ENCLOSURE 3 

AMENDMENTS TO 

VERMONT AIR POLLUTION CONTROL REGULATIONS 

SUBMITTED AS REVISIONS TO THE VERMONT SIP 

SUBCHAPTER 11 . PROHIBITIONS 

5-253 .16 Wood Furniture Manufacturing 

Package includes : Memoranda between the Air Pollution Control Division and other state 

officials during the rule adoption process . 

Adopted rule with line-out of portions not to be included in this SIP 

submittal establishing RACT for wood furniture manufacturing sources in 

VT.(text lined out by red line are NOT intended to be included as part of 

the Vermont SIP) 

Incorporation by Reference Statement which describes the sections of the 

Code of Federal Regulations which are explicitly mentioned in the 

adopted Vermont rule . These sections describe test methods that 

manufacturers subject to the rule are required to use. 

AMENDMENTS TO 

VERMONT SIP NARRATIVE 

Revised pages 63 through 71 of the SIP Narrative which includes the first 

nine pages of SECTION-6 STRATEGIES FOR AMBIENT AIR 

QUALITY STANDARD ATTAINMENT. (text with changes is 

highlighted in red only to allow easier comparison to the current pages 63 

to 71) 

These revised pages (including the red highlighted text) are intended to 

fully replace the corresponding existing pages in the Vermont SIP 

NARRATIVE document currently approved by EPA. 
AMENDMENTS TO 

VERMONT AIR POLLUTION CONTROL REGULATIONS 

SUBMITTED AS REVISIONS TO THE VERMONT SIP 
State of Vermont 

Department of Fish and Wildlife 

Department of Forests, Parks and Recreation 

Department of Environmental Conservation 

State Geologist 

RELAY SERVICE FOR THE HEARING IMPAIRED 

1-800-253-0191 TDD>Voice 

1-800-253-0195 Voice>TDD 

MEMORANDUM 

TO: Katie Pickens, Staff 

Legislative Committee on Administrative Rules 

a- FROM : Conrad W. Smith, Counsel 

Air Pollution Control Division 

DATE: Jiune 24, 2003 

AGENCY OF NATURAL RESOURCES 

Department of Environmental Conservation 

Air Pollution Control Division 

Bldg. 3 South, 103 South Main Street 

Waterbury, Vermont 05671-0402 

Tel. : (802) 241-3840 

Fax: ~ (802) 241-2590 

http :l/www.anr .state .vt.us/dedair/ 

SUBJECT: Filing of Final Proposed Rules for Wood Furniture Manufacturing #02P-051 

Please accept for filing the enclosed documents for a Final Proposed Rule amending our Air Pollution 

Control Regulations. The rulemaking includes a new §5-253.16, Wood Furniture Manufacturing addition 

to our rules and some minor amendments to §5-101, Definitions. 

Enclosed are clean and annotated texts of both rule sections and signed originals of the required APA 

forms . In addition, I have included a copy of the action taken by the Intra-agency Committee on 

Administrative Rules regarding this rulemaking and a request for an extension of time by the Legislative 

Committee on Administrative Rules. 

Please contact me at 241-3604 if you have any questions about the rule and let me know when the 

Committee will consider the rule and/or the request for extension. 

Regional Offices - Barre/Essex Jct ./Pittsford/RutiandlSpringfieldi'St Johnsbury 
PAVILION OFFICE BUILDING 

MONTPELIER, VERMONT 05609-0201 

STATE OF VERMONT 

OFFICE OF THE SECRETARY 

TEL: (802) 828-3322 

FAX: (802) 828-3320 

AGENCY OF ADMINISTRATION 

INTERAGENCY COMMITTEE ON ADMINISTRATIVE RULES 

TO: Doug Elliott 

ANR 

103 S. Main Street 

Waterbury, Vermont 

FROM: Interagency Committee on Administrative Rules 

DATE : October 29, 2002 

SUBJECT:' Proposed Rule: Air Pollution Control Regulations -

Wood Furniture 

The Interagency Committee on Administrative Rules has made the following decision concerning the 

proposed rule identified above : 

[ X ] The Committee has no objection to the proposed rule being filed with the Secretary of State. 

