**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 MANUFA CTURING OPERATIONS** 

Effective 7 March 1996 Last Amended 19 July 2007

AUTHORI TY: These regulations are authorized pursuant to R.I . Gen. Laws § 42

- 17.1

- 2(s) and 23

- 23 , as amended, and have been promulgated pursuant to the procedures set forth in the R.I . Administrative Procedures Act, R.I . Gen. Laws Chapter 42

- 35.RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO. 35
CONTROL OF VOLATILE ORGANIC COMPOUNDS AND VOLATILE HAZARD OUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING OPERATIONS

35.1 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

35.5 Work Practice Standards

................................ ................................ ................................ .... 12

35.6 Complianc e Procedures and Monitoring Requirements

................................ ........................ 19

35.7 Recordkeeping and Reporting

................................ ................................ ............................ 25

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

SOLVENTS

................................ ................................ ................................ ................. 43Page 1 of 45

**RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE**  **OF AIR RESOURCES AIR POLLUTION CONTROL REGULATION NO. 35**  **CONTROL OF VOLATILE ORGANIC C OMPOUNDS AND**  **VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS**

**MANUFACTURING OPERATIONS**

**35.1 Definitions**  Unless otherwise expressly defined in this section, the terms used in this regulation shall be defined by

reference to the Rhode I sland Air Po llution 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.
35.1. 2 **"Alternative method** " means a method of sampling and analy zing for an air pollutant that is not a reference or equivalent EPA sampling method but that has been d emonstrated to the EPA's satisfaction to, in specific cases, produce results adequate for a determination of compliance.
35.1. 3

. **"As applied"** means the VOC, VHAP and solids content of the coating material as it is used for coating the substrate, including the contribution of thinners.
35.1. 4

. **"Basecoat"** means a coat of colored material, usually opaque, that is applied before graining inks, glazing coats, or other opaque finishing materials and is usually topco ated for protection.
35.1. 5

. **"Capture device"** means a hood, enclosed room, floor sweep, or other means of collecting solvent emissions or other pollutants into a duct so that pollutants can be directed to a pollution control device such as an incinerator or a carbon adsorber.
35.1. 6

. **"Capture efficiency"** means the fraction of all organic vapors generated by a process that are directed to a control device.
35.1. 7

. **"Certified product data sheet" or "CPDS"**  means documentation furnished by a coating supplier or an outside laboratory that provides the VHAP content, VOC content, solids content, and density of a finishing material, strippable booth coating, adhesive, or solvent, measured using EPA Methods 24 and 311, or an equivalent or alternative method (or formulation data if the coating meets thePage 2 of 45 criteria specified in Subsection 35.8.1(b)). The purpose of the CPDS is to assist the facility

in demonstrating compliance with the emission limit ations presented in Sections 35.3, 35.4 and 35.5 of this regulation. Therefore, the VOC and VHAP content should represent the maximum VOC and VHAP emission potential of the finishing material, strippable booth coating, or solvent.
35.1. 8

. **"Cleaning operations"** means operations in which organic solvent is used to remove coating materials from equipment used in wood products manufacturing operations.
35.1. 9

. **"Coating"** means a protective, decorative, or functiona l material applied in a thin lay er to a surface. Such materials include, but are not limited to, paints, topcoats, varnishes, sealers, stains, washcoats, basecoats, adhesives, inks, enamels, and temporary

protective coatings.
35.1. 10 **"Coating solids or solids** " means the part of a coating that remains after the coating is dried or cured; solids content is determined using data from EPA Method 24.
35.1. 11 **"Compliant coating"** means a finishing material, adhesive, or strippable booth coating that meets applicable emission limitations specified in Section 35.3 and 35.4 of this regulation.
35.1. 12 **"Contact adhesive"** means an adhesive that is applied to two substrates, dried, and mated under only enough pressure to result in good contact. The bond is immediate and sufficiently strong to hold pieces together without further clamping, pressure, or airing.
35.1. 13 **"Continuous coater"** means a finishing sy stem that continuously applies finishing materials onto wood parts moving along a convey or sy stem. Finishing materials that are not transferred to the part are recycled to the finishing material reservoir. Several ty

pes of application methods can be used with a continuous coat er including spraying, curtain coating, roll coating, dip coating, and flow coating.
35.1. 14

. **"Continuous compliance"** means that the facility is meeting the applicable emission limitations and other applicable requirements of this re gulation at all times and is fulfilling all monitoring and recordkeeping provisions of the regulation in order to demonstrate compliance.
35.1. 15

. **"Control device"** means any equipment that reduces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent recovery . Control devices include, but are not limited to, incinerators, carbon adsorbers, and condensers.Page 3 of 45

35.1. 16

. **"Control device efficiency"** means the ratio of the amount of pollutant released by a control device to the amount of pollutant introduced to the control device, expressed as a fraction.
35.1. 17

. **"Control system"** means the combination of capture and control devices u sed 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 (ga uge) at the point of atomization. Airless, air assisted airless, and electrostatic spray technologies are not considered conventional air spray methods.
35.1. 19

. **"Day"** means a period of 24 consecutive hours beginning at midnight loc al time, or beginning at a time consistent with a facility 's operating schedule.
35.1. 20 **. "Disposed offsite"** means sending used organic solvent or coatings outside of the facility

boundaries for disposal.
35.1. 21

. **"Emission"** means the release or discharge, directly or indirectly , of one or more air pollutants into ambient air.
35.1. 22

. **"Enamel"** means a coat of colored, usually opaque material that is applied as a protective topcoat over a basecoat, primer, or previously applied enamel coats. In some cases, another finishing material may be applied as a topcoat over the enamel.
35.1. 23 **"Equipment leak"** means emissions of VOC or VHAP from pumps, valves, flanges, or other equipment used to transfer or apply finishing materials, adhesives, or organic solvents.
35.1. 24 **"Equivalent method** " means a method of sampling and analy zing for an air pollutant that EPA has determined to have a consistent and quantitatively known relationship to the refer ence method, under specific conditions.
35.1. 25 **"Filler"** means a finishing material which is applied to a wood surface primarily to build up, or fill the voids and imperfections in, the wood surface to be coated. Edge filler is included in this definitio n. 35.1. 26 **"Finishing application station"** means the part of a finishing operation where the finishing material is applied, e.g., a spray booth.
35.1. 27 **"Finishing material"** means a coating other than an adhesive. For the wood products manufacturing ind ustry , such materials include, but are not limited to, basecoats, stains, washcoats, enamels, sealers, and topcoats.Page 4 of 45

35.1. 28 **"Finishing operation"** means those activities in which a finishing material is applied to a substrate and is subsequently air

- dried , cured in an oven, or cured by radiation.
35.1. 29 **"Foam adhesive"** means a contact adhesive used for gluing foam to fabric, foam to foam, and fabric to wood.
35.1. 30 **"Gluing operation"** means those operations in which adhesives are used to join components , for example to apply a laminate to a wood substrate or foam to fabric.
35.1. 31 **"High**
**- solids stains"**  means stains containing more than one pound of solids per gallon and includes wiping stains, glazes, and opaque stains.
35.1. 32 **"Incinerator"** means an e nclosed combustion device that thermally oxidizes volatile organic compounds to CO and CO 2 . This term does not include devices that burn municipal or hazardous waste material.
35.1. 33 **"In** k" means a fluid that contains dy es and/or colorants and is used t o make markings, but not to protect surfaces.
35.1. 34 **"Low**
**- solids stains"**  means stains containing one pound of solids per gallon, or less.
35.1. 35 " **Major source of Hazardous Air Pollutants"** means a facility that emits or has the potential to emit, in the aggregate, 10 tons per y ear (tpy ) or more of any Hazardous Air Pollutant (HAP), 25 tpy or more of any

combination of HAPs, or such lesser quantity

as the EPA may

establish by

rule.
35.1. 36 **"Malfunction"** means any sudden, infrequent, and not reasonably p reventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.
35.1. 37 **"Multi**
**- colored coating**  **"** means a coating which exhibits more than one color when applied, and which is packaged in a single container and applied as a single coat. 35.1. 38 **"Nonpermanent final finish"** means a material such as a wax, polish, nonoxidizing oil, or similar substance that must be periodically reapplied to a surface over its lifetime to maintain or restore the reapplied material's intended effect.
35.1. 39 **"Operating day"** means a day , or any part of a day , in which a facility isPage 5 of 45 engaged in manufacturing.
35.1. 40 **"Oper ating parameter value"**  means a minimum or maximum value established for a control device or process parameter that, if achieved by itself or in combination with one or more other operating parameter values, determines that an owner or operator has complied with an applicable emission limitation.
35.1. 41 **"Organic solvent"** means a liquid containing VOC that is used for dissolving or dispersing constituents in a coating, adjusting the viscosity of a coating, cleaning, or washoff. When used in a coating, the organic solvent evaporates during drying and does not become a part of the dried film.
35.1. 42 **"Overall control efficiency"** means the efficiency of a control sy stem, calculated as the product of the capture and control device efficiencies, expressed as a percentage. 35.1. 43 **"Permanent total enclosure"** means a permanently installed enclosure that completely

