STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR RESOURCES

AIR POLLUTION CONTROL REGULATION NO. 35

CONTROL OF VOLATILE ORGANIC COMPOUNDS 

AND VOLATILE HAZARDOUS AIR POLLUTANTS

FROM WOOD PRODUCT MANUFACTURING OPERATIONS 

Effective 7 March 1996

Last Amended 19 July 2007

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

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

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

42-35.
RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR RESOURCES

AIR POLLUTION CONTROL REGULATION NO. 35

CONTROL OF VOLATILE ORGANIC COMPOUNDS AND 

VOLATILE HAZARDOUS 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 Compliance 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 .................................................................................................................43
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RHODE ISLAND 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 PRODUCTS 

MANUFACTURING OPERATIONS

35.1 Definitions

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

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

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

permits, be construed as follows:

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

bonding two surfaces together other than by mechanical means.

35.1.2 "Alternative method" means a method of sampling and analyzing for an air 

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

been demonstrated to the 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 topcoated for protection.

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

collecting solvent emissions or other pollutants into a duct so that pollutants can 

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

adsorber.

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

process that are directed to a control device.

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

a coating supplier or an outside laboratory that provides the VHAP content, 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 the 
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criteria specified in Subsection 35.8.1(b)). The purpose of the CPDS is to assist 

the facility in demonstrating compliance with the emission limitations presented 

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

content should represent the 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 functional material applied in a thin 

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

varnishes, sealers, stains, washcoats, basecoats, adhesives, inks, enamels, and 

temporary protective coatings.

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

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

Method 24.

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

coating that meets applicable emission limitations specified in Section 35.3 and 

35.4 of this regulation.

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

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

immediate and sufficiently strong to hold pieces together without further 

clamping, pressure, or airing.

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

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

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

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

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

coating.

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

emission limitations and other applicable requirements of this regulation at all 

times and is fulfilling all monitoring and recordkeeping provisions of the 

regulation in order to demonstrate compliance.

35.1.15. "Control 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.
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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 used to 

reduce emissions to the atmosphere.

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

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

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

airless, and electrostatic spray technologies are not considered conventional air 

spray methods.

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

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

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

the facility boundaries for disposal.

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 analyzing for an air 

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

relationship to the reference method, under specific conditions.

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

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

Edge filler is included in this definition.

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

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

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

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

basecoats, stains, washcoats, enamels, sealers, and topcoats.
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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 enclosed combustion device that thermally oxidizes 

volatile organic compounds to CO and CO2. This term does not include devices 

that burn municipal or hazardous waste material.

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

markings, but not to protect surfaces.

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

less.

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

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

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

such lesser quantity as the EPA may establish by rule.

35.1.36 "Malfunction" means any sudden, infrequent, and not reasonably preventable 

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

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 is 
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engaged in manufacturing.

35.1.40 "Operating 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 system, 

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

as a percentage.

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

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

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

applicable EPA 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.

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

process other than cleaning or washoff.

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

substrate before additional coats of finishing material are applied. Washcoats, 

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

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

operations for any purpose.

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

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

When used in a coating, it evaporates during drying and does not become a part of 

the dried film.

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

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

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

prestains, sap stains, body stains, no-wipe stains, penetrating stains, and toners.
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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 receive overspray during finishing operations; (2) is 

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

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

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

coatings are impregnated.

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

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

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

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

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

system.

35.1.56 "Touch-up and repair" means the application 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 

operations.

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

to remove coating from a substrate.

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

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

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

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

Regulation No. 19.

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

cleaning and washoff operations conducted at a wood products facility.
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35.2 Applicability

35.2.1 The provisions of this regulation apply to any wood products facility which has 

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

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

major source of Hazardous Air Pollutants (HAP).

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

applicability thresholds specified in Subsection 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 provisions of this regulation. If 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 applicability thresholds are reached or the date that the applicable 

requirement becomes effective, whichever is later.

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

month period shall not exceed 1,666 pounds of any one HAP or 4,166 

pounds of any combination of HAP; and

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

five years and made available to the Department or the EPA upon request:

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

gluing and washoff material used each month at the facility; and

(2) Certified Product Data Sheets showing the VOC and VHAP 

content of each finishing, gluing, and washoff material used at the 

facility; and
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(3) The type and amount of solvent used as thinners and in cleaning 

operations each month at the facility;

(4) The average monthly emissions of each HAP from the facility, 

calculated monthly for the previous twelve month period.

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

limitations specified in Sections 35.3 and 35.4 shall immediately apply.

35.3 Emission Limitations for Finishing Operations

35.3.1 VOC Emission Limitations for Finishing Operations

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

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

tons per year of volatile organic compounds (VOC) shall limit VOC 

emissions from 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 system that achieves 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 provisions 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.
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Table 2. Emissions Limitations for Finishing Materials

COATING 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, toners 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) In addition to complying with the limitations in Table 2, on and after 

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

which has the potential to emit greater than or equal to 25 tons per year 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 system 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 years to 
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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 limitations determined to be RACT within one 

year of that determination and shall thereafter operate in compliance with 

those limitations.

