinery), Major Group 36 (electrical 

machinery), Major Group 37 (transportation equipment), Major Group 38 

(miscellaneous instruments), and Major Group 39 (miscellaneous 

manufacturing industries); and 

Page 3 of28 
(8) Application of underbody antic hip materials (e.g., underbody 

plastisol) and coating application operations other than prime, primer 

surface, topcoat, and final repair operations at automobile and light-duty 

truck assembly plants. 

(9) Miscellaneous metal parts coating does not include the application 

of a coating or coatings to the following: 

(i) Automobiles and light-duty trucks; 

(ii) Automobile and light duty truck refinishing; 

(iii) Customized top coating of automobiles and trucks, 

if production is less than 35 vehicles per day; 

(iv) Metal cans; 

(v) Flat metal sheets and strips in the form of rolls or coils; 

(vi) Magnet wire for use in electrical machinery; 

(vii) Metal furniture; and 

(viii) Large appliances. 

(ix) Exterior of completely assembled aircraft; 

(x) Exterior of major aircraft subassemblies, if 

approved by the Director, and approved by EPA, as a 

Federal Implementation Plan (FIP) or State Implementation 

Plan (SIP) revision; 

(xi) Exterior of completely assembled marine vessels; or 

(xii) Exterior of major marine vessel subassemblies if 

approved by the Director, and approved by EPA, as a FIP 

or SIP revision; or 

(xiii) Exterior of tanks used for bulk storage of chemicals 

at the facility. 

( e) Magnet wire coating - the application of a coating in which an electrically 

insulating varnish or enamel is applied onto the surface of a wire for use in 

electrical machinery. 

(t) Coil coating - the application of a coating to any continuous metal strip 

Page 4 of28 
with thickness of 0.006 inch or more that is packaged in a roll or coil. 

(g) Flat wood paneling coating - the application of a coating to flat wood 

panels including: printed interior panels made of hardboard plywood and thin 

particle board (i.e., less than or equal to 0.25 inches in thickness) natural finish 

hardboard plywood panels; and hardboard paneling with Class II finishes. 

(I) Flat wood paneling does not include: Class I hardboard panels, 

particle board used in furniture or wood products, insulation board, 

exterior siding, tile board, and soft wood plywood coating lines. 

(h) Metal furniture coating - the application of a coating to any furniture piece 

made of metal or any metal part that will be assembled with other metal, wood, 

fabric, plastic, or glass parts to form a furniture piece including, but not limited to, 

tables, chairs, waste baskets, beds, desk, locker, benches, shelving, file cabinets, 

and room dividers. 

(i) Large appliance coating - the application of a coating to the surface of 

component metal parts (including, but not limited to, doors, cases, lids, panels 

and interior parts) of any residential or commercial washer, dryer, freezer, range, 

refrigerator, water heater, dishwasher, trash compactor, air conditioner, or other 

similar products under Standard Industrial Classification Code 363. 

( 1) Large appliance coating does not include the use of quick drying 

lacquers for repair of scratches and nicks that occur during assembly, 

provided that the volume of coating does not exceed 0.25 gallons in any 

one 8 hour period. 

19.1.21 "Thin particleboard" is a manufactured board that is 0.25 inch or less 

in thickness made of individual wood particles that have been coated with a 

binder and formed into flat sheets by pressure. 

19. l .22 "Tile board" means paneling that has a colored, waterproof surface coating. 

19.1.23 "Topcoat" means the final film or series of films of coating applied to a 

surface; 

19.2 Applicability 

19.2.l The provisions of this regulation apply to all surface coating facilities for 

which actual uncontrolled emissions from all operations in any one of the surface 

coating categories listed as Subsections 19.1.20 (a)-(i) have been greater than 15 

pounds of volatile organic compounds in any one day after December 31, 1989. 

Page 5 of28 
19.2.2 Where ever the term Volatile Orgae:ic Compound or VOC is ll:Sed i:a 

8eetioas 19.2 !hroagh 19.8 and 8abseetioa 19.1.1 this term saoi:Hd be read as 

Volatile Orgae:ic Compound and Halogenated Orgaaie Compo\!Bd or VOC and 

HGG:-

19 .2.3 An owner or operator of a surface coating facility whose emissions are 

below the applicability threshold in Subsection 19 .2.1 shall comply with the 

certification, recordkeeping, and reporting requirements of Subsection 19 .5 .1. 

19.2.4 Any facility that was subject to the provisions of this regulation on or 

before November 19, 1992 by having or having had the potential to emit 100 tons 

ofVOC per year from paper, fabric, or vinyl coating or becomes subject to the 

provisions of this regulation after November 19, 1992 by exceeding the 

applicability threshold in Section 19 .2 .1 will remain subject to these provisions 

even if its emissions later fall below the applicability threshold. 