surrounds a source of emissions such that all emissions are captured and contained for discharge through a control device. The enclosure must meet app licable EPA criteria.
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.
3 5.1. 45 **"Recycled onsite"** means the reuse of an org anic solvent at the facility in a process other than cleaning or washoff.
35.1. 46 **"Sealer"** means a finishing material used to seal the pores or grains of a wood substrate before additional coats of finishing material are applied. Washcoats, which are use d in some finishing sy stems to optimize aesthetics, are not sealers.
35.1. 47 **"Shutdown"** means the cessation of operation of wood products manufacturing operations for any

purpose. 35.1. 48 **"Solvent"** means a liquid used in a coating for dissolving or dispe rsing constituents in a coating, adjusting the viscosity of a coating, cleaning, or washoff. When used in a coating, it evaporates during drying and does not become a part of the dried film.
35.1. 49 **"Stain"** means any color coat having a solids content by weight of not more than 8.0 percent that is applied in single or multiple coats directly to the substrate. Stains include, but are not limited to, nongrain raising stains, equalizer stains, prestains, sap stains, body stains, no

- wipe stains, penetrating s tains, and toners.Page 6 of 45

35.1. 50 **"Startup"** means the setting in operation of wood products manufacturing operations for any

purpose. 35.1. 51 **"Strippable booth coating"** means a coating that: (1) is applied to a booth wall to provide a protective film to receiv e overspray during finishing operations; (2) is subsequently

peeled off and disposed; and (3) by achieving (1) and (2), reduces or eliminates the need to use organic solvents to clean booth walls.
35.1. 52 **"Substrate"** means the surface onto which coatings are applied or into which coatings are impregnated.
35.1. 53 **"Thinner"** means a volatile liquid that is used to dilute coatings to reduce viscosity , color strength, and solids, or to modify drying conditions.
35.1. 54 **"Toner"** means a stain which contains bi nders and dy es or pigments to add tint to a coated surface or to even the color of an initial application of stain.
35.1. 55 **"Topcoat"** means the last film

- building finishing material applied in a finishing sy stem. 35.1. 56 **"Touch**
**- up and repair"**  means the a pplication of finishing materials to cover minor finishing imperfections.
35.1. 57 **"Volatile Hazardous Air Pollutant"** and "VHAP" means any of the substances listed in Table 1.
35.1. 58 **"Washcoat"** means a transparent special purpose coating having a solids content by weight of 12.0 percent or less. Washcoats are applied over initial stains to protect and control uniformity of color, to stiffen the wood fibers, to prepare the wood surface for sanding, and to partially seal the wood from subsequent staining o perations.
35.1. 59 **"Washoff operations"** means those operations in which organic solvent is used to remove coating from a substrate.
35.1. 60 **"Wood products facility"** means a facility which is engaged in coating the surface of products manufactured of wood or wood products, including, but not limited to, particle board, reed, rattan and wicker. Wood product coating does not include coating of flat wood panels, as defined in Air Pollution Control Regulation No. 19.
35.1. 61 **"Wood products manufacturing oper ations"**  means the finishing, gluing, cleaning and washoff operations conducted at a wood products facility

.Page 7 of 45

**35.2 Applicability**  35.2.1 The provisions of this regulation apply to any wood products facility

which has the potential to emit 25 tons per y ear or more of volatile organic compounds (VOC) from wood products manufacturing operations or which is located at a major source of Hazardous Air Pollutants (HAP).
35.2.2 The owner or operator of a wood products facility which has emissions below the applic ability

thresholds specified in Subsection 35.2.1 but above 15 pounds of VOC in any

day shall comply

with the recordkeeping and reporting requirements in Paragraphs (a) and (c) of Subsection 35.7.1 but the facility shall not be subject to any other provisi ons of this regulation. I f the facility becomes subject to the regulation at a future date due to an increase in emissions of VOC or VHAP, the facility shall be subject to applicable requirements in this regulation on and after the date that the applicabi lity thresholds are reached or the date that the applicable requirement becomes effective, whichever is later.
35.2.3 Where ever the term Volatile Organic Compound or VOC is used in Sections 35.2 through 35.8 and Subsections 35.1.3, 35.1.7, 35.1. 23 , and 35.1. 41 , this term should be read as Volatile Organic Compound and Halogenated Organic Compound or VOC and HOC.
35.2.4 The owner or operator of a facility which is a major source of Hazardous Air Pollutants (HAP) but which has not emitted more than 10 to ns of any one HAP or more than 25 tons of any

combination of HAP, including emissions from source categories other than wood products, in any 12 month period since December 1994 may apply to the Director for an exemption from the VHAP emissions limitations in Subsections 35.3.2, 35.3.3, 35.4.2 and 35.4.3 of this regulation. Exemption will be given in the form of an enforceable document, and will include the following conditions: (a) Average monthly

emissions from the facility in any consecutive twelve m onth period shall not exceed 1,666 pounds of any one HAP or 4,166 pounds of any

combination of HAP; and (b) The following records shall be maintained at the facility for a period of five y ears and made available to the Department or the EPA upon request : (1) The name, identification number, and amount of each finishing, gluing and washoff material used each month at the facility ; and (2) Certified Product Data Sheets showing the VOC and VHAP content of each finishing, gluing, and washoff material used at the facility ; andPage 8 of 45 (3) The ty

pe and amount of solvent used as thinners and in cleaning operations each month at the facility ; (4) The average monthly emissions of each HAP from the facility , calculated monthly

for the previous twelve month period. (c) If the limit in Paragraph 35.2.4.(a) is exceeded, applicable VHAP emission limitations specified in Sections 35.3 and 35.4 shall immediately apply

.

**35.3 Emission Limitations for Finishing Operations**  35.3.1 VOC Emission L imitations for Fi nishing Operations (a) On and after March 7, 1996, the owner or operator of a facility subject to this regulation which has the potential to emit greater than or equal to 25 tons per y ear of volatile organic compounds (VOC) shall limit VOC emissions fro m wood products finishing operations by : (1) Using finishing materials which comply with the emissions limitations in pounds of VOC per gallon of coating minus water and exempt compounds listed in Table 2; or (2) Using a control sy stem that achieve s the emissions limitations in pounds of VOC per pound of solids listed in Table 2; or (3) Using finishing materials with a weighted average VOC content, within a particular category of coatings as identified in Table 2, which conforms with the provisi ons specified in Subsection 35.6.2(a); or (4) Using a combination of the methods presented in Paragraphs 35.3.1(a)(1), 35.3.1(a)(2), and 35.3.1(a)(3) which is approved by the Department

.Page 9 of 45 Table 2. Emissions L imitations for Finishing Materials COATI NG CATEGORY lbs VOC/ gal coating minus water and exempt compounds lbs VOC/

lb solids

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, t oners and washcoats containing HOC 4.0 0.9

low

- solids stains, toners and washcoats not containing HOC 6.7 7.5

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) Inaddition to complying with the limitations in Table 2, on and after March 7, 1998, the owner or operator of a facility subject to this regulation which has the potential to emit greater than or equal to 25 tons per y ear of VOC shall: (1) 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 sy stem that achieves equivalent reductions in VOC emissions from topcoats and sealers. (c) A facility

subject to the emissions limits in Table 2 may be required, at the discretion of the Department , to undergo a review every two ye ars toPage 10 of 45 determine whether the limitations in Paragraphs (a) and (b) of this subsection represent Reasonably Available Control Technology (RACT) for the finishing operations at that facility at that time. Facilities shall comply with emissions limitation s determined to be RACT within one ye ar of that determination and shall thereafter operate in compliance with those limitations.
35.3.2 VHAP Emission L imitations for Finishing Operations at Existing Facilities (a) On and after March 7, 1998, the owner or operator of a facility subject to this regulation which is a major source of HAP and which began operations before December 6, 1994 shall limit VHAP emissions from wood products finishing operations by : (1) Using stains, washcoats, sealers, topcoat s, basecoats, and enamels with VHAP contents no higher than 1.0 lb VHAP/lb solids, as applied; thinners for stains, sealers, and topcoats that contain no more than 10% VHAP by weight; and thinners for washcoats, basecoats and enamels that contain no more than 3% VHAP by weight; or (2) Using finishing materials with a weighted average VHAP content of no greater than 1.0 lb VHAP/lb solids, as applied, calculated using the procedures in Subsection 35.6.2(b), and thinners with VHAP contents as specified in Paragraph 35.3.2(a)(1); or (3) Using a control sy stem that achieves a reduction in emissions equivalent to that which would be achieved by complying with the requirements of Paragraph (1) or (2) of this subsection, calculated according to the procedure s in Subsection 35.6.3(c) of this regulation; or (4) Using a combination of the methods presented in Paragraphs (1) and (3) of this subsection which is approved by the Department