The public involvement plan was deemed appropriate, with a recommendation for listing 

ways to obtain federal scientific information. 

[ ] 

[] 

The Committee has no objection to the proposed rule being filed with the Secretary of State, 

The Committee requests that the proposed rule not be filed with the Secretary of State until 

the questions listed below have been resolved between you agency or board and the 

Committee. 

[ ] The Committee opposes filing of the proposed rule . 

.-

lenn Ger aneck, Chair 

Interagericy Committee on 

Administrative Rules 

CC : Scott Johnstone, Secretary, Agency of Natural Resources 
State of Vermont 

Department of Fish and Wildlife 

Department of Forests, Parks and Recreation 

Department of Environmental Conservation 

State Geologist 

RELAY SERVICE FOR THE HEARING IMPAIRED 

1-eQ0-253-0191 TDD>Voice 

1-800-253-0195 Voioe>TDD 

AGENCY OF NATURAL RESOURCES 

Department of Environmental Conservation 

Air Pollution Control Division 

Bldg . 3 South, 103 South Main Street 

Waterbury, Vermont 05671-0402 

Tel. : (802) 241-3840 

Fax: (802) 241-2590 

http :/lwww.anr .state .vt.usldec/air/ 

EXTENSION REQUEST 

TO: 

FROM: 

Legislative Committee on Administrative Rules 

Conrad W. Smith, Counsel C w_ 

Air Pollution Control Division 

DATE: June 24, 2003 

SUBJECT: Request for Extension of Time for Adoption of Final Proposed Rules for Wood 

Furniture Manufacturing #02P-051 - Pursuant to 3 V.S.A. §843(c) 

Section 843(c) of Title 3 of the Vermont Statutes provides authority to the Legislative Committee on 

Administrative Rules to provide for an extension of the eight-month time period for the adoption of a rule . 

No standard or guidance is given in the statute for the exercise of this authority by the Committee. It is 

apparently within the sound discretion of the Committee. 

An sixty day extension is requested and should be granted in this case because: 

" Only a minimal extension is necessary - the normal period need only be extended by a month or so to 

allow for consideration of the rule by the Committee and for any actions consistent with or in response 

to the Committee's determination; 

This rulemaking brings within the jurisdiction of the state, and simplifies, requirements of an federal 

rule, concerned with hazardous air pollutants in coatings, sealers and adhesives, which is currently 

applicable to wood furniture manufactures in Vermont by EPA; 

The rulemaking also combines those requirements for hazardous air pollutants with similar 

requirements of an EPA model rule for the Ozone Transport Region concerned with volatile organic 

compounds which are also present in the same coatings, sealers and adhesives and are used by the 

same manufacturers; 

There has been public comment and some revisions were made in response to those comments but, 

by and large, the entities that commented and the participants at the public hearing agreed that the 

rule should be adopted; 

The delay in filing the Final Proposed Rule was caused, in part, by: the complexity of the rule and the 

related federal regulations which meant that it took considerable time to respond to the two formal 

comment letters received; by a staff shortage (two staff members and a chief engineer) in the permit 

section of the Air Pollution Control Division, which along with our enforcement section was 

responsible for technical work on the rule ; and by the Division's counsel being occupied with a 

number of other matters . 

Regional Offices - Barre/Essex Jct ./Pittsford/Rutland/Springfield/St Johnsbury 
State of Vermont 

AGENCY OF NATURAL RESOURCES 

Department of Environmental Conservation 

Department of Fish and Wildlife 

Department of Forests, Parks and Recreation 

Department of Environmental Conservation 

State Geologist 

RELAY SERVICE FOR THE HEARING IMPAIRED 

1-800-253-0191 TDD>Voice 

1-800-253-0195 Voioe>TDD 

MEMORANDUM 

TO: Louise Corliss, APA clerk 

Secretary of State 

FROM: Conrad W. Smith, Counsel 

Air Pollution Control Division 

DATE : June 24; 2003 

SUBJECT: 

Air Pollution Control Division 

Bldg. 3 South, 103 South Main Street 

Waterbury, Vermont 05671-0402 

Tel. : (802) 241-3840 

Fax: (802) 241-2590 

http :llwww.anr .state .vt.us/declair/ 

Filing of Final Proposed Rules for Wood Furniture Manufacturing #02P-051 

Please accept for filing the enclosed documents for a Final Proposed Rule amending our Air Pollution 

Control Regulations . The rulemaking includes a new §5-253.16, Wood Furniture Manufacturing addition 

to our rules and some minor amendments to §5-101, Definitions. 