19 .2.5 Any surface coating facility which has actual emissions of 15 lbs 

VOC/day or more in any one day from all operations in any one of the surface 

coating categories listed as Subsections 19.1.20 (a)-(i), but has not had total actual 

voe emissions from surface coating operations exceeding 1,666 pounds in any 

calendar month since December 31, 1989, may apply to the Director for 

exemption from Section 19.3 of this regulation. Exemption will be given in the 

form of an enforceable document, and will include the following conditions: 

(a) The total emissions from all surface coating operations shall not 

exceed 1,666 pounds in any one calendar month, 

(b) The facility shall maintain the following records at the facility for a 

period of five years. This information shall be made available to DEM 

and EPA upon request: 

(1) The name, identification number and amount used each 

month of each coating, as applied, on each coating line or 

operation; 

(2) The mass ofVOC per volume (excluding water), as 

applied, for each coating used on each coating line or 

operation; 

(3) The type and amount of solvent used for diluents and 

cleanup operations; 

(c) If the limit in (a) is exceeded, the emission limitations specified in 

Subsection 19.3.1 will immediately apply. 

19.3 Emission Limitations 

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19.3.l As outlined in the following table, surface coating lines must meet the 

emission limitations given below in either pounds ofVOC per gallon of coating 

(minus water) or in pounds ofVOC per gallon of solids, depending on the method 

of compliance: 

Page 7 of28 
TYPE OF SURF ACE EMISSION LIMITATION 

lbs VOC/gallon of lbs VOC/gallon of 

coating minus water solids 

Paper 2.9 4.79 

Fabric 2.9 4.79 

Vinyl 3.8 7.86 

Flat wood Paneling* 

Printed Interior Wall Panels 6.0* 

Made of Hardwood Plywood and Thin 

Particleboard 

Natural Finish Hardwood 12.0* 

Plywood Panels 

Class II Finishes for 10.0* 

Hardboard Paneling 

Miscellaneous Metal Parts** 

Clear Coating 4.3 10.34 

Steel Pail and Drum Interiors 4.3 10.34 

Air Dried Coating 3.5 6.67 

Extreme Performance Coating 3.5 6.67 

All other coating on misc. 3.0 5.06 

metal parts 

Metal Furniture 3.0 5.06 

Coil 2.6 4.02 

Large Appliances 2.8 4.52 

Magnet Wire 1.7 2.21 

*Emission limits for flat wood paneling are expressed in terms of lbs VOC/1000 square feet coated. 

**For miscellaneous metal parts coating, if more than one emission limitation applies to a specific coating, then 

the least stringent emission limitation shall be applied. 

For facilities complying without using add-on control equipment, the pounds ofVOC per gallon of coating 

(minus water) limit must be met. For facilities which bubble or use add-on control equipment, the pounds of 

VOC/gallon of solids emission limit must be met. 

Page 8 of28 
19.3.2 Compliance with the emission limitations of Subsection 19.3.1 shall be achieved, 

through: 

(a) Installation of an approved control system such that the total 

emission reduction from the controlled coating line is 95 percent or greater 

over uncontrolled volatile organic compound emissions, or 

(b) Coating reformulation such that the emission limitation of 

Subsection 19.3.l is met for all coatings on any coating lines using this 

method of compliance, or 

( c) Installation of control equipment to reduce emissions to the 

equivalent of the emission limitations of Subsection 19 .3 .1 as calculated 

on a solids applied basis, or 

(d) Use of daily-weighted averaging, as determined by the procedures 

in Appendix A of this regulation, to achieve the emissions limitations in 

Subsection 19 .3 .1 for all surface coating operations except the coating of 

flat wood paneling; 

(e) An alternative equivalent method of control as approved by the 

Director. Approval of an alternative method must be approved by EPA as 

a source specific State Implementation Plan (SIP) revision. 

19.3.3 The emission limitations set forth in Subsection 19.3.1 may be relaxed on 

a case-by-case basis as provided below: 

(a) The emission limitations set forth in Subsection 19.3.l shall not 

apply to surface coating facilities that comply with the following, if 6 

months prior to the final compliance date the owner or operator of the 

facility submits for approval by the Director: 

(1) Economic and/or technical documentation to the 

satisfaction of the Department and EPA that the applicable 

emission limitations set forth in Subsection 19 .3. I cannot feasibly 

be met, and 

(2) A proposal to set emission limitations different from those 

of Subsection 19. 3. I that will represent an Alternative Reasonably 

Available Control Technology; and 

(3) A schedule for attaining the Alternative Reasonably 

Available Control Technology emission limitations within two 

years of its being approved. 

Page 9 of28 
(b) All compliance date and emission limitation relaxations made 

under Subsections 19.3.3 (a) will not be final until approved by EPA as a 

SIP revision. 

( c) A relaxation of the emissions limitations in 19 .3 .1 will be approved 

only if the facility can demonstrate that economically, technically or both 

that neither coating reformulation nor the installation of a control system 

is feasible or even partially feasible. 