. (b) The formaldehy de content of a finishing material shall be calculated as the amount of free formaldehyde present in the finishing material when it is applied. (c) The sty

rene content of a finishing material shall be based on an estimate of unreacted sty

rene, which shall be calculated by multiplying the amount of sty re ne monomer in the finishing material when it is applied by a factor of 0.16.Page 11 of 45

35.3.3 VHAP Emission L imitations for Finishing Operations at New Facilities (a) On and after March 7, 1996, the owner or operator of a facility subject to this regulation whi ch is a major source of HAP and began operation on or after December 6, 1994 shall limit VHAP emissions from wood products finishing operations by : (1) Using stains with VHAP contents no greater than 1.0 lb VHAP/lb solids, as applied; washcoats, sealer s, 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 thinners for washcoats, basecoats and enamels that contai n no more than 3% VHAP by weight; or (2) Using finishing materials with a weighted average VHAP content of no greater than 0.8 lb VHAP/lb solids, as applied, calculated using the procedures in Subsection 35.6.2(b), and thinners with VHAP contents as sp ecified in Paragraph 35.3.3(a)(1); or (3) Using a control sy stem that achieves a reduction in emissions equivalent to that which would be achieved by complying with the requirements of Paragraph (1) or (2) of this subsection, calculated according to th e procedures in provisions in Subsection 35.6.3(c) of this regulation; or (4) Using a combination of the methods presented in Paragraphs (1) and (3) of this subsection which is approved by the Department

. (b) The formaldehy de content of a finishing material shall be calculated as the amount of free formaldehyde present in the finishing material when it is applied. (c) The sty

rene content of a finishing material shall be based on an estimate of unreacted sty

rene, which shall be calculated by multip lying the amount of sty rene monomer in the finishing material when it is applied by a factor of 0.16.Page 12 of 45

**35.4 Emission Limitations for Cleaning and Gluing Operations**  35.4.1 VOC Emission L imitations 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 L imitations for Existing Gluing Operations On and after March 7, 1996, the owner or operator of a f acility subject to this regulation which is a major source of HAP and which began operation before December 6, 1994 shall limit VHAP emissions from contact adhesives used in gluing operations as follows: (a) For foam adhesives used in products that mee t the upholstered seating flammability

requirements of California Technical Bulletin 116, 117, or 133, the Business and Institutional Furniture Manufacturers Association's (BIFMA's) X5.7, UFAC flammability testing, or any

similar requirements from local, S tate, or Federal fire regulatory agencies, the VHAP content of the adhesive shall not exceed 1.8 lb VHAP/lb solids, as applied; (b) For all other contact adhesives, including foam adhesives used in products that do not meet the standards presented in Paragraph (a) of this subsection, the VHAP content of the adhesive shall not exceed 1.0 lb VHAP/lb solids, as applied; or (c) By

using a control sy stem that will achieve a reduction in VHAP emissions equivalent to that which would be achieved by complying with the requirements of Paragraph (b) of this subsection, as calculated using the procedures in Subsection 35.6.3(d) of this regulation.
35.4.3 VHAP Emission L imitations for New Gluing Operations On and after March 7, 1996, the owner or operator of a facility subject to this regulation which is a major source of HAP and which began operation on or after December 6, 1994 shall not use contact adhesives which have VHAP contents higher than 0.2 lb VHAP/lb solids, as applied or shall use a control sy stem that achieves an equivalent reduction in emissions of VHAP, as calculated using the procedures in Subsection 35.6.3(d).
**35.5 Work Practice Standards**  The owner or operator of a facility subject to this regulation shall implement the following work practi ce standards by March 7, 1996, except where another date is specified.Page 13 of 45

35.5.1 Work Practice I mplementation Plan (a) The owner or operator of a facility subject to this regulation shall prepare and maintain a written work practice implementation plan t hat defines work practices for each wood products manufacturing operation and addresses each of the topics specified in Subsections 35.5.2 through 35.5.10. (b) The work practice implementation plan shall be developed by May 6, 1996 and shall be subject to the approval of the Department

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

with each provision of the work practice implementation plan. (d) The work practice implementation plan shall be available for inspection by the EPA or the Department upon request and shall be modified by the facility if found to be inadequate.
35.5.2 Operator Training Course (a) Each owner or operator of a facility subject to this regulation shall train all new and existing personnel, including contract per sonnel, who are involved in finishing, gluing, cleaning, or washoff operations, use of manufacturing equipment, or implementation of the requirements of this regulation. (b) All personnel shall be trained by November 6, 1996, or upon hiring, whichever i s later. All personnel shall be given refresher training annually

. (c) In itial and refresher trainings shall include, at a minimum, the following topics: (1) Appropriate application techniques; (2) Appropriate cleaning and washoff procedures; (3) Appropriate equipment setup and adjustment to minimize finishing material usage and overspray ; and (4) Appropriate management of cleanup wastes. (d) The facility

shall maintain records of the training program. Records shall include, at a min imum, the following:Page 14 of 45 (1) A list of all current personnel by name and job description who are required to be trained and a record of the date that each employee was trained; (2) An outline of the subjects covered in the initial and refresher trainin g for each position, or group of personnel; (3) Lesson plans for courses to be given at the initial and the annual refresher training that include, at a minimum, the topics specified in Paragraph (c) of this subsection; and (4) A description of the methods to be used to demonstrate successful completion of initial and refresher training.
35.5.3 Equipment Operation, Maintenance, Inspection and Repair (a) Equipment L eak I nspection and Repair (1) After March 6, 1996, all equipment used to transfer or apply finishing materials, adhesives, or organic solvents shall be visually inspected for leaks at least once per month. (2) A first attempt at repair shall be made no later than 3 calendar day s after a leak is detected and final repairs sha ll be made within 10 calendar day s, unless the leaking equipment is to be replaced by a new purchase, in which case repairs shall be completed within 3 months. (3) Each owner or operator of a source subject to this regulation shall prepare and maintain a written leak inspection and maintenance plan that includes: (i) A schedule for conducting visual inspections required in Paragraph (a) of this subsection; and (ii) A log documenting the date and results of each inspection and any repairs that are made. (b) Operation and Maintenance Requirements (1) At all times, including periods of startup, shutdown, and malfunction, owners or operators shall operate and maintain any equipment associated with wood products manufacturing operations, incl uding associated air pollution control equipment, in a manner consistent with good air pollution control practices forPage 15 of 45 minimizing emissions. (2) Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startu p, shutdown, and malfunction plan required in Paragraph (b)(4) of this subsection. (3) The Department will determine whether acceptable operation and maintenance procedures are being used, based on information which may

include, but is not limited to, monitoring results, review of operation and maintenance procedures (including the startup, shutdown, and malfunction plan required in Paragraph (b)(4) of this subsection), review of operation and maintenance records, and inspection of the facility

. (4) The owner or operator of a facility subject to this regulation shall develop and implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining equipment associated with wood products manufa cturing operations during periods of startup, shutdown, and malfunction and a program of corrective action for malfunctioning process and air pollution control equipment used to comply with this regulation. The facility 's standard operating procedures (SO P) manual, an Occupational Safety and Health Administration (OSHA) or another plan can be used to fulfill this requirement, provided the plan meets all the requirements of this paragraph. Startup, shutdown, and malfunction plans shall be maintained at the facility

and made available to the Department or the EPA for review upon request and shall be revised if determined to be unacceptable. (5) During periods of startup, shutdown, and malfunction, the owner or operator of a facility

subject to this r egulation shall operate and maintain equipment associated with wood products manufacturing operations (including associated air pollution control equipment) in accordance with the procedures specified in the startup, shutdown, and malfunction plan develope d according to the provisions of Paragraph (b)(4) of this subsection. (6) The owner or operator of a facility subject to this regulation shall keep records of action taken during startups, shutdowns, and malfunctions, including actions taken to correct malfunctions and shall certify , in the semi