35.3.2 VHAP Emission Limitations for Finishing Operations at Existing Facilities

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

this regulation which is a major source of HAP and which began 

operations before December 6, 1994 shall limit VHAP emissions from 

wood products finishing operations by:

(1) Using stains, washcoats, sealers, topcoats, basecoats, and enamels 

with VHAP contents no higher than 1.0 lb VHAP/lb solids, as 

applied; thinners for stains, sealers, and topcoats that contain no 

more than 10% VHAP by weight; and thinners for washcoats, 

basecoats and enamels that contain no more than 3% VHAP by

weight; or

(2) Using finishing materials with a weighted average VHAP content 

of no greater than 1.0 lb VHAP/lb solids, as applied, calculated 

using the procedures in Subsection 35.6.2(b), and thinners with 

VHAP contents as specified in Paragraph 35.3.2(a)(1); or

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

equivalent to that which would be achieved by complying with the 

requirements of Paragraph (1) or (2) of this subsection, calculated 

according to the procedures in Subsection 35.6.3(c) of this 

regulation; or

(4) Using a combination of the methods presented in Paragraphs (1) 

and (3) of this subsection which is approved by the Department.

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

amount of free formaldehyde present in the finishing material when it is 

applied.

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

unreacted styrene, which shall be calculated by multiplying the amount of 

styrene monomer in the finishing material when it is applied by a factor of 

0.16.
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35.3.3 VHAP Emission Limitations for Finishing Operations at New Facilities

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

this regulation which is a major source of HAP and began operation on or 

after December 6, 1994 shall limit VHAP emissions from wood products 

finishing operations by:

(1) Using stains with VHAP contents no greater than 1.0 lb VHAP/lb 

solids, as applied; washcoats, sealers, topcoats, basecoats, and 

enamels with VHAP contents no greater than 0.8 lb VHAP/lb 

solids, as applied; thinners for stains, sealers, and topcoats that 

contain no more than 10% VHAP by weight; and 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 0.8 lb VHAP/lb solids, as applied, calculated 

using the procedures in Subsection 35.6.2(b), and thinners with 

VHAP contents as specified in Paragraph 35.3.3(a)(1); or

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

equivalent to that which would be achieved by complying with the 

requirements of Paragraph (1) or (2) of this subsection, calculated 

according to the procedures in provisions in Subsection 35.6.3(c) 

of this regulation; or

(4) Using a combination of the methods presented in Paragraphs (1) 

and (3) of this subsection which is approved by the Department.

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

amount of free formaldehyde present in the finishing material when it is 

applied.

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

unreacted styrene, which shall be calculated by multiplying the amount of 

styrene monomer in the finishing material when it is applied by a factor of 

0.16.
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35.4 Emission Limitations for Cleaning and Gluing Operations

35.4.1 VOC Emission Limitations for Cleaning Operations

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

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

35.4.2 VHAP Emission Limitations for Existing Gluing Operations

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

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

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

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

flammability requirements of California Technical Bulletin 116, 117, or 

133, the Business and Institutional Furniture Manufacturers Association's 

(BIFMA's) X5.7, UFAC flammability testing, or any similar requirements 

from local, State, or Federal fire regulatory agencies, the VHAP content of 

the adhesive shall not exceed 1.8 lb VHAP/lb solids, as applied;

(b) For all other contact adhesives, including foam adhesives used in products 

that do not meet the standards presented in Paragraph (a) of this 

subsection, the VHAP content of the adhesive shall not exceed 1.0 lb 

VHAP/lb solids, as applied; or

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

emissions equivalent to that which would be achieved by complying with 

the requirements of Paragraph (b) of this subsection, as calculated using 

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

35.4.3 VHAP Emission Limitations for New Gluing Operations

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

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

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

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

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

specified.
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35.5.1 Work Practice Implementation Plan

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

and maintain a written work practice implementation plan that defines 

work practices for each wood products manufacturing operation and 

addresses each of the topics specified in Subsections 35.5.2 through 

35.5.10.

(b) The work practice implementation plan shall be developed by May 6, 1996 

and shall be subject to the approval of the Department.

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

the work practice implementation plan.

(d) The work practice implementation plan shall be available for inspection by

the EPA or the Department upon request and shall be modified by the 

facility if found to be inadequate.

35.5.2 Operator Training Course

(a) Each owner or operator of a facility subject to this regulation shall train all 

new and existing personnel, including contract personnel, who are 

involved in finishing, gluing, cleaning, or washoff operations, use of 

manufacturing equipment, or implementation of the requirements of this 

regulation.

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

whichever is later. All personnel shall be given refresher training 

annually.

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

topics:

(1) Appropriate application techniques;

(2) Appropriate cleaning and washoff procedures;

(3) Appropriate equipment setup and adjustment to minimize finishing 

material usage and overspray; and

(4) Appropriate management of cleanup wastes.