Enclosed are clean and annotated texts of both rule sections and signed originals of the required APA 

forms. 

Please contact me at 241-3604 if you have any questions about the rule . 

Regional Offices - Barre/Essex Jct ./Pittsford/Rutiand/Springfield/St Johnsbury 
FPCS-02 

FINAL PROPOSAL: COVER SHEET SOS# 

(Do not complete) 

Note: File this form with the appropriate attachments with the Secretary of State and the Legislative Committee 

on Administrative Rules. You must file an adopting page, an economic impact statement, text of the rule, 

annotated text showing the changes to existing rules and an explanation of the changes along with this cover 

sheet. You must also file a scientific information statement and/or incorporation by reference statement if 

applicable. 

Please complete the following. 

1 . Title of final proposal : 

Air Pollution Control Regulations 

Furniture Manufacturing . 

Subchapter II Prohibitions, '5-253 .16 Wood 

2. Proposed Rule # previously assigned by the Secretary of State O.ZP- Or/ 

3 . Agency: 

Agency of Natural Resources : Air Pollution Control Division of the Department 

of Environmental Conservation . 

4. Contact Person (Name, Address & Phone) 

Doug Elliott, Agency of Natural Resources, 103 South Main Street, Bldg . 3 

South, Waterbury, Vermont 05671 (802) 241-3845 . 

5 . Statutory authority for this rule : 

10 V .S .A . 1554(2)and 1558 . 

6. This filing has ® has not El changed since the filing of the proposed rule. If it has changed, please 

attach a letter to this filing explaining in detail what changes were made, citing chapter and section of those 

changes where applicable . 

7. Substantial arguments and considerations were ® were not 0 raised for or against the original 

proposal. Please attach copies of all written submissions and synopses of oral comments received for or against 

the original proposal. If substantial arguments and considerations were raised for or against the original 

proposal or if suggestions with respect to separate requirements for small businesses were made, please attach a 

letter to this filing explaining in detail the reasons for the agency's decision to reject or adopt them. 

8. Give a concise summary explaining the effect of the rule (150 words or less): 

The rule will restrict air emissions of volatile organic compounds and volatile 

hazardous air pollutants from wood furniture manufacturing facilities by 

limiting the content of these pollutants in the various coatings used by the 

industry . The rule will also contain work practice requirements such as 

specifying operator training requirements, spray gun usage limitations- and 

spray gun cleaning procedures . The rule requires the development of a work 

practice implementation plan to ensure proper implementation of the work 

practice standards . 

9. Explanation of why this rule is necessary: 

This rule incorporates two separate federal requirements regulating wood 

furniture manufacturing operations . One is an existing federal regulation that 

is currently in effect and which the Agency is proposing to taking delegation 

of . The second is a regulation Vermont is required to develop pursuant to our 

obligations under the federal Clean Air Act . In both cases, the Agency's 

proposed rule is equivalent to the federal requirements and is not intended to 

be more or less stringent . 

10. List of people, enterprises and government entities affected by this rule: 
FPCS-02 

Large wood furniture manufacturing facilities are the only entities affected by 

this rule . The Agency has identified fifteen (15) potentially affected wood 

furniture manufacturing facilities . Of these, at least eight (8) are expected 

to be able to take an enforceable restriction on their coating usage to avoid 

the regulation with little or no impact on their operations . 

11 . 

12. 

Brief summary of economic impact of this rule (150 words or less): 

Since subject facilities would be expected to comply with the rule by using 

compliant coatings and those coatings are not expected to have a significant 

cost differential from noncompliant coatings, the economic impacts to the 

facilities are expected to be minimal . However, the rule does impose 

additional burdens on the facilities in the form of research and development 

required for reformulating coatings, recordkeeping and reporting requirements 

and the development of several implementation work plans . The Agency's 

proposed rule does not impose any additional requirements beyond the federal 

requirements and the Agency has attempted to streamline these requirements 

where it was possible . 