- annual reports required in Subsection 35.7.7, that all such actions were consistent with the procedures specified in the facility 's startup, shutdown and malfunction planPage 16 of 45 developed under Paragraph (b)(4) of this subsection

. (7) If actions taken by the owner or operator during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) are not consistent with the procedures specified in the facility 's startup, shutdown, and malfunc tion plan, the owner or operator shall record the actions taken and report such actions to the Office of Air Resources within 2 working day s after beginning actions inconsistent with the plan, followed by a letter within 7 working day s after the end of the event. (8) If a malfunction occurs that was not adequately addressed in the startup, shutdown, and malfunction plan, the owner or operator shall revise the plan within 45 day s after the event to include detailed procedures for operating and maintainin g the source during similar malfunction events and a program of corrective action for similar malfunctions of process or air pollution control equipment.
35.5.4 Cleaning and Washoff Solvent Requirements (a) The owner or operator of a facility subject to this regulation shall account for organic solvent use in cleaning and washoff operations by recording the following information: (1) The quantity

and ty pes of organic solvent used in washoff and cleaning operations each month; (2) The number of pieces washed off, and the reason for the washoff; and (3) The quantity

of spent organic solvent generated from each washoff and cleaning activity

each month, and whether it is recycled onsite or disposed offsite. (b) Facilities subject to this regu lation shall not use cleaning or washoff solvents that contain any

of the pollutants listed in Table 3 in concentrations greater than 0.1%.Page 17 of 45

35.5.5 Spray

Booth Cleaning Facilities subject to this regulation shall not use compounds containing more than 8 .0 percent by

weight of VOC for cleaning spray booth components other than convey ors, continuous coaters and their enclosures, or metal filters, unless the spray booth is being refurbished. I f the spray

booth is being refurbished, that is, the spray booth coating or other material used to cover the booth is being replaced, the facility shall use no more than 1.0 gallon of organic solvent per booth to prepare the booth prior to applying the booth coating.
35.5.6 Storage Requirements All finishing, gluin g, cleaning, and washoff materials shall be stored in containers that are closed at all times except when material is being added or removed.
35.5.7 Application Equipment Requirements Conventional air spray

guns shall not be used to apply finishing mat erials, except in the following situations: (a) When applying finishing materials before March 6, 1998 at a facility which is not a major source of HAP or which began operation prior to December 6, 1994; (b) When applying finishing materials that hav e a VOC content no greater than 1.0 lb VOC/lb solids, as applied; (c) Touch

- up or repair that occurs after the completion of a finishing operation; (d) Touch

- up or repair that occurs after the stain and before any other ty pe of finishing material is applied, provided that the touch

- up finishing materials are applied from a container that has a volume of no more than 2.0 gallons; (e) If the spray

gun is aimed and triggered automatically , not manually ; (f) If emissions from the finishing applicati on station are directed to a control device; (g) For application of a finishing material if the total usage of that finishing material is no more than 5.0 percent of the total gallons of all finishing materials used at that facility during that semi

- annual reporting period, as specified in Subsection 35.7.7(a).; orPage 18 of 45 (h) The application of stain on a part for which it is technically or economically

infeasible to use any

other spray

application technology

. The facility

must demonstrate technical or econ omic infeasibility by submitting documentation to the Department that the following criteria, either independently

or in combination, are met: (1) The production speed is too high or the part shape is too complex for one operator to coat the part and the application station is not large enough to accommodate an additional operator; or (2) The excessively

large vertical spray

area of the part makes it difficult to avoid sagging or runs in the stain.
35.5.8 Li ne Cleaning All organic solvent used f or 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 a t all times except when material is being added or removed.
35.5.10 Washoff operations Emissions from washoff operations shall be controlled by : (a) Using tanks for washoff that are closed at all times except when material is being added or removed ; and (b) Minimizing dripping by tilting or rotating the part to drain as much organic solvent as possible.
35.5.11 Formulation Assessment Plan Each owner or operator of a facility that is subject to this regulation and that is a major source of Ha zardous Air Pollutants shall prepare and maintain a formulation assessment plan that: (a) Li sts all VHAP from Table 1 that are being used in finishing operations at the facility

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

for each VHAP as follows:Page 19 of 45 (1) The baseline usage level shall be the annual usage from the calendar y ear 1994 for each VHAP; (2) For formaldehy de, the baseline level of usage shall be based on the amount of free formaldehyde present in the finishing material whe n it is applied; (3) For sty

rene, the baseline level of usage shall be an estimate of unreacted sty

rene, which shall be calculated by multiplying the amount of sty

rene monomer in the finishing material when it is applied by

a factor of 0.16; and (4 ) Facilities using a control device to reduce emissions may adjust their baseline usage based on the overall control efficiency of the control sy stem, calculated using Equation 5 in Paragraph 35.6.3(c). (5) The baseline levels for a VHAP that was not u sed in 1994 shall be established as 20% of the Reportable Quantity for that substance specified in Table I II of Regulation No. 22. (c) Tracks the annual usage of each VHAP used by the facility

. (d) If, beginning with the calendar y ear 1998, the usage of a VHAP in any ye ar exceeds its baseline level, then the owner or operator of the facility shall provide a written notification to the Division by 31 January

of the following y ear that specifies the amount of the increase and explains the reasons for th e increase. The Department will determine whether the increase would cause an exceedance of the Acceptable Ambient Levels specified in Air Pollution Control Regulation No. 22. I f Regulation No. 22 limits are exceeded, the Department will develop a timeta ble for the facility to achieve compliance and a schedule for submitting notification of progress.

**35.6 Compliance Procedures and Monitoring Requirements**  35.6.1 Compliance Using Compliant Coatings Compliance with the emissions limitations in Sections 35.3 and 35.4 of this regulation through the use of compliant coatings shall be demonstrated by the following methods: (a) Maintaining Certified Product Data Sheets (CPDS) documenting that the VOC and/or VHAP content of each topcoat, filler, stain, ton er, ink, multi

colored coating, pigmented coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth coating meets the applicablePage 20 of 45 emissions limitations in Sections 35.3 and 35.4 in lb VOC/gallon of coating or lb VHAP/lb of solids; and (b) Maintaining formulation data and related calculations showing that the VOC and VHAP content of each topcoat, filler, stain, toner, ink, multi

colored coating, sealer, washcoat, enamel, basecoat, adhesive and strippable booth coating diluted onsi te, as applied, meets the applicable emissions limitations in Sections 35.3 and 35.4 in lb VOC/gallon of coating or lb VHAP/lb of solids; and (c) For facilities with continuous coaters, using one of the following procedures: (1) Calculating the VOC and VHAP content, as applicable, of the finishing material in the reservoir from information on the CPDS and records of materials added to the reservoir; or (2) Monitoring the viscosity of the finishing material in the reservoir with a viscosity

meter or testing the viscosity of the initial finishing material and retesting the material in the reservoir each time solvent is added. I f this option is chosen, the facility shall maintain data that demonstrates the correlation between the viscosity of the fi nishing material and the VOC and VHAP content, as applicable, of the finishing material; and (d) The Department or EPA will determine compliance either by reviewing the records specified in Paragraphs (a), (b) and (c) of this subsection or by conducting a performance test according to the specifications in Subsections 35.8.1 and 35.8.2. I f the VOC or VHAP content of a coating determined by

a performance test using the procedures specified in Subsections 35.8.1 and 35.8.2 is greater than that indicated o n a CPDS or by the facility 's formulation or viscosity data, the performance test results shall govern.
35.6.2 Compliance Using Averaging (a) To demonstrate compliance with the VOC emission limitations in Subsection 35.3.1 for a particular coating cat egory through the use of averaging, the owner or operator of a facility shall, each week: (1) Calculate the average VOC content for all coatings in that category used at the facility

using Equation 1: n n E voc = ( ∑ V i Ci ) /  V i Equation 1 i=I i=IPage 21 of 45 Where: E VOC = the average VOC content of coatings in a particular coating

category , in lb VOC/gal coating, as applied; C = the VOC content of a coating in the coating category , in lb VOC/gal co ating minus water and exempt compounds, as applied; i = subscript denoting an individual coating; V = the volume of coating, in gallons, as applied, of a particular coating in the coating category used during the weekly

averaging period; (2) Demonstrate that the value calculated for E VOC 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 compli ance with the VHAP emission limitations in Subsections 35.3.2 and 35.3.3 through the use of averaging, the owner or operator of a facility