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

include, at a minimum, the following:
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(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 

training for each position, or group of personnel;

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

refresher training that include, at a minimum, the topics specified 

in Paragraph (c) of this subsection; and

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

completion of initial and refresher training.

35.5.3 Equipment Operation, Maintenance, Inspection and Repair

(a) Equipment Leak Inspection and Repair 

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

finishing materials, adhesives, or organic solvents shall be visually

inspected for leaks at least once per month.

(2) A first attempt at repair shall be made no later than 3 calendar days 

after a leak is detected and final repairs shall be made within 10 

calendar days, unless the leaking equipment is to be replaced by a 

new purchase, in which case repairs shall be completed within 3 

months.

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

prepare and maintain a written leak inspection and maintenance 

plan that includes:

(i) A schedule for conducting visual inspections required in 

Paragraph (a) of this subsection; and

(ii) A log documenting the date and results of each inspection 

and any repairs that are made.

(b) Operation and Maintenance Requirements

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

malfunction, owners or operators shall operate and maintain any

equipment associated with wood products manufacturing 

operations, including associated air pollution control equipment, in 

a manner consistent with good air pollution control practices for 
Page 15 of 45

minimizing emissions.

(2) Malfunctions shall be corrected as soon as practicable after their 

occurrence in accordance with the startup, shutdown, and 

malfunction plan required in Paragraph (b)(4) of this subsection.

(3) The Department 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 

manufacturing operations during periods of startup, shutdown, and 

malfunction and a program of corrective action for malfunctioning 

process and air pollution control equipment used to comply with 

this regulation. The facility's standard operating procedures (SOP) 

manual, an Occupational Safety and Health Administration 

(OSHA) or another plan can be used to fulfill this requirement, 

provided the plan meets all the requirements of this

paragraph. Startup, shutdown, and malfunction plans shall be 

maintained at the facility and made available to the Department or 

the EPA for review upon request and shall be revised if determined 

to be unacceptable.

(5) During periods of startup, shutdown, and malfunction, the owner 

or operator of a facility subject to this regulation shall operate and 

maintain equipment associated with wood products manufacturing 

operations (including associated air pollution control equipment) in 

accordance with the procedures specified in the startup, shutdown, 

and malfunction plan developed according to the provisions of 

Paragraph (b)(4) of this subsection.

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

keep records of action taken during startups, shutdowns, and 

malfunctions, including actions taken to correct malfunctions and 

shall certify, in the semi-annual reports required in Subsection 

35.7.7, that all such actions were consistent with the procedures 

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

operator shall record the actions taken and report such actions to 

the Office of Air Resources within 2 working days after beginning 

actions inconsistent with the plan, followed by a letter within 

7 working days after the end of the event.

(8) If a malfunction occurs that was not adequately addressed in the 

startup, shutdown, and malfunction plan, the owner or operator 

shall revise the plan within 45 days after the event to include 

detailed procedures for operating and maintaining the source 

during similar malfunction events and a program of corrective 

action for similar malfunctions of process or air pollution control 

equipment.

35.5.4 Cleaning and Washoff Solvent Requirements

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

for organic solvent use in cleaning and washoff operations by recording 

the following information:

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

cleaning operations each month;

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

and

(3) The quantity of spent organic solvent generated from each washoff 

and cleaning activity each month, and whether it is recycled onsite 

or disposed offsite.

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

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

concentrations greater than 0.1%.
Page 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 conveyors, 

continuous coaters and their enclosures, or metal filters, unless the spray booth is being 

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

other material used to cover the booth is being replaced, the facility shall use no more 

than 1.0 gallon of organic solvent per booth to prepare the booth prior to applying the 

booth coating.

35.5.6 Storage Requirements

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

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

35.5.7 Application Equipment Requirements

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

following situations:

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

which is not a major source of HAP or which began operation prior to 

December 6, 1994;

(b) When applying finishing materials that have a VOC content no greater 

than 1.0 lb VOC/lb solids, as applied;

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

operation;

(d) Touch-up or repair that occurs after the stain and before any other type of 

finishing material is applied, provided that the touch-up finishing materials 

are applied from a container that has a volume of no more than 

2.0 gallons;

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

(f) If emissions from the finishing application station are directed to a control 

device;

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

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

materials used at that facility during that semi-annual reporting period, as 

specified in Subsection 35.7.7(a).; or
Page 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 economic 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 Line Cleaning

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

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

35.5.9 Gun Cleaning

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

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

35.5.10 Washoff operations

Emissions from washoff operations shall be controlled by:

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

being added or removed; and

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

organic solvent as possible.

35.5.11 Formulation Assessment Plan

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

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

plan that:

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

the facility.

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

follows:
Page 19 of 45

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

calendar year 1994 for each VHAP;

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

amount of free formaldehyde present in the finishing material when 

it is applied;

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

unreacted styrene, which shall be calculated by multiplying the 

amount of styrene monomer in the finishing material when it is 

applied by a factor 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 system, calculated using Equation 5 in Paragraph 35.6.3(c).