( d) The facility will undergo Reasonably Available Control 

Technology review every three years after the compliance date as 

determined in 19.3.3(a)(3) until the final emission limitation is achieved as 

defined in subsection 19. 3 .1. 

19.4 Alternative Standards Allowing Internal Offsets for Surface Coating Facilities (The 

Bubble Concept) 

19.4.2 

19.4. l The Director may approve alternative volatile organic compound emission 

standards in an applicable compliance schedule if: 

(a) the facility as a whole complies in a 24 hour period with the 

applicable emission limitations of Subsection 19 .3 .1 by the applicable 

compliance date, and 

(b) the requirements of Subsections 19.4.2 through 19.4.7 are met, and 

(c) the state is designated by EPA as Attainment or as Non-Attainment 

With Approved Demonstration of Attainment for Ozone. 

(a) The facility owner or operator specifies an emission limitation 

which defines the alternative maximum allowable emission rate in pounds 

per hour for each surface coating line which is part of the surface coating 

facility, and which is eligible under the criteria in Subsection 19.4.2 (b), 

and 

(b) To be eligible for consideration under this section the construction 

or modification of the coating line must have commenced prior to the 

effective date of the regulation, and 

( c) The combined actual emissions over a 24-hour period from all 

surface coating in the bubble used at surface coating lines which are a part 

of the surface coating facility and which are eligible as per subsection 

19.4.2(b) must be less than or equal to the allowable emission total (E) 

determined by the following equation: 

E=Al xBl +A2xB2+ ... +AnxBnwhere: 

Page 10 of28 
E = the allowable emissions from the surface coating facility in 

pounds per day, Al, A2, ... ,An= the applicable emission limitation for 

each coating line as determined in Subsection 19.3.l in pounds per gallon 

of solids applied; B 1, B2, .. ., Bn = the amount of gallons of solids applied 

for each coating in that 24-hour period. 

( d) All surface coating lines at the surface coating facility which are not 

included in the internal offset must comply with other applicable portions 

of this regulation. Non reactive VOC may not generate credit in a trade 

against reactive voe in a bubble. 

19.4.3 In order for a facility to demonstrate compliance with the emission 

limitations that were approved pursuant to Subsection 19.3.1, it is required that 

records shall be maintained. The records shall be: 

(a) kept on a daily basis for each installation being bubbled; and 

(b) follow record keeping requirements of Subsection 19.5.2; and 

(c) maintained for a five-year period and be accessible for review by the 

Director or the designated personnel of the Director. 

19.4.4 Facilities applying to bubble will be assigned an emission baseline, as described 

in Subsection 19 .1.8 Capacity utilization will be based on the average production 

during the two-year period prior to application to bubble. Facilities' annual 

emissions may not exceed the limit set by the emission baseline. Emissions will 

be reported monthly and compliance with the emission baseline will be met every 

consecutive 12 month period or some shorter period approved by the Director. 

19 .4.5 The provisions and emission limitations of any emissions bubble shall be 

incorporated in an approval, which must include source specific emission limits, 

recordkeeping requirements, and test methods used to demonstrate compliance. 

Facilities which are subject to an enforcement action need EPA approval to 

bubble. 

19.4.6 The ERC's used in an emissions bubble must be calculated on a solids applied 

basis. 

19.4.7 An approvable bubble must meet the following requirements: 

Page 11 of28 
(a) Emissions must be surplus. The reductions must not have been 

included in those anticipated in the SIP for the affected source. Credit 

cannot be taken for reductions made prior to the base year of the State's 

Approved SIP. This is accomplished by not including any coatings that 

were in compliance prior to the base year of the State's Approved SIP in 

the daily calculation of actual emissions and the daily calculation of 

allowable emissions in subsection 19.4.2 (c). Emissions reductions shown 

must not have been required by current state regulations, and must not be 

used by the source to meet any other regulatory requirement. 

(b) Emission reductions must be permanent. The amount and duration of the 

reductions must be shown. 

( c) Emission reductions must be quantifiable. A reliable basis for calculating 

the amount and rate of reductions must be used. Emission rates before and 

after the reductions must be demonstrated. 

( d) Emission reductions must be enforceable. An approval containing 

enforceable emissions rates will be issued. Demonstration of emission 

reductions must follow recordkeeping guidelines listed in subsection 

19.5.2. 

(e) All of the requirements ofEPA's final Emission Trading Policy (51 FR 

43814) must be met. 

19.4.8 The Department shall not approve any emissions bubble without first giving 

public notice at least 30 days prior to approval, and affording all interested 

persons opportunity to comment. The public may request a hearing. Upon a 

demonstration of significant public interest, the Director, in his discretion, may 

hold a hearing. EPA shall be provided with the public notice, proposed approval 

order, and technical support by the first day of the public comment period. Public 

(and EPA) comments will be considered prior to final approval of the bubble 

application. Upon issuance of final approval of the bubble, EPA will be mailed a 

copy of the approval, new technical support, and response to public comments. 