shall, each month: (1) Calculate the average VHAP content for all finishing materials used at the facility

using Equation 2:

n n n E VHAP = (  M i C 1 +  S i W i ) /  M i Equation 2 i=1 i=1 i=1 Where: E VHAP = the average VHAP content of finishing materials, in lb VHAP/lb

s olids; C = the VHAP content of a coating, in lb VHAP/lb solids, as applied; i = subscript denoting an individual coating; M = the mass of solids, in pounds, in a particular finishing material used during the monthly averaging peri od; S = the VHAP content of a solvent, expressed as a weight fraction, added to finishing materials; andPage 22 of 45 W = the amount of solvent, in pounds, added to finishing materials during the monthly averaging period. (2) Demonstrate that the value calculated for E VHAP is no greater than 1.0 if the facility

is complying with Subsection 35.3.2 and is no greater than 0.8 if the facility is complying with Subsection 35.3.3.
35.6.3 In itial Compliance Using Control Equipment (a) The owner or op erator of a facility which uses control equipment to comply with the VOC emission limitations in Table 2 or the VHAP limitations in Subsections 35.3.3 and/or 35.4.3 shall conduct an initial performance test to measure the capture and control efficiency of the control sy stem using the procedures specified in Subsection 35.8.3 by June 4, 1996. I nitial performance tests for control equipment which is being used to comply

with the VHAP emission limitations in Subsections 35.3.2 and/or 35.4.2 or the VOC emissio ns limitations for sealers and clear topcoats in Paragraph 35.3.1(b) shall be conducted by September 8, 1998. (b) In itial compliance with VOC emission limitations for finishing materials through the use of a control sy stem shall be determined as follows : (1) Calculate the overall control efficiency needed (R

n ) for each finishing material which will be controlled by the control equipment using the following equation:
R n = [(C

- EL)/C](100) Equation 3 Where: R

n = the overall efficiency of the control sy stem needed, expressed as a percentage. C = the VOC content of a coating, in lb VOC/lb solids, as applied; EL = the emission limitation required for the coating, from Table 2, in lb VOC/lb solids. (2) Document that the value of C used in Equation 3 was calculated from the VOC and solids content of the as

- applied finishing material. (3) Demonstrate, for all applicable coatings, that the value of R n calculated using Equation 3 is less than or equal to the actual overall cont rol efficiency (R a ) calculated by

substituting the capture efficiency

(N) and control efficiency (F) of the control sy stem measured in the initial performance test into Equation 4.Page 23 of 45 R a = (F x N)(100) Equation 4 (c) In itial compliance with VHAP em ission limitations for finishing materials through the use of a control sy stem shall be determined as follows: (1) Calculate the overall control efficiency needed, R

n , so that the value of E ac in Equation 5 is no greater than 1.0 if complying with Subs ection 35.3.2 and so that the value of E ac in Equation 5 is no greater than 0.8 if complying with Subsection 35.3.3;
R n = (100)(E bc - E ac )/E bc Equation 5 Where: R

n = the overall efficiency

of the control sy stem needed, expressed as a perce ntage;
E ac = emissions from an emission point or a set of emission points after control equipment is in operation, in lb VHAP/lb solids; and
E bc = emissions from an emission point or set of emission points before controls, calculated as E VHAP in Equation 2. (2) Demonstrate that the value of R n calculated using Equation 5 is less than or equal to the actual overall control efficiency (R a ) calculated using the capture efficiency (N) and control efficiency (F) of the control sy stem measured in th e initial performance test and Equation 4. (d) In itial compliance with VHAP emission limitations for gluing materials through the use of a control sy stem shall be determined as follows: (1) Calculate the overall control efficiency of the control sy s tem needed (R

n ) so that the value of G ac in Equation 6 is no greater than 1.0 if complying with Subsection 35.4.2 and 0.2 if complying with Subsection 35.4.3;
R n = (100)(G bc - G ac )/G bc ) Equation 6 Where: R

n = the overall efficiency

of the c ontrol sy stem needed, expressed as a percentage; G ac = emissions from the gluing operation after control equipment, in lb VHAP/lb solids; and
G bc = emissions from the gluing operation before controls, in lbPage 24 of 45 VHAP/lb solids. (2) Demonstrate tha t the value of R n calculated using Equation 6 is less than or equal to the actual overall control efficiency (R a ) calculated using the capture efficiency (N) and control efficiency (F) of the control sy stem measured in the initial performance test and Equa tion 4.
35.6.4 Continuous Compliance Using Control Equipment (a) The owners or operator of a facility that is complying with the emission limitations in this regulation through the use of a control sy stem shall demonstrate continuous compliance by ins talling, calibrating, maintaining, and operating appropriate monitoring equipment according to manufacturers' specifications. (b) The monitoring equipment installed pursuant to Paragraph (a) of this subsection shall measure operating parameters which in dicate ongoing compliance with the control efficiency requirements in this regulation. (c) Where a thermal incinerator is used, the operating parameter to be monitored shall be minimum combustion temperature, and a temperature monitoring device equipped with a continuous recorder shall be installed in the firebox or in the ductwork immediately downstream of the firebox in a position before any

substantial heat exchange occurs. (d) Where a cataly

tic incinerator equipped with a fixed cataly st bed is use d, the operating parameter to be monitored shall be the minimum gas temperature upstream and downstream of the cataly st bed and temperature monitoring devices equipped with continuous recorders shall be installed in the gas stream immediately before and af

ter the cataly st bed. (e) Where a cataly

tic incinerator equipped with a fluidized cataly st bed is used, the operating parameters to be monitored shall be the minimum gas temperature upstream of the cataly st bed and the pressure drop across the cataly st bed, and temperature monitoring devices equipped with continuous recorders shall be installed in the gas stream immediately before the bed. In addition, a pressure monitoring device shall be installed to determine the pressure drop across the cataly st bed . A constant pressure drop, as measured monthly at a constant flow rate, shall be maintained. (f) Where a carbon adsorber is used, the operating parameters to be monitored shall be either the total regeneration mass stream flow for each regeneration cy cle and the carbon bed temperature after each regeneration, or the concentration level of organic compounds exiting the adsorber,Page 25 of 45 unless the owner or operator requests and receives approval from the Department and the EPA to establish other operating param eters. One of the following devices is required to monitor these parameters: (1) An integrating regeneration stream flow monitoring device having an accuracy

of + 10 percent, capable of recording the total regeneration stream mass flow for each regener ation cy cle; and a carbon bed temperature monitoring device having an accuracy of + 1 percent of the temperature being monitored expressed in degrees Celsius or + 0.5 o C, whichever is greater, capable of recording the carbon bed temperature after each regene ration and within 15 minutes of completing any cooling cy cle; (2) An organic monitoring device, equipped with a continuous recorder, to indicate the concentration level of organic compounds exiting the carbon adsorber; or (3) Another monitoring dev ice that has been approved by the Department and the EPA. (g) A facility

using a control device not listed in this section to comply with this regulation shall submit to the Office of Air Resources a description of the device, test data verifying the pe rformance of the device, and appropriate operating parameter values that will be monitored to demonstrate continuous compliance with the standard. Compliance using this device is subject to the approval of the Department and the EPA. (h) Operating parameter values indicating compliance shall be calculated as the arithmetic average of the maximum or minimum value of those parameters, as appropriate, measured during the three test runs of the initial performance test, provided that the initial performance test demonstrated compliance. (i) The capture or control device shall be operated so that the average of all values for a monitored parameter recorded during each operating day is in compliance with the operating parameter value calculated according to the procedures in Paragraph (h) of this subsection.