(5) The baseline levels for a VHAP that was not used in 1994 shall be 

established as 20% of the Reportable Quantity for that substance 

specified in Table III of Regulation No. 22.

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

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

year exceeds its baseline level, then the owner or operator of the facility

shall provide a written notification to the Division by 31 January of the 

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

reasons for the increase. The Department will determine whether the 

increase would cause an exceedance of the Acceptable Ambient Levels 

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

22 limits are exceeded, the Department will develop a timetable for the 

facility to achieve compliance and a schedule for submitting notification of 

progress.

35.6 Compliance Procedures and Monitoring Requirements

35.6.1 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, toner, ink, multicolored coating, pigmented coating, sealer, washcoat, enamel, basecoat, 

thinner, adhesive and strippable booth coating meets the applicable 
Page 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, multicolored coating, sealer, washcoat, enamel, basecoat, adhesive and 

strippable booth coating diluted onsite, as applied, meets the applicable 

emissions limitations in Sections 35.3 and 35.4 in lb VOC/gallon of 

coating or lb VHAP/lb of solids; and

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

procedures:

(1) Calculating the VOC and VHAP content, as applicable, of the 

finishing material in the reservoir from information on the CPDS 

and records of materials added to the reservoir; or

(2) Monitoring the viscosity of the finishing material in the reservoir 

with a viscosity meter or testing the viscosity of the initial finishing 

material and retesting the material in the reservoir each time 

solvent is added. If this option is chosen, the facility shall maintain 

data that demonstrates the correlation between the viscosity of the 

finishing material and the VOC and VHAP content, as applicable, 

of the finishing material; and

(d) The Department or EPA will determine compliance either by reviewing 

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

conducting a performance test according to the specifications in 

Subsections 35.8.1 and 35.8.2. If the VOC or VHAP content of a coating 

determined by a performance test using the procedures specified in 

Subsections 35.8.1 and 35.8.2 is greater than that indicated on a CPDS or 

by the facility's formulation or viscosity data, the performance test results 

shall govern.

35.6.2 Compliance Using Averaging

(a) To demonstrate compliance with the VOC emission limitations in 

Subsection 35.3.1 for a particular coating category through the use of 

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

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

at the facility using Equation 1:

n n

Evoc= (∑ ViCi ) /  Vi Equation 1

i=I i=I
Page 21 of 45

Where:EVOC = 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 coating minus water and exempt compounds, as applied;

i = subscript denoting an individual coating;

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

coating in the coating category used during the weekly averaging 

period;

(2) Demonstrate that the value calculated for EVOC is no greater than 

0.9 times the emission limitation, in lbs VOC/gallon coating minus 

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

as listed in Table 2.

(b) To demonstrate compliance with the VHAP emission limitations in 

Subsections 35.3.2 and 35.3.3 through the use of averaging, the owner or 

operator of a facility shall, each month:

(1) Calculate the average VHAP content for all finishing materials 

used at the facility using Equation 2:

 n n n

EVHAP = (  MiC1 +  SiWi ) /  Mi Equation 2

 i=1 i=1 i=1 

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

solids; 

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

applied;

i = subscript denoting an individual coating; 

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

material used during the monthly averaging period;

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

fraction, added to finishing materials; and
Page 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 EVHAP is no greater than 

1.0 if the facility is complying with Subsection 35.3.2 and is no 

greater than 0.8 if the facility is complying with Subsection 35.3.3.

35.6.3 Initial Compliance Using Control Equipment

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

comply with the VOC emission limitations in Table 2 or the VHAP 

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

performance test to measure the capture and control efficiency of the 

control system using the procedures specified in Subsection 35.8.3 by June 

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

used to comply with the VHAP emission limitations in Subsections 35.3.2 

and/or 35.4.2 or the VOC emissions limitations for sealers and clear 

topcoats in Paragraph 35.3.1(b) shall be conducted by September 8, 1998.

(b) Initial compliance with VOC emission limitations for finishing materials 

through the use of a control system shall be determined as follows:

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

finishing material which will be controlled by the control 

equipment using the following equation:

Rn = [(C - EL)/C](100) Equation 3

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

percentage.

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

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

2, in lb VOC/lb solids.

(2) Document that the value of C used in 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 Rn

calculated using Equation 3 is less than or equal to the actual 

overall control efficiency (Ra) calculated by substituting the 

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

system measured in the initial performance test into Equation 4.
Page 23 of 45

Ra = (F x N)(100) Equation 4

(c) Initial compliance with VHAP emission limitations for finishing materials 

through the use of a control system shall be determined as follows:

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

value of Eac in Equation 5 is no greater than 1.0 if complying with 

Subsection 35.3.2 and so that the value of Eac in Equation 5 is no 

greater than 0.8 if complying with Subsection 35.3.3;

Rn = (100)(Ebc - Eac)/Ebc Equation 5

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

a percentage;

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

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

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

before controls, calculated as EVHAP in Equation 2.