19.5 Compliance Certification, Recordkeeping and Reporting Requirements 

19 .5 .1 Any owner or operator of a coating line or operation that is exempt from the 

emission limitations in Section 19.3 because the facility's VOC emissions from all 

operations in any one of the surface coating categories listed as Subsections 

19.1.20 (a)-(i) have not exceeded 15 lbs/day, before the application of capture 

systems and control devices, on any day since 31December1989, shall comply 

with the following: 

(a) Certification. By November 19, 1993, the owner or operator of a 

facility referenced in Subsection 19 .5 .1 shall certify to the Director that 

the facility is exempt by providing the following: 

Page 12 of28 
(1) Name and location of the facility; 

Where: 

(2) Name, address and telephone number of the person 

responsible for the facility; 

(3) A declaration that the facility is exempt from the emission 

limitations of Section 19 .3 because the facility's VOC emissions 

from all operations on each of the surface coating categories listed 

as Subsections 19.1.20 (a)- (i) have not exceeded 15 lbs/day, 

before the application of capture systems and control devices, on 

any day since 31 December 1989; 

(4) Calculations that demonstrate that the combined VOC 

emissions from all coating lines and operations at the facility for 

each of the surface coating categories listed as Subsections 19. l .20 

(a) - (i) for a day representative of current maximum production 

levels are 15 pounds or less before the application of capture 

systems and control devices. The following equation shall be used 

to calculate total voe emissions for that day for each surface 

coating category: 

T = Total VOC emissions from coating lines and operations at the facility associated 

with any one of the surface coating categories listed as Subsections 19 .1.20 (a) -

(i), before the application of capture systems and control devices, in units of 

lb/day; 

n = The number of different coatings applied on each coating line or each operation at 

the facility associated with the surface coating category; 

i = Subscript denoting an individual coating; 

Ai = Mass ofVOC per volume of coating (i) (excluding water), as applied, used at the 

facility in units of pounds voe per gallon; and 

Bi = Volume of coating (I) (excluding water), as applied, associated with the surface 

Coating category, used at the facility in units of gallons per day. The instrument 

or method by which the owner or operator accurately measured or calculated the 

volume of each coating, as applied, used shall be described in the certification to 

the Director. 

(b) Record.keeping. On and after November 19, 1993, the owner or 

operator of a facility referenced in Subsection 19 .5.1 shall collect and 

record all of the following information each year and maintain the 

information at the facility for a period of 5 years: 

(1) The name and identification number of each coating, as applied; 

Page 13 of28 
(2) The mass ofVOC per volume (excluding water) and the 

volume of coating 

(excluding water), as applied, used each year; 

(3) The total voe emissions from coating lines and operations 

at the facilityassociated with each of the surface coating categories 

listed as Subsections 19. l .20 (a) - (i), before the application of 

capture systems and control devices, as calculated using the 

equation in Section 19.5.l(a)(S), and 

( 4) The type and amount of solvent used for diluents and 

cleanup operations. 

(c) Reporting. On and after November 19, 1993, the owner or 

operator of a facility referenced in Subsection 19.5.l of this regulation 

shall notify the Director of any record 

showing that the facility's voe emissions from all operations in any one of the surface 

coating categories listed as Subsections 19.1.20 (a) - (i), before the application of 

capture systems and control devices, exceed 15 pounds on any day. 

19.5.2 Any owner or operator of a coating line or operation that meets the applicability 

threshold in Subsection 19.2.1 and complies with or intends to comply with 

Subsection 

19 .3 .1 by the use of daily-weighted averaging shall comply with the following: 

(a) Initial Compliance Certification Plan: By November 19, 1993, or 

upon startup of a new coating line or operation, or upon changing the 

method of compliance for an existing subject coating line or operation 

from control devices or complying coatings to the use of daily-weighted 

averaging, the owner or operator of a coating line or operation referenced 

in Subsection 19.5.2 shall certify to the Director that the coating line or 

operation is or will be in compliance with the requirements of Subsection 

19.3.l on and after the compliance dates specified in Subsection 19.8.5. 

Such certification shall include: 

(l) The name and location of the facility; 

(2) The name, address and telephone number of the person responsible 

for the facility; 

(3) An identification of subject sources; 

( 4) The name and identification number of each coating line or 

operation which will comply by means of daily-weighted 

averaging; 

Page 14 of28 
( 5) The instrument or method by which the owner or operator will 

accurately measure or calculate the volume of each coating 

(excluding water), as applied,used each day on each coating line or 

operation; 

( 6) The method by which the owner or operator will create and 

maintain records each day as required by Subsection 19.5.2(b); 

(7) The time at which the facility's day begins if a time other than 

midnight local time is used to define a day. 