**35.7 Recordkeeping and Reporting**  35.7.1 The owner or operator of a facility subject to this regulation shall maintain the following records for a period of five y ears: (a) A certified product data sheet (CPDS) for each finishing material, thinner,Page 26 of 45 adhesive, and strippable booth coating subject to the emission limitations in this regulation; (b) As applicable, the VOC content in lb VOC/gallon of coating, as applied and the VHAP content, in lb VHA P/lb of solids, as applied, of each coating subject to the emission limitations in this regulation, and copies of calculations documenting how the as

- applied values were determined. The VOC content of strippable booth coatings shall be expressed in units of lb VOC/lb solids, as applied. (c) The amount and ty pe of each coating and thinner used at the facility each month. (d) If viscosity

measurements are used to track VOC and/or VHAP concentrations: (1) Records of dates and amounts of solvent and finishing material added to the continuous coater reservoir; (2) Records of dates and results of viscosity measurements; and (3) Data demonstrating that viscosity is an appropriate parameter for demonstrating compliance.
35.7.2 The owner or oper ator of a facility using weekly

averaging to comply

with the VOC emissions limitations in Subsection 35.3.1 or monthly averaging to comply with the VHAP emissions limitations in Subsection 35.3.2 or 35.2.3 shall maintain the calculations of E VOC and E VHAP required in Subsection 35.6.2 for a period of 5 y ears. 35.7.3 The owner or operator of a source using control equipment to comply with the emissions limitations in this regulation shall maintain the following records for a period of five y ears: (a) Co pies of calculations of E VHAP from Equation 2 and R n from Equation 3, 5 and 6, as applicable; (b) Records of the daily average value of each continuously monitored operating parameter for each operating day . I f all recorded values for a monitored param eter during an operating day are within the range established during the initial performance test, the owner or operator may record that all values were within the range rather than calculating and recording an average for that day ; and (c) Records of t he pressure drop across the cataly st bed for facilitiesPage 27 of 45 complying with the emission limitations using a cataly tic incinerator with a fluidized cataly st bed.
35.7.4 The owner or operator of a facility subject to this regulation shall maintain onsite the w ork practice implementation plan and for five y ears shall maintain onsite all records associated with fulfilling the requirements of that plan, as specified in Section 35.5, including, but not limited to: (a) Records demonstrating that the operator trai ning 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 sy stem; (d) Records ass ociated with the limitation on the use of conventional air spray guns showing total finishing material usage and the percentage of finishing materials applied with conventional air spray guns for each reporting period; (e) Records associated with the fo rmulation assessment plan; (f) Records showing the VOC content of compounds used for cleaning booth components, except for solvent used to clean conveyors, continuous coaters and their enclosures, and/or metal filters; (g) A copy

of logs and other do cumentation developed to demonstrate that the provisions of the work practice implementation plan are followed; and (h) A copy

of the compliance certifications, and periodic reports submitted in accordance with the requirements of this regulation.
35 .7.5 In itial Notifications (a) The owner or operator of a facility subject to this regulation which was constructed before December 7, 1995 and which is a major source of HAP shall submit a I nitial Notification to the Division by September 2, 1996 or wi thin 30 day s of becoming a major source of HAP, whichever is later. In itial Notifications for facilities constructed before December 7, 1995 shall include the following information: (1) The name and address of the owner or operator; (2) The addres s (i.e., phy sical location) of the facility ;Page 28 of 45 (3) An identification of the relevant standard, or other requirement, that is the basis of the notification and the facility 's compliance date; (4) A brief description of the nature, size, design, and me thod of operation of the facility , including its operating design capacity and an identification of each point of emission for each HAP, or, if a definitive identification is not y et possible, a preliminary identification of each point of emission for each HAP; (5) An estimate of the amount of each HAP used and emitted annually from the facility ; and (6) The number of hours per day and day s per week that the facility operates. (b) The owner or operator of a facility subject to this regulation wh ich was constructed or reconstructed on or after December 7, 1995 and which is a major source of HAP shall submit an Initial Notification in conjunction with its construction permit application. A facility constructed or reconstructed on or after December 7, 1995 which subsequently becomes a major source of HAP shall submit an Initial Notification within 30 day s of becoming a major source of HAP. Initial Notifications for facilities constructed on or after December 7, 1995 shall include the following info rmation: (1) The date when construction or reconstruction began or is scheduled to begin; (2) The anticipated date of startup of the source; and (3) The information listed in paragraphs (a)(1) through (a)(6) of this subsection. (c) A facilit y subject to this regulation which was constructed or reconstructed after December 7, 1995 shall notify the Division of the actual date of startup of the facility

by April 6, 1996 or within 15 calendar day s after the startup date, whichever is later.
35. 7.6 In itial Compliance Certification (a) The owner or operator of a facility subject to the VHAP emission limitations in this regulation shall submit an I nitial Compliance Certification for VHAP to the Division. Initial Compliance Certifications for VHA P for facilities which began operation on or after December 6,Page 29 of 45 1994 shall be submitted by May 6, 1996 or 60 day s after beginning operation, whichever is later. Initial Compliance Certifications for VHAP for facilities which began operation before December 6, 1994 shall be submitted by

May 6, 1998. The owner or operator of a facility that, due to an increase in emissions, becomes a major source of HAP after the effective date of the regulation, shall submit an Initial Compliance Certification to the Divisi on no more than 60 day s after becoming a major source of HAP. (b) The owner or operator of a facility subject to the VOC emission limitations in this regulation shall submit an I nitial Compliance Certification for VOC to the Division. Initial Compliance Certifications for VOC shall be submitted by May 6, 1998. (c) In itial Compliance Certifications shall include the following information: (1) For a facility

that is complying with emission limitations through the use of compliant materials, Initi al 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 l imitations in this regulation and identify the method used to determine 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 35.6.1(b)(2) and that viscosity measurements demonstrate that the VHAP and VOC content of the material in the coaters is in complian ce with applicable emission limitations. (3) For a facility

using weekly

averaging to comply

with the VOC emission limitations in Subsection 35.3.1 or monthly averaging to comply with the VHAP emission limitations in Subsection 35.3.2 or 35.2.3, the In itial Compliance Certification shall state that E VOC and E VHAP , as calculated using Equation 1 and Equation 2, respectively , are no greater than the applicable emission limitations specified in Subsection 35.6.2. (4) For a facility

using a control sy st em to comply with the emission limitations in this regulation, the Initial Compliance Certification shall identify

each control device installed, including the identification number, permit number, installation date andPage 30 of 45 equipment controlled. In addition, the following information must be submitted no more than 60 day s after completing the initial performance test of the control sy stem: (i) The results of the initial performance test of the control sy stem; (ii) The overall control efficiency neede d (R

n ), 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 efficie ncy (R a ) calculated using the results of the initial performance test and Equation 4; and (iv) A plan for monitoring operating parameters which identifies the operating parameter values which indicate ongoing compliance, calculated as specified in Par agraph 35.6.4(h), discusses why

those parameters are appropriate indicators of compliance, and specifies the frequency that those parameters will be monitored. (5) In itial Compliance Certifications shall state that a work practice implementation plan h as been developed and procedures have been established for implementing the provisions of that plan. (6) In itial Compliance Certifications shall be signed by a responsible official of the company

that owns or operates the facility

. 35.7.7 Periodic Re ports The owner or operator of a facility subject to this regulation shall submit periodic reports to the Office of Air Resources according to the following specifications: (a) Periodic reports shall be submitted semi

- annually by 1 February

of each ye ar for the reporting period of 1 July through 31 December of the previous y ear and by

1 September for the reporting period of January 1 through June 30, which include the following: (1) The amount and ty pe of VOC and VHAP in each coating used at the fa cility

during the reporting period, (2) A compliance certification, as specified in Paragraphs (b) throughPage 31 of 45 (g) of this subsection, and (3) Documentation of progress made during the reporting period toward reducing the VOC and VHAP content of coati ngs used at the facility

. (b) If the facility

is using compliant coatings to comply with the emission limitations in Sections 35.3 and 35.4 of this regulation, periodic reports shall state that the VOC and VHAP content of each topcoat, filler, stain, to ner, ink, multi

- colored coating, pigmented coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth coating used each day at the facility

was in compliance with applicable limitations in those sections throughout the reporting pe riod, or should identify periods of noncompliance and the reasons for noncompliance. (c) If the facility

uses viscosity

to monitor compliance, the periodic report shall state that the viscosity of the finishing material in the reservoir was monitored ac cording to the specifications in Paragraph 35.6.1(b)(2) and that those measurements demonstrated compliance with applicable emission limitations throughout the reporting period, or should identify the day s of noncompliance and the reasons for noncompliance

. (d) If the facility

is complying with the VOC emissions limitations in Section 35.3 using averaging, the periodic report shall include the results of the VOC averaging calculation (Equation 1) for each week in the reporting period and shall certify

th at the facility

was in compliance with the applicable emission limitations in all weeks during that period, or identify the weeks that these limitations were exceeded and give reasons for those exceedances. (e) If the facility

is complying with the VHAP emissions limitations in Section 35.3 using averaging, the periodic report shall include the results of the VHAP averaging calculation (Equation 2) for each month in the reporting period and shall certify that the facility

was in compliance with the appli cable emission limitations in all months during that period, or identify the months that these limitations were exceeded and give reasons for those exceedances. (f) If the facility

is complying with the emission limitations in this regulation using a co ntrol sy stem, the periodic report shall state that the daily average value of each continuously monitored operating parameter was within the acceptable range on each operating day , or identify the day s of noncompliance and the reasons for the noncompliance

. (g) Periodic reports shall include a statement certify ing that the work practicePage 32 of 45 implementation plan and startup, shutdown, and malfunction plan were followed throughout the reporting period, or otherwise identify the periods of noncompliance with the work practice standards. (h) The periodic report shall be signed by a responsible official of the company that owns or operates the facility

. (i) If an exceedance occurs, periodic reports must be submitted quarterly until a request to reduce the rep orting 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 y ear of compliance without an exceedance; and (2) The owne r or operator of the facility continues to comply

with the recordkeeping and monitoring requirements specified in this regulation.