(2) Demonstrate that the value of Rn calculated using Equation 5 is 

less than or equal to the actual overall control efficiency (Ra) 

calculated using the capture efficiency (N) and control efficiency

(F) of the control system measured in the initial performance test 

and Equation 4.

(d) Initial compliance with VHAP emission limitations for gluing materials 

through the use of a control system shall be determined as follows:

(1) Calculate the overall control efficiency of the control system 

needed (Rn) so that the value of Gac in Equation 6 is no greater than 

1.0 if complying with Subsection 35.4.2 and 0.2 if complying with 

Subsection 35.4.3;

Rn = (100)(Gbc - Gac)/Gbc) Equation 6

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

a percentage;

Gac = emissions from the gluing operation after control equipment, 

in lb VHAP/lb solids; and

Gbc = emissions from the gluing operation before controls, in lb 
Page 24 of 45

VHAP/lb solids.

(2) Demonstrate that the value of Rn calculated using Equation 6 is 

less than or equal to the actual overall control efficiency (Ra) 

calculated using the capture efficiency (N) and control efficiency

(F) of the control system measured in the initial performance test 

and Equation 4.

35.6.4 Continuous Compliance Using Control Equipment

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

limitations in this regulation through the use of a control system shall 

demonstrate continuous compliance by installing, calibrating, maintaining, 

and operating appropriate monitoring equipment according to 

manufacturers' specifications.

(b) The monitoring equipment installed pursuant to Paragraph (a) of this 

subsection shall measure operating parameters which indicate ongoing 

compliance with the control efficiency requirements in this regulation.

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

monitored shall be minimum combustion temperature, and a temperature 

monitoring device equipped with a continuous recorder shall be installed 

in the firebox or in the ductwork immediately downstream of the firebox 

in a position before any substantial heat exchange occurs.

(d) Where a catalytic incinerator equipped with a fixed catalyst bed is used, 

the operating parameter to be monitored shall be the minimum gas 

temperature upstream and downstream of the catalyst bed and temperature 

monitoring devices equipped with continuous recorders shall be installed 

in the gas stream immediately before and after the catalyst bed.

(e) Where a catalytic incinerator equipped with a fluidized catalyst bed is 

used, the operating parameters to be monitored shall be the minimum gas 

temperature upstream of the catalyst bed and the pressure drop across the 

catalyst bed, and temperature monitoring devices equipped with 

continuous recorders shall be installed in the gas stream immediately

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

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

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

(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 cycle 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 parameters. One of 

the following devices is required to monitor these parameters:

(1) An integrating regeneration stream flow monitoring device having 

an accuracy of +10 percent, capable of recording the total 

regeneration stream mass flow for each regeneration cycle; and a 

carbon bed temperature monitoring device having an accuracy of 

+1 percent of the temperature being monitored expressed in 

degrees Celsius or +0.5o C, whichever is greater, capable of 

recording the carbon bed temperature after each regeneration and 

within 15 minutes of completing any cooling cycle;

(2) An organic monitoring device, equipped with a continuous 

recorder, to indicate the concentration level of organic compounds 

exiting the carbon adsorber; or

(3) Another monitoring device that has been approved by the 

Department and the EPA.

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

this regulation shall submit to the Office of Air Resources a description of 

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

appropriate operating parameter values that will be monitored to 

demonstrate continuous compliance with the standard. Compliance using 

this device is subject to the approval of the Department and the EPA.

(h) Operating parameter values indicating compliance shall be calculated as 

the arithmetic average of the maximum or minimum value of those 

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

initial performance test, provided that the initial performance test 

demonstrated compliance.

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

values for a monitored parameter recorded during each operating day is in 

compliance with the operating parameter value calculated according to the 

procedures in Paragraph (h) of this subsection.

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 years:

(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 VHAP/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 type 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 operator 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 EVOC and EVHAP required in Subsection 35.6.2 for a 

period of 5 years.

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

emissions limitations in this regulation shall maintain the following records for a 

period of five years:

(a) Copies of calculations of EVHAP from Equation 2 and Rn from Equation 3, 

5 and 6, as applicable;

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

operating parameter for each operating day. If all recorded values for a 

monitored parameter during an operating day are within the range 

established during the initial performance test, the owner or operator may

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

recording an average for that day; and

(c) Records of the pressure drop across the catalyst bed for facilities 
Page 27 of 45

complying with the emission limitations using a catalytic incinerator with 

a fluidized catalyst bed.

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

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

records associated with fulfilling the requirements of that plan, as specified in 

Section 35.5, including, but not limited to:

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

(b) Records maintained in accordance with the equipment leak inspection and 

maintenance plan and startup, shutdown, and malfunction plan;

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

(d) Records associated with the limitation on the use of conventional air spray

guns showing total finishing material usage and the percentage of finishing 

materials applied with conventional air spray guns for each reporting 

period;

(e) Records associated with the formulation assessment plan;

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

components, except for solvent used to clean conveyors, continuous 

coaters and their enclosures, and/or metal filters;

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

provisions of the work practice implementation plan 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 Initial Notifications

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

constructed before December 7, 1995 and which is a major source of HAP 

shall submit a Initial Notification to the Division by September 2, 1996 or 

within 30 days of becoming a major source of HAP, whichever is later. 