(b) Final Compliance Certification: By the 

compliance dates specified in Subsection 19.8.5, the owner 

or operator of sources identified in Subsection 19.5.2 shall 

certify to the Director that the facility is in compliance with 

the emission limitations in Subsection 19.3. l by the 

use of daily-weighted averaging. This certification shall 

include: 

(1) The name, identification number, mass ofVOC per volume (minus 

water) and the volume of each coating (minus water), as applied,. 

on each coating line or operation and the calculation of the dailyweighted average for each day of the previous month using the 

procedure outlined in Appendix A of this regulation, or 

(2) The name, identification number, inass ofVOC per volume (minus 

water) and the volume of each coating (minus water), as applied, 

on each coating line or operation, the density of each coating as 

applied, and the volume fraction solids content of each coating, as 

applied and the calculation of the daily-weighted average for each 

day of the previous month using the procedure outlined in 

Appendix A of this regulation, and 

(3) An identification of any changes from the initial compliance 

certification plan. 

( c) Record.keeping. On and after the compliance dates 

specified in Subsection 

19 .8.5, the owner or operator of a coating line or operation 

referenced in Subsection 19.5.2 and complying by the means of dailyweighted averaging shall collect and record all of the following 

information each day for each coating line or operation and maintain the 

information at the facility for a period of 5 years: 

(1) The name and identification number of each coating, as applied, on 

each coating line or operation, 

Page 15 of28 
(2) The mass ofVOC per volume coating (excluding water) and the 

volume of each coating (excluding water), as applied, used each 

day on each coating line or operation, 

(3) The daily-weighted average voe content of all coatings, as 

applied on each coating line or operation calculated according to 

the procedure in Appendix A of this regulation 

( 4) The type and amount of solvent used for diluents and cleanup 

operations. 

( d) Reporting. On and after the compliance dates specified in 

Subsection 19 .8.5, the owner or operator of a subject coating line or 

operation referenced in Subsection 19.5.2 shall: 

( 1) Notify the Director of any record showing noncompliance with the 

applicable daily weighted average requirements by sending a copy 

of the record to the Director within 30 calendar days following the 

occurrence, and, 

(2) At least 30 calendar days before changing the method of 

compliance from daily-weighted averaging to the use of complying 

coatings or control devices, comply with all requirements of 

Subsections 19.5.3 or 19.5.4, respectively. Upon changing the 

method of compliance from the use of daily-weighted averaging to 

complying coatings or control devices, the owner or operator shall 

comply with all requirements of the sections of this regulation 

applicable to that compliance method. 

19 .5 .3 Any owner or operator of a coating line which meets the applicability threshold in 

Subsection 19.2.1 of this regulation and complies with or intends to comply with 

Subsection 19.3.1 by the use of complying coatings shall comply with the 

following: 

(a) Initial Compliance Certification Plan: By November 19, 1993, or 

upon startup of a new coating line or operation, or upon changing the 

method of compliance for an existing subject coating line or operation 

from daily-weighted averaging or control devices to the use of complying 

coatings, the owner or operator of a coating line or operation referenced in 

Subsection 19.5.3 shall certify to the Director that the coating line or 

operation is or will be in compliance with the applicable emission 

limitations in this regulation on and after the compliance dates specified in 

Subsection 19.8.5. Such certification shall include: 

(1) The name and location of the facility; 

Page 16 of28 
(2) The name, address and telephone number of the person responsible 

for the facility; 

(3) Identification of subject sources; 

( 4) The name and identification number of each coating, as applied, on 

each coating line or operation; 

(5) The mass ofVOC per volume coating (excluding water) and the 

volume of each coating (excluding water), as applied, and 

( 6) The time at which the facility's day begins if a time other than 

midnight local time is used to define a day. 

(b) Final Compliance Certification: By the compliance dates specified 

in Subsection 19.8.5, the owner or operator of sources identified in 

Subsection 19.5.2 shall certify to the Director that the facility is in 

compliance with the emission limitations in Subsection 19 .3 .1 by the use 

of complying coatings. This certification shall include: 

(1) The name, identification number, mass ofVOC per volume (minus 

water) and the volume of each coating (minus water), as applied, 

on each coating line or operation and 

(2) An identification of any changes from the initial compliance 

certification plan. 

(c) Record.keeping. On and after the compliance dates specified in Subsection 

19.8.5, the owner or operator of a coating line or operation referenced in 

Subsection 19.5.3 shall collect and record all of the following information 

each month for each coating line or operation and maintain the 

information at the facility for a period of 5 years: 

( 1) The name and identification number of each coating, as applied, on 

each coating line or operation, and 

(2) The mass ofVOC per volume of each coating (excluding water), 

as applied, used each month on each coating line or operation. 

(3) The type and amount of solvent used for diluents and cleanup 

operations. 