**35.8 Performance Test Methods**  35.8.1 VOC and Solids Content (a) VOC and solids content, by weight, of coatings shall b e demonstrated with EPA Method 24 or an alternative procedure approved by EPA and the Department. Sampling procedures shall follow the guidelines presented in "Standard Procedures for Collection of Coating and Ink Samples for VOC Content Analy sis by

Refere nce Method 24 and Reference Method 24A," EPA

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- 010. (b) The owner or operator of a facility that uses a finishing material that does not release VOC reaction by products during the cure; for example, if all VOC is solvent; may

request permission t o use batch formulation information to demonstrate compliance. I f the VOC content of a coating determined by

an EPA Method 24 test is greater than that indicated by the facility 's formulation data, the EPA Method 24 test shall govern.Page 33 of 45

35.8.2 VHAP and So lids Content (a) EPA Method 311 of Part 63, Appendix A, or an alternative method, if approved by

EPA and the Department , shall be used in conjunction with formulation data to determine the VHAP content of the liquid coating. Formulation data shall be u sed to identify VHAP present in the coating, and Method 311 or an approved alternative method shall be used to quantify the VHAP identified through the formulation data. EPA method 311 shall not be used to quantify VHAP such as sty

rene and formaldehy de th at are emitted during the cure. (b) EPA Method 24 (40 CFR part 60) shall be used to determine the solids content by

weight and the density

of coatings for the purpose of showing compliance with VHAP emission limitations. (c) The owner or operator of a facility that uses a finishing material that does not release VOC or VHAP by products during the cure; for example, if all VOC and VHAP present in the coating is solvent; may request permission to use batch formulation information to demonstrate complianc e. (d) If the VOC content of a coating as determined by EPA Method 24/311 test is higher than that indicated by a facility 's formulation data, the EPA Method 24/311 test shall govern, unless the facility can demonstrate to the satisfaction of the Depart ment that formulation data are correct. (e) Sampling procedures shall follow the guidelines presented in "Standard Procedures for Collection of Coating and Ink Samples for VOC Content Analy sis by

Reference Method 24 and Reference Method 24A," EPA

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- 91

- 010.
35.8.3 Control Equipment Efficiency (a) EPA Method 18, 25, or 25A shall be used to determine the VOC concentration of gaseous air streams. EPA Method 18 shall be used to determine the VHAP concentration of gaseous air streams. The test shall consist of three separate runs, each lasting a minimum of 30 minutes. (b) EPA Method 1 or 1A 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 Met hod 3 shall be used to analy ze exhaust gases. (e) EPA Method 4 shall be used to measure the moisture content of stack gasPage 34 of 45 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 sy stems must be constructed so that volumetric flow rates and VOC and/or total VHAP concentrations, as applicable, can be determined by

the test methods specified in Paragraphs (a) through (f) of this subsection, as applicable. (h) Capture efficiency shall be measured using measures approved by the EPA. (i) Testing shall be performed while all affected emission points are connected and operating at maximum production rate.

(j) The efficiency

(F) of the control device shal l be determined using Equation 7:

where: F = control device efficiency , expressed as a fraction.

C b i = the concentration of VOC or VHAP, as applicable, in gas stream (i) entering the emission control device, in parts per million by volume.
C aj = the concentration of VOC or VHAP, as applicable, in gas stream (j) exiting the emission control device, i n parts per million by volume. Q aj = the volumetric flow rate of gas stream (j) exiting the emission control device, in dry

standard cubic meters per hour. Q bi = the volumetric flow rate of gas stream (i) entering the emission control device, in dr

y standard cubic meters per hour. n p 

## Σ Q bi 

### C bi 

## - **Σ** Q aj 

## C aj i=I j=I F = ___________________________________ Equation 7

N 

## Σ Q bi C biPage 35 of 45

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

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

C di = the concentration of VOC or VHAP, as applicable, in gas stream (i) entering the emission control device from the a ffected emission point(s), in parts per million by

volume.
C fk = the concentration of VOC or VHAP, as applicable, in each uncontrolled gas stream (k) emitted directly to the atmosphere from the affected emission point(s), in parts per million by volume

. Q di = the volumetric flow rate of gas stream (i) entering the emission control device from the affected emission point(s), in dry standard cubic meters per hour. Q fk = the volumetric flow rate of each uncontrolled gas stream (k) emitted directly to the atmosphere from the affected emission point(s), in dry standard cubic meters per hour. (l) If all effected emissions points are surrounded by a permanent enclosure that is demonstrated to be total by procedures acceptable to the Department and th e EPA, the control device capture efficiency , N, is equal to 1.
**35.9 General Provisions**  35.9.1 Purpose

The purpose of this regulation is to limit emissions of volatile organic compounds and hazardous air pollutants from wood products manufacturing operations. n

**Σ** Q di C di N = _______________________________ Equation 8 n P
**Σ** Q di C di + **Σ** Q fk C fkPage 36 of 45 35.9.2 Aut

hority These regulations are authorized pursuant to R.I . Gen. Laws § 42

- 17.1

- 2(s) and 23

- 23 , as amended, and have been promulgated pursuant to the procedures set forth in the R.I . Administrative Procedures Act, R.I . Gen. Laws Chapter 42

- 35

35.9.3 Application

The terms and provisions of this regulation shall be liberally construed to permit the Department to effectuate the purposes of state law, goals and policies.
35.9.4 Severability

If any provision of this regulation or the application thereof to any person or ci rcumstance, is held invalid by a court of competent jurisdiction, the validity of the remainder of the regulation shall not be affected thereby

.

35.9.5 Effective Date

The foregoing regulation, "Control of Volatile Organic Compounds and Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations”, as amended, after due notice, is hereby adopted and filed with the Secretary

of State this ___29th

__ day of ___June ____, 20 07 _ to become effective twenty

(20) day s thereafter, in accordance with the provisions of Chapters 23

- 23, 42

- 35, 42

- 17.1, 42

- 17.6, of the General Laws of Rhode Is land of 1956, as amended.Page 37 of 45 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 38 of 45



### TABLE 1. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS Chemical name CAS No. Acetaldehy de 75070 Acetamide 60355 Acetonitrile 75058 Acetophenone 98 862 2

- Acetylaminofluorine 53963 Acrolein 107028 Acry lamide 79061 Acry lic acid 79107 Acry lonitrile 107131 Ally l chloride 107051 4

- Aminobiphenyl 92671 Aniline 62533 o - Anisidine 90040 Benzene 71432 Benzidine 92875 Benzotrichloride 9807 7 Benzyl chloride 100447 Biphenyl 92524 Bis(2

- ethylhexy l)phthalate (DEHP) 117817 Bis(chloromethyl)ether 542881 Bromoform 75252 1,3

- Butadiene 106990 Caprolactam 105602 Carbon disulfide 75150 Carbon tetrachloride 56235 Carbonyl sulfide 46 3581 Catechol 120809 Chloroacetic acid 79118 2

- Chloroacetophenone 532274 Chlorobenzene 108907 Chloroform 67663 Chloromethyl methyl ether 107302 Chloroprene 126998 Cresols (isomers and mixture) 1319773 o - Cresol 95487 m - Cresol 108394 p - C resol 106445 Cumene 98828 2,4

- D (2,4

- Dichlorophenoxy acetic acid, including salts and esters) 94757Table 1 (continued)

Page 39 of 47 Chemical name CAS No. DDE (1,1

- Dichloro

- 2,2

- bis(p

- chlorophenyl)ethylene) 72559 Diazomethane 334883 Dibenzofuran 132649 1,2

- Dibromo

- 3

- chloropropane 96128 Dibutylpht halate 84742 1,4

- Dichlorobenzene 106467 3,3'