Initial Notifications for facilities constructed before December 7, 1995 

shall include the following information:

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

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

operation of the facility, including its operating design capacity and 

an identification of each point of emission for each HAP, or, if a 

definitive identification is not yet possible, a preliminary

identification of each point of emission for each HAP; 

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

from the facility; and

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

operates.

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

constructed or reconstructed on or after December 7, 1995 and which is a 

major source of HAP shall submit an Initial Notification in conjunction 

with its construction permit application. A facility constructed or 

reconstructed on or after December 7, 1995 which subsequently becomes a 

major source of HAP shall submit an Initial Notification within 30 days of 

becoming a major source of HAP. Initial Notifications for facilities 

constructed on or after December 7, 1995 shall include the following 

information:

(1) The date when construction or reconstruction began or is scheduled 

to begin;

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

(3) The information listed in paragraphs (a)(1) through (a)(6) of this 

subsection.

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

after December 7, 1995 shall notify the Division of the actual date of 

startup of the facility by April 6, 1996 or within 15 calendar days after the 

startup date, whichever is later.

35.7.6 Initial Compliance Certification

(a) The owner or operator of a facility subject to the VHAP emission 

limitations in this regulation shall submit an Initial Compliance 

Certification for VHAP to the Division. Initial Compliance Certifications 

for VHAP for facilities which began operation on or after December 6, 
Page 29 of 45

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

operation, whichever is later. Initial Compliance Certifications for VHAP 

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

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

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

effective date of the regulation, shall submit an Initial Compliance 

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

source of HAP. 

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

limitations in this regulation shall submit an Initial Compliance 

Certification for VOC to the Division. Initial Compliance Certifications 

for VOC shall be submitted by May 6, 1998.

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

(1) For a facility that is complying with emission limitations through 

the use of compliant materials, Initial Compliance Certifications 

shall state that each topcoat, filler, stain, toner, ink, multi-colored 

coating, pigmented coating, sealer, washcoat, enamel, basecoat, 

thinner, adhesive and strippable booth coating is in compliance 

with applicable emissions limitations in this regulation and identify

the method used to 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 compliance 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 Initial Compliance Certification shall state that EVOC

and EVHAP, as calculated using Equation 1 and Equation 2, 

respectively, are no greater than the applicable emission limitations 

specified in Subsection 35.6.2.

(4) For a facility using a control system to comply with the emission 

limitations in this regulation, the Initial Compliance Certification 

shall identify each control device installed, including the 

identification number, permit number, installation date and 
Page 30 of 45

equipment controlled. In addition, the following information must 

be submitted no more than 60 days after completing the initial 

performance test of the control system:

(i) The results of the initial performance test of the control 

system;

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

Equation 3 for VOC emissions from finishing operations, 

Equation 5 for VHAP emissions from finishing operations, 

and Equation 6 for VHAP emissions from gluing 

operations, as applicable;

(iii) The actual overall control efficiency (Ra) calculated using 

the results of the initial performance test and Equation 4; 

and

(iv) A plan for monitoring operating parameters which 

identifies the operating parameter values which indicate 

ongoing compliance, calculated as specified in Paragraph 

35.6.4(h), discusses why those parameters are appropriate 

indicators of compliance, and specifies the frequency that 

those parameters will be monitored.

(5) Initial Compliance Certifications shall state that a work practice 

implementation plan has been developed and procedures have been 

established for implementing the provisions of that plan.

(6) Initial Compliance Certifications shall be signed by a responsible 

official of the company that owns or operates the facility.

35.7.7 Periodic Reports

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

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

(a) Periodic reports shall be submitted semi-annually by 1 February of each 

year for the reporting period of 1 July through 31 December of the 

previous year and by 1 September for the reporting period of January 1 

through June 30, which include the following:

(1) The amount and type of VOC and VHAP in each coating used at 

the facility during the reporting period, 

(2) A compliance certification, as specified in Paragraphs (b) through 
Page 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 coatings used at 

the facility.

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

limitations in Sections 35.3 and 35.4 of this regulation, periodic reports 

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

toner, 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 period, or should identify periods of 

noncompliance and the reasons for noncompliance.

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

shall state that the viscosity of the finishing material in the reservoir was 

monitored according to the specifications in Paragraph 35.6.1(b)(2) and 

that those measurements demonstrated compliance with applicable 

emission limitations throughout the reporting period, or should identify the 

days of noncompliance and the reasons for noncompliance.

(d) If the facility is complying with the 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 that the facility was in compliance with the 

applicable emission limitations in all weeks during that period, or identify

the weeks that these limitations were exceeded and give reasons for those 

exceedances.