(d) Reporting. On and after the compliance dates specified in Subsection 

19 .8.5, the owner or operator of a subject coating line or operation 

referenced Subsection 19.5.3 shall: 

Page 17 of28 
( 1) Notify the Director of any record showing use of any noncomplying coatings by sending a copy of such record to the 

Director within 30 calendar days following that use, and, 

(2) At least 30 calendar days before changing the method of 

compliance from the use of complying coatings to daily-weighted 

averaging or control devices, comply with all requirements of 

Subsections 19.5.2 or 19.5.4, respectively. Upon changing the 

method of compliance from the use of complying coatings to dailyweighted averaging or control devices, the owner or operator shall 

comply with all requirements of the section of this regulation 

applicable to that compliance method. 

19 .5 .4 Any owner or operator of a coating line or operation that meets the applicability 

threshold in subsection 19 .2.1 and complies with or intends to comply with 

subsection 19.3.1 by means of control devices shall comply with the following: 

(a) Initial Compliance Certification Plan: By November 19, 1993, or 

upon startup of a new coating line or operation, or upon changing the 

method of compliance for an existing coating line or operation from the 

use of complying coatings or daily-weighted averaging to control devices, 

the owner or operator of the subject coating line or operation shall certify 

to the Director that the coating line will be in compliance with the 

applicable emission limits in this regulation on and after the compliance 

dates specified in Subsection 19.8.5. Such certification shall include: 

(1) The name and location of the facility; 

(2) The name, address and telephone number of the person 

responsible for the facility; 

(3) Identification of subject sources; 

( 4) The name and identification number of each coating, as 

applied, on each coating line or operation; 

(5) The mass ofVOC per volume coating solids applied and 

the gallons of solids of each coating applied; 

( 6) Identification of each control device which will be or has 

been installed pursuant to the requirements in this regulation and 

date of installation; 

(7) Identification of coating lines which will be controlled by 

each control device and documentation of expected capture and 

destruction efficiency or reduction efficiency; 

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(8) Control device design information; 

(i) For thermal incinerators - design combustion 

temperature (°F); 

(ii) For catalytic incinerators - design exhaust gas 

temperature {°F), design temperature rise across catalyst 

bed (°F), anticipated frequency of catalyst change, and 

catalyst changes; 

(iii) For condensers - design inlet temperature of 

cooling medium (°F), design exhaust gas temperature (°F); 

(iv) For carbon adsorbers - design pressure drop across 

the adsorber, voe concentration at breakthrough. 

(b) Final Compliance Certification: By the compliance dates specified 

in Subsection 19.8.5, the owner or operator of sources identified in 

Subsection 19.5.4 shall certify to the Director that control devices have 

been installed which reduce emissions from subject lines. This 

certification shall include: 

(1) An identification of each control device installed, including the 

identification number, model number, installation date and coating 

lines controlled. 

(2) Results of compliance tests and associated calculations 

demonstrating a 95% overall reduction ofVOC emissions from 

subject lines or reduction of emissions to the equivalent of the 

emission limitations of Subsection 19 .3 .1 as calculated on a solids 

applied basis. Overall reduction efficiency shall be calculated as 

the product of the capture efficiency and the control device 

destruction or removal efficiency. Testing shall be performed 

according to Section 19. 7. Capture efficiency shall be determined 

by methods approved by the Department and EPA. 

(3) An identification of any changes from the initial compliance 

certification plan. 

( c) Record.keeping. On and after the compliance dates specified in 

Subsection 19.8.5, the owner or operator of a coating line or operation 

referenced in Subsection 19.5.4 shall collect and record all of the 

following information each month for each coating line or operation and 

maintain the information at the facility for a period of 5 years: 

(1) The name and identification number of each coating used on each 

coating line or operation; 

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(2) For sources complying with Subsection 19.3.2 (a): 

(i) The mass ofVOe per unit volume of coating solids, as 

applied, the volume solids content, as applied, and the 

volume, as applied, of each coating used each month on 

each coating line or operation; 

(3) For sources complying with Subsection 19.3.2 (c): 

(i) The maximum voe content (mass ofVOe per unit volume of 

coating solids, as applied) or the daily-weighted average voe 

content (mass ofVOe per unit volwne of coating solids, as 

applied) of the coatings used each day on each coating line or 

operation; 

(4) The type and amount of solvent used for diluents and clean up 

operations; 

(5) A log of operating time for the capture system, control device, 

monitoring equipment, and the associated coating line or 

operation; 

( 6) A maintenance log for the capture system, control device, and 

monitoring equipment detailing all routine and non-routine 

maintenance performed including 

dates and duration of any outages; 

(7) For thermal incinerators: 

(i) All 3-hour periods of operation in which the average 

combustion temperature was more than 28Ee (50EF) 

below the average combustion temperature during the most 

recent performance test that demonstrated that the facility 

was in compliance, and 

(ii) The operating temperature. 

(8) For catalytic incinerators: 

(i) All periods where the temperature increase across the 

catalyst bed is less than 80% of the temperature increase 

recorded during the most re·cent performance test that 

demonstrated that the facility was in compliance, and 

(ii) The inlet and outlet temperatures and temperature rise 

across the catalyst bed. 