- Dichlorobenzidine 91941 Dichloroethyl ether (Bis(2

- chloroethyl)ether) 111444 1,3

- Dichloropropene 542756 Diethanolamine 111422 N,N

- Dimethylaniline Diethyl sulfate 121697 64675 3,3'

- Dimethoxy

benzidi ne 119904 4

- Dimethylaminoazobenzene 60117 3,3'

- Dimethylbenzidine 119937 Dimethylcarbamoyl chloride 79447 N,N

- Dimethylformamide 68122 1,1

- Dimethy lhy drazine 57147 Dimethyl phthalate 131113 Dimethyl sulfate 77781 4,6

- Dinitro

- o - cresol, and salt s 2,4

- Dinitrophenol 51285 2,4

- Dinitrotoluene 121142 1,4

- Dioxane (1,4

- Diethyleneoxide) 123911 1,2

- Diphenylhy drazine 122667 Epichlorohy drin (1

- Chloro

- 2,3

- epoxy propane) 106898 1,2

- Epoxy

butane 106887 Ethyl acrylate 140885 Ethylbenzene 100414 Ethyl carbamate (Urethane) 51796 Ethyl chloride (Chloroethane) 75003 Ethylene dibromide (Dibromoethane) 106934 Ethylene dichloride (1,2

- Dichloroethane) 107062 Ethylene gly col 107211 Ethylene oxide 75218 Ethylenethiourea 96457 Ethylidene dichl oride (1,1

- Dichloroethane) 75343 Formaldehy de 50000Table 1 (continued)

Page 40 of 47 Chemical name CAS No. Gly col ethers 0 Hexachlorobenzene 118741 Hexachloro

- 1,3

- butadiene 87683 Hexachloroethane 67721 Hexamethy lene

- 1,6

- diisocy anate 822060 Hexamethy lphosphoramide 680319 Hexane 110543 Hy drazin e 302012 Hy droquinone 123319 Is ophorone 78591 Maleic anhy dride 108316 Methanol 67561 Methyl bromide (Bromomethane) 74839 Methyl chloride (Chloromethane) 74873 Methyl chloroform (1,1,1

- Trichloroethane) 71556 Methyl ethyl ketone (2

- Butanone) 78933 Methylhy drazine 60344 Methyl iodide (I odomethane) 74884 Methyl isobuty l ketone (Hexone) 108101 Methyl isocy anate 624839 Methyl methacrylate 80626 Methyl tert

- buty l ether 1634044 4,4'

- Methylenebis(2

- chloroaniline) 101144 Methylene chlo ride (Dichloromethane) 75092 4,4'

- Methylenediphenyl diisocy anate (MDI ) 101688 4,4'

- Methylenedianiline 101779 Naphthalene 91203 Nitrobenzene 98953 4

- Nitrobiphenyl 92933 4

- Nitrophenol 100027 2

- Nitropropane 79469 N

- Nitroso

- N

- methylurea 684935 N

- Nitrosodimethylamine 62759 N

- Nitrosomorpholine 59892 Phenol 108952 p - Pheny lenediamine 106503 Phosgene 75445 Phthalic anhy dride 85449Table 1 (continued)

Page 41 of 47 Chemical name CAS No. Poly chlorinated biphenyls (Aroclors) 1336363 Poly cy clic Organic Matter b 0 1,3

- Propane sultone 1120714 beta

- Propiolactone 57578 Propionaldehy de 123386 Propoxur (Bay gon) 114261 Propy lene dichloride (1,2

- Dichloropropane) 78875 Propy lene oxide 75569 1,2

- Propy lenimine (2

- Methyl aziridine) 75558 Quinone 106514 Sty rene 100425 Sty rene 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

- diisocy anate 584849 o - Toluidine 95534 1,2,4

- Trichlorobenzene 1208 21 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 Viny l acetate 108054 Viny l bromide 593602 Viny l chlorid e 75014 Viny lidene chloride (1,1

- Dichloroethylene) 75354 Xy lenes (isomers and mixture) 1330207 o - Xy lene m - Xy lene 95476 108383 p - Xy lene 106423

a In cludes mono

- and di

- ethers of ethylene gly col, diethylene gly cols and triethylene gly col; R

- (OCH 2 CH 2 )RR

- OR where:Table 1 (continued)

Page 42 of 47 n = 1, 2, or 3, R = alkyl or aryl groups R'= R, H, or groups which, when removed, yield gly col ethers with the structure: R

- (OCH 2 CH 2 ) n - OH. Poly mers are excluded from the gly col category

. b In cludes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100  C.Page 43 of 47



### TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING

AND WASHOFF SOLVENTS 1

1 Solvents containing these pollutants in concentrations less t han or equal to 0.1% may

be used. Chemical Name CAS No. 4

- Aminobiphenyl 92671 Sty rene oxide 96093 Diethyl sulfat e 64675 N

- Nitrosomorpholine 59892 Dimethyl formamide 68122 Hexamethy lphosphoramide 680319 Acetamide 60355 4,4'

- Methylenedianiline 101779 o - Anisidine 90040 2,3,7,8

- Tetrachlorodibenzo

- p - dioxin 1746016 Beryllium salts

- Benzidine 92875 N

- Ni troso

- N

- methylurea 684935 Bis(chloromethyl)ether 542881 Dimethyl carbamoyl chloride 79447 Chromium compounds (hexavalent)

- 1,2

- Propy lenimine (2

- Methyl aziridine) 75558 Arsenic and inorganic arsenic compounds 99999904 Hy drazine 302012 1,1

- Dime thy l hy drazine 57147 Beryllium compounds 7440417 1,2

- Dibromo

- 3

- chloropropane 96128 N

- Nitrosodimethylamine 62759 Cadmium compounds

- Benzo (a) py

rene 50328 Poly chlorinated biphenyls (Aroclors) 1336363 Heptachlor 76448 3,3'

- Dimethyl benzidine 119937 Nickel subsulfide 12035722 Acry lamide 79061 Hexachlorobenzene 118741 Chlordane 57749 1,3

- Propane sultone 1120714Page 44 of 45

Chemical Name CAS No. 1,3

- Butadiene 106990 Nickel refinery

dust

- 2

- Acetylaminoflourine 53963 3,3'

- Dichlorobenzidine 53963 Li ndane (hexachlo rcy clohexane, gamma) 58899 2,4

- Toluene diamine 95807 Dichloroethyl ether (Bis(2

- chloroethyl)ether) 111444 1,2

- Diphenylhy drazine 122667 Toxaphene (chlorinated camphene) 8001352 2,4

- Dinitrotoluene 121142 3,3'

- Dimethoxy

benzidine 119904 Formalde hy de 50000 4,4'

- Methylene bis(2

- chloroaniline) Acry lonitrile 101144 107131 Ethylene dibromide(1,2

- Dibromoethane) 106934 DDE (1,1

- p - chlorophenyl 1

- 2 dichloroethylene) 72559 Chlorobenzilate 510156 Dichlorvos 62737 Viny l chloride 75014 Coke Ove n Emissions 99999908 Ethylene oxide 75218 Ethylene thiourea 96457 Viny l bromide (bromoethene) 593602 Selenium sulfide (mono and di) 7488564 Chloroform 67663 Pentachlorophenol 87865 Ethyl carbamate (Urethane) 51796 Ethylene dichloride (1,2

- D ichloroethane) 107062 Propy lene dichloride (1,2

- Dichloropropane) 78875 Carbon tetrachloride 56235 Benzene 71432 Methyl hy drazine 60344 Ethyl acrylate 140885 Propy lene oxide 75569 Aniline 62533 1,4

- Dichlorobenzene(p) 106467 2,4,6

- Trichloro phenol 88062 Bis(2

- ethylhexy l)phthalate (DEHP) 117817Page 45 of 45

Chemical Name CAS No. o - Toluidine 95534 Propoxur 114261 Trichloroethylene 79016 1,4

- Dioxane (1,4

- Diethyleneoxide) 123911 Acetaldehy de 75070 Bromoform 75252 Captan 133062 Epichlorohy drin 106898 Methylene chloride (Dichloromethane) 75092 Tetrachloroethylene (Perchloroethylene) 127184 Dibenz (ah) anthracene 53703 Chry sene 218019 Dimethyl aminoazobenzene 60117 Benzo (a) anthracene 56553 Benzo (b) fluoranthene 205992 Antimony

trioxide 1 309644 2

- Nitropropane 79469 1,3

- Dichloropropene 542756 7, 12

- Dimethy lbenz(a)anthracene 57976 Benz(c)acridine 225514 In deno(1,2,3

- cd)py

rene 193395 1,2:7,8

- Dibenzopy

rene 189559