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

Section 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 applicable emission limitations in all months during that period, or 

identify the months that these limitations were exceeded and give reasons 

for those exceedances.

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

using a control system, the periodic report shall state that the daily average 

value of each continuously monitored operating parameter was within the 

acceptable range on each operating day, or identify the days of 

noncompliance and the reasons for the noncompliance.

(g) Periodic reports shall include a statement certifying that the work practice 
Page 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 reporting frequency has been approved. Submittal 

frequencies may be reduced to semi-annual provided that the following 

conditions have been satisfied:

(1) The facility has demonstrated a full year of compliance without an 

exceedance; and

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

recordkeeping and monitoring requirements specified in this 

regulation.

35.8 Performance Test Methods

35.8.1 VOC and Solids Content

(a) VOC and solids content, by weight, of coatings shall be demonstrated with 

EPA Method 24 or an alternative procedure approved by EPA and the 

Department. Sampling procedures shall follow the guidelines presented in 

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

Content Analysis by Reference Method 24 and Reference Method 24A," 

EPA-340/1-91-010.

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

not release VOC reaction byproducts during the cure; for example, if all 

VOC is solvent; may request permission to use batch formulation 

information to demonstrate compliance. If 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 Solids Content

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

approved by EPA and the Department, shall be used in conjunction with 

formulation data to determine the VHAP content of the liquid coating. 

Formulation data shall be used to identify VHAP present in the coating, 

and Method 311 or an approved alternative method shall be used to 

quantify the VHAP identified through the formulation data. EPA method 

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

that are emitted during the cure.

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

content by weight and the density of coatings for the purpose of showing 

compliance with VHAP emission limitations.

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

not release VOC or VHAP byproducts during the cure; for example, if all 

VOC and VHAP present in the coating is solvent; may request permission 

to use batch formulation information to demonstrate compliance.

(d) If the VOC content of a coating as determined by EPA Method 24/311 test 

is higher than that indicated by a facility's formulation data, the EPA 

Method 24/311 test shall govern, unless the facility can demonstrate to the 

satisfaction of the Department that formulation data are correct.

(e) Sampling procedures shall follow the guidelines presented in "Standard 

Procedures for Collection of Coating and Ink Samples for VOC Content 

Analysis by Reference Method 24 and Reference Method 24A," 

EPA-340/1-91-010.

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 Method 3 shall be used to analyze exhaust gases.

(e) EPA Method 4 shall be used to measure the moisture content of stack gas 
Page 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 systems must be constructed so that volumetric 

flow rates and VOC and/or total VHAP concentrations, as applicable, can 

be determined by the test methods specified in Paragraphs (a) through (f) 

of this subsection, as applicable.

(h) Capture efficiency shall be measured using measures approved by the 

EPA.

(i) Testing shall be performed while all affected emission points are 

connected and operating at maximum production rate.

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

determined using Equation 7:

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

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

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

Caj = the concentration of VOC or VHAP, as applicable, in gas stream (j) 

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

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

control device, in dry standard cubic meters per hour.

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

control device, in dry standard cubic meters per hour.

n p

Σ Qbi Cbi - Σ Qaj Caj

i=I j=I

F = ___________________________________ Equation 7

N

Σ Qbi Cbi
Page 35 of 45

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

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

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

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

in parts per million by volume.

Cfk = 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.

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

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

meters per hour.

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

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

standard cubic meters per hour.

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

that is demonstrated to be total by procedures acceptable to the 

Department and the EPA, the control device capture efficiency, N, is equal 

to 1.

35.9 General Provisions

35.9.1 Purpose

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

compounds and hazardous air pollutants from wood products manufacturing 

operations.

 n

 Σ Qdi Cdi 

N = _______________________________ Equation 8

 n P

 Σ Qdi Cdi + Σ Qfk Cfk
Page 36 of 45

35.9.2 Authority

These regulations are authorized pursuant to R.I. Gen. Laws § 42-17.1-2(s) 

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

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

Laws Chapter 42-35

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 

circumstance, 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____, 2007_ to become 

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

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

Island of 1956, 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.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorine 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Benzene 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Caprolactam 105602

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

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-Cresol 106445

Cumene 98828

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

salts and esters) 94757
Table 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

Dibutylphthalate 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'-Dimethoxybenzidine 119904

4-Dimethylaminoazobenzene 60117

3,3'-Dimethylbenzidine 119937

Dimethylcarbamoyl chloride 79447

N,N-Dimethylformamide 68122

1,1-Dimethylhydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

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

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

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

1,2-Diphenylhydrazine 122667

Epichlorohydrin (1-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 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 glycol 107211

Ethylene oxide 75218

Ethylenethiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000
Table 1 (continued)

Page 40 of 47

Chemical name CAS No.