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19.6 Registration 

(9) For carbon adsorbers: 

(i) All 3-hour periods of operation during which the average 

voe concentration or reading of organics in the exhaust 

gases is more than 20 percent greater than the average 

exhaust gas concentration or reading measured by the 

organics monitoring device during the most recent 

determination of the recovery efficiency of the carbon 

adsorber that demonstrated that the facility was in 

compliance, and 

(ii) The pressure drop across the adsorber and the hydrocarbon 

levels for breakthrough. 

( d) Reporting. On and after the compliance dates specified in 

Subsection 19.8.5, the owner or operator of a subject coating line or 

operation referenced in Subsection 19 .5 .4 shall: 

(1) Notify the Director of any record showing noncompliance 

with the applicable requirements for control devices by sending a 

copy of the record to the Director within 30 calendar days 

following the occurrence, and 

(2) At least 30 calendar days before changing the method of 

compliance from control devices to the use of complying coatings 

or daily- weighted averaging, comply with all requirements of 

Subsections 19.5.3 or 19.5.2, respectively. Upon changing the 

method of compliance from control devices to the use of 

complying coatings or daily-weighted averaging, the owner or 

operator shall comply with all requirements of the section of this 

regulation applicable to the coating line or operation referenced in 

Subsection 19.5.4 

19.6.1 Any person who meets the applicability threshold in Subsection 19.2.l must 

register annually with the Office of Air Resources. No later than 45 days 

following the end of a calendar year, the following information must be submitted 

on forms supplied by the Director: 

(a) The name and address of the company and the name and telephone 

number of a responsible corporate official submitting the registration, and 

(b) A description of all operations in the facility where volatile organic 

compounds are emitted, and 

Page 21 of28 
(c) Quantities of coatings, solvents, dissolvers, viscosity reducers, 

diluents, thinners, reagents, cleaning agents, enamels, lacquers, or paints 

consumed during the calendar year of record, and 

( d) The amount of volatile organic compound per gallon of coating 

solution (pounds per gallon) for each coating, enamel, lacquer, or paint 

consumed at the facility during the calendar year of record. 

19. 7 Compliance Demonstrationff esting 

19. 7 .1 Compliance with emission limitations of Subsections 19 .3 .1 and 19 .3 .3 and 

Section 19.4 shall be demonstrated in accordance with 40 CFR 60, Appendix A, 

Methods 24, 24A, 25 as amended or any other EPA approved method which has 

been accepted by the Director. A one hour bake time must be used for Methods 

24 and 24A and, further, Methods 24 and 24A apply to multicomponent coatings. 

19.7.2 (Reserved for stack exhaust sampling techniques.) 

19.7.3 Facilities using add on controls to comply with RACT must show that the 

equipment meets specific capture and control efficiency limits which will be set 

in an enforceable document. Control efficiency of the equipment will be 

detennined using EPA-approved test methods. Calculations will be done on a 

solids applied basis. Continuous compliance will be maintained at all times. 

Compliance averaging times will be met according to the control device chosen 

and EPA test methods (as codified in 40 CFR 60), as follows: 

Compliance Method 

Reformulation 

Solvent destruction or 

solvent recovery except 

carbon adsorption 

Carbon adsorption 

EPA Reference Test 

Method 

24 

25 

25 or other test method as 

appropriate 

Test Averaging Time 

instantaneous 

3 hours 

The length of adsorption 

cycle or 24-hours, whichever is less. 

or other methods approved by the Director and EPA. Once the control efficiency has 

been determined for any add-on control device by Reference Method 25, or any 

alternative method approved by the Department and EPA, compliance shall be 

determined on an instantaneous basis time period (e.g. determined control efficiency shall 

be used to calculate whether samples from the process meet the applicable emissions 

limit.) 

19.8 Compliance Schedules 

19. 8 .1 Persons owning, leasing or controlling the operation of any surface 

coating facility and subject to the emission limitations set forth in Subsection 

19.3.1 shall achieve compliance according to the dates set forth in Subsection 

Page 22 of28 
19.8.5. Proposed plans and compliance schedules for paper, fabric, and vinyl 

coating facilities which have or have had actual emission of 100 tons ofVOC per 

year will be submitted to the Director no later than 1 March 1980. The Director 

may require other subject facilities to submit compliance schedules after review 

of initial compliance certification. 

19.8.2 All compliance schedules for process equipment replacement or 

modification or installation of control equipment shall provide for periodic 

increments of progress to document such, including but not limited to: 

(a) Submittal of engineering plans, 

(b) Ordering of equipment plan approval, 

(c) Installation date after confirmation of order by the manufacturer, and 

( d) Date by which the applicable regulatory emission limitations will be 

achieved after equipment is in satisfactory operation. 

19.8.3 All compliance schedules based upon reformulation shall provide for periodic 

increments of progress to document such, including but not limited to: 

(a) Submittal of research, engineering plans, and formulation, 

(b) Operating and maintenance procedures, 

( c) Schedules for research and development, 

( d) Purchase orders for reformulations, 

( e) Commencement and completion of process modifications, product 

marketability testing, and 

(f) Date by which regulatory emission limitations will be achieved. 

19.8.4 Any compliance schedule based on the provisions of Sections 19.3 and Section 

19.4 shall not allow a facility to supersede any applicable emission limitations 

including but not limited to: 

(a) Best Available Control Technology determinations, or 

(b) Lowest Achievable Emissions Rate determinations, or 

(c) Federal New Source Performance Standards, or National Emission 

Standards of Hazardous Air Pollutants, or 

( d) Any other condition or standard that is specifically required by the 

Page 23 of28 
Clean Air Act (as amended) for new or modified sources. 

(e) In the case ofa bubble issued under Section 19.4, the emission 

baseline as defined by Subsection 19.1.8 

19.8.5 Compliance schedules submitted in accordance with the requirements of 

Subsection 19.8.1 are subject to review and approval by the Director. 

Compliance shall be achieved as follows: 

(a) For paper, vinyl, and fabric coating facilities with actual emissions 

in excess of 100 tons per year prior to 1985, no later than July 1, 1985. 

(b) For paper, fabric, and vinyl coating facilities having actual 

emissions of 100 tons per year or more between July 1, 1985 and 

December 10, 1989, no later than one year after having become an actual 

100 ton per year source. 

(c) For paper, fabric and vinyl coating facilities having potential 

emissions in excess of 100 tons per year or more prior to 1990, no later 

than December 10, 1990. 

( d) For any surface coating facility covered by this regulation, which 

exceeds the applicability threshold in Subs.ection 19.2.1 on or after 

November 19, 1992 and which does not come under Subsections (a) 

through ( c) above, no later than May 31, 199 5. All coating lines 

commencing operation after November 19, 1992 must be in compliance 

with the emission limits specified in Section 19.3 upon commencing 

operation. 

19.9 General Provisions 

19.9.l Purpose 

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

compounds from surface coating operations. 

19.9.2 Authority 

These regulations are authorized pursuant to R.I. Gen. Laws§ 42-17.l-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 

Page 24 of28 
19.9 .3 1\pplieatioa. 

The teffftS aBS pro•Asions ohhis regH:latioe shall be lil:JeFa:Uy eonstraec4 to permit the 

Departmeet to effeemate the p:urposes of state law, goals aBG policies. 

19 .9 .4 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. 

19.9.5 Effective Date 

The foregoing regulation, "Control of Volatile Organic Compounds from Surface 

Coating 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 ofl 956, as 

amended. 

W. Michael Sullivan, PhD., Director 

Department of Environmental Management 

Notice Given on: February 21, 2007 

Public Hearing held: March 23, 2007] 

Filing Date: June 29, 2007 

Effective Date: July 19, 2007 

Page 25 of28 
APPENDIX A 

Procedure for Calculating the Daily-Weighted Averages 

1. The daily-weighted average voe content, in units of mass of VOe per unit volume of 

coating, excluding water and exempt compounds, as applied, of the coatings used on a 

day on a coating line or operation shall be calculated using the following equation: 

where: 

VOew = 

n = 

= 

= 

Vr = 

VOCw 

Vr 

The daily-weighted average VOC content of the coatings, as applied, used 

on a coating line or operation in units of pounds ofVOe per gallon of 

coating, excluding water and exempt compounds; 

The number of different coatings, as applied, each day on a coating line or 

operation; 

The volume of each coating (i), as applied, used in a day on a coating line 

or operation in units of gallons, excluding water and exempt compounds; 

The VOC content of each coating (i), as applied, used in a day on a 

coating line or operation in units of pounds voe per gallon of coating, 

excluding water and exempt compounds; and 

The total volume of all coating, as applied, used in a day on a coating line 

or operation in units of gallons, excluding water and exempt compounds. 

Page 26 of28 
2. The daily-weighted average voe content, as applied, of the coatings used on a coating 

line or operation in units of mass of voe per unit volume of coating solids shall be 

calculated by the following equation: 

where: 

VOCws = 

n = 

= 

Wvoci = 

VOCws 

n L Wvoc 1 D; Vi 

i=l 

The daily-weighted average voe content, as applied, of the coatings used 

on a coating line or operation in units of mass ofVOe per unit volume of 

coating solids; 

The number of different coatings, as applied, used in a day on a coating 

line or operation; 

The volume of each coating (i), as applied, used in a day on a coating line 

or operation in units of gallons, 

The weight fraction of voe in each coating (i), as applied, used in a day 

on a coating line or operation in units of pounds voe per pound of 

coating; 

The density of each coating (i) as applied, used in a day on a coating line 

or operation in units of pounds voe per gallon of coating (lb/gal); and 

The volume fraction solids content of each coating (i), as applied, used in 

a day on a coating line or operation in units of gallons solids/gallons 

coating. 

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