Glycol ethers 0

Hexachlorobenzene 118741

Hexachloro-1,3-butadiene 87683

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydroquinone 123319

Isophorone 78591

Maleic anhydride 108316

Methanol 67561

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

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

Methyl ethyl ketone (2-Butanone) 78933

Methylhydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert-butyl ether 1634044

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

Methylene chloride (Dichloromethane) 75092

4,4'-Methylenediphenyl diisocyanate (MDI) 101688

4,4'-Methylenedianiline 101779

Naphthalene 91203

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-Phenylenediamine 106503

Phosgene 75445

Phthalic anhydride 85449
Table 1 (continued)

Page 41 of 47

Chemical name CAS No.

Polychlorinated biphenyls (Aroclors) 1336363

Polycyclic Organic Matterb0

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

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

Quinone 106514

Styrene 100425

Styrene oxide 96093

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

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Toluene 108883

2,4-Toluenediamine 95807

Toluene-2,4-diisocyanate 584849

o-Toluidine 95534

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylene 

m-Xylene 

95476

108383

p-Xylene 106423

a

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

glycol; R-(OCH2CH2)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 glycol ethers with the structure: 

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

b

Includes 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 SOLVENTS1

 

 

1

Solvents containing these pollutants in concentrations less than or equal to 0.1% may be used.

Chemical Name CAS No. 

4-Aminobiphenyl 92671 

Styrene oxide 96093 

Diethyl sulfate 64675 

N-Nitrosomorpholine 59892 

Dimethyl formamide 68122 

Hexamethylphosphoramide 680319 

Acetamide 60355 

4,4'-Methylenedianiline 101779 

o-Anisidine 90040 

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

Beryllium salts -

Benzidine 92875 

N-Nitroso-N-methylurea 684935 

Bis(chloromethyl)ether 542881 

Dimethyl carbamoyl chloride 79447 

Chromium compounds (hexavalent) -

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

Arsenic and inorganic arsenic compounds 99999904 

Hydrazine 302012 

1,1-Dimethyl hydrazine 57147 

Beryllium compounds 7440417 

1,2-Dibromo-3-chloropropane 96128 

N-Nitrosodimethylamine 62759 

Cadmium compounds -

Benzo (a) pyrene 50328 

Polychlorinated biphenyls (Aroclors) 1336363 

Heptachlor 76448 

3,3'-Dimethyl benzidine 119937 

Nickel subsulfide 12035722 

Acrylamide 79061 

Hexachlorobenzene 118741 

Chlordane 57749 

1,3-Propane sultone 1120714 
Page 44 of 45

Chemical Name CAS No. 

1,3-Butadiene 106990 

Nickel refinery dust -

2-Acetylaminoflourine 53963

3,3'-Dichlorobenzidine 53963 

Lindane (hexachlorcyclohexane, gamma) 58899 

2,4-Toluene diamine 95807 

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444 

1,2 - Diphenylhydrazine 122667 

Toxaphene (chlorinated camphene) 8001352 

2,4-Dinitrotoluene 121142 

3,3'-Dimethoxybenzidine 119904

Formaldehyde 50000 

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

Acrylonitrile

101144 

107131 

Ethylene dibromide(1,2-Dibromoethane) 106934 

DDE (1,1-p-chlorophenyl 1-2 dichloroethylene) 72559 

Chlorobenzilate 510156 

Dichlorvos 62737 

Vinyl chloride 75014 

Coke Oven Emissions 99999908 

Ethylene oxide 75218 

Ethylene thiourea 96457 

Vinyl bromide (bromoethene) 593602 

Selenium sulfide (mono and di) 7488564 

Chloroform 67663 

Pentachlorophenol 87865 

Ethyl carbamate (Urethane) 51796 

Ethylene dichloride (1,2-Dichloroethane) 107062 

Propylene dichloride (1,2-Dichloropropane) 78875 

Carbon tetrachloride 56235 

Benzene 71432 

Methyl hydrazine 60344 

Ethyl acrylate 140885 

Propylene oxide 75569 

Aniline 62533 

1,4-Dichlorobenzene(p) 106467 

2,4,6-Trichlorophenol 88062 

Bis(2-ethylhexyl)phthalate (DEHP) 117817 
Page 45 of 45

Chemical Name CAS No. 

o-Toluidine 95534 

Propoxur 114261 

Trichloroethylene 79016 

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

Acetaldehyde 75070 

Bromoform 75252 

Captan 133062 

Epichlorohydrin 106898 

Methylene chloride (Dichloromethane) 75092 

Tetrachloroethylene (Perchloroethylene) 127184 

Dibenz (ah) anthracene 53703 

Chrysene 218019 

Dimethyl aminoazobenzene 60117 

Benzo (a) anthracene 56553 

Benzo (b) fluoranthene 205992 

Antimony trioxide 1309644 

2-Nitropropane 79469 

1,3-Dichloropropene 542756 

7, 12-Dimethylbenz(a)anthracene 57976 

Benz(c)acridine 225514 

Indeno(1,2,3-cd)pyrene 193395 

1,2:7,8-Dibenzopyrene 189559