Date, time and place of hearing(s), if any were held: 

Tuesday, December 10, 2002 

7 :00 PM, Pavilion Auditorium, Pavilion Building, 

109 State Street 

Montpelier, VT 

13 . The deadline for public comments was: 12 / 17 / 0 2 

CERTIFICATION: AS THE ADOPTING AUTHORITY (see 3 V.S .A. § 801(b)(11) for a definition) OF THIS 

RULE, I APPROVE THE CONTENTS OF THIS FILING. 

Date: 06/24/03 

C - l,1e l 

(Sign here) 

Eliabeth McLain 

Secretary, Agency of 

Natural Resources 

(Type name here please) 

Please Check off the following components that are enclosed with this rule (Please check only those that 

apply to this proposed rule). 

® Final Proposed Rule Cover sheet 

® Adopted Page 

® Economic Impact Statement 

® Scientific Information 

® Public Input Statement 

® Incorporation by Reference 

® Text of the Rule 

® Annotated Text 

This box for Secretary of State use only 

El Final Proposed Rule Cover Sheet 

" Adopted Page 

" Economic Impact Statement 

" Scientific Information 

O Plan for Maximizing Public Input 

0 Incorporation by Reference 

0 Text of the Rule 

0 Annotated Text 

These components were filed with this rule Filing Agent's Initials 
ATTACHMENT A 

Changes Made to Proposed Rule # 02P-051 Prior to Filing as a Final Proposed Rule 

In response to the written and oral comments received on this proposed rule during the public 

comment period, including the public hearing, the following changes were made to the rule. For 

a more detailed explanation of the reasons for the changes, please see the Summary of and 

Response to Comments dated June 20, 2003 (attached). 

§ 5-253 .16(a)(3) 

The exemption from the rule for "incidental wood furniture manufacturers" was revised to apply 

to those manufacturers that "use no more than 100 gallons per month of finishing material and 

contact adhesives combined" in response to EPA's concern that Vermont had misinterpreted the 

federal regulation on this point (see EPA comment 6). 

§ 5-253 .16(b) Definitions . "Certified Product Data Sheet (CPDS)"; "Coating Solids (or solids)" . 

Both of the above definitions were changed to specify that, if an equivalent or alternative test 

method to an EPA test method is used to determine the hazardous air pollutant ("HAP") or solids 

content of a material, the method must be approved not only by the Vermont Air Pollution 

Control Division, but also by EPA (see EPA comment 8) . 

§ 5-253.16(c)(2)(i), (c)(2)(iii), (c)(3)(i), and (c)(3)(iii). 

In each of these divisions, the word "using" has been replaced by "use". These changes are for 

grammatical reasons only (see EPA comment 14). 

§ 5-253 .16(c)(4)(ii) . 

This provision has been revised based on a comment from Ethan Allen, Inc. to make clear that, 

for any water based or UV-cured coatings exempted by this subparagraph from § 5-261 of the 

Regulations, the operator has the option of demonstrating compliance with the emission 

standards in § 5-253 .16(c)(1), (2) and (3) by means of monthly weighted averaging of the volatile 

organic compound ("VOC") or HAP content of the coatings, as is allowed for other coatings 

subject to the regulation (see Ethan Allen comment 2). 

§ 5-253.16(e)(1)(iii), (e)(2)(iii) and (e)(3)(ii) . 

In all three divisions, the words "and monitoring requirements" have been added after "By 

achieving equivalent emission reductions through the use of a control system . . ." to make clear 

that any owner or operator that chooses to use a control system to achieve compliance must 

obtain approval from the Air Pollution Control Division not only for the control device, but also 

for any required instruments and methods needed to monitor the operation of the control device 

(see EPA comment 10) . 

§ 5-253 .16(e)(1)(iv) and (e)(2)(iv). 

The words in both of these divisions have been reordered and the phrase "each as provided for 

above" has been added to each. The purpose of this change is to make a clear cross reference 
Attachment A 

Page 2 

between these provisions and the preceding three provisions in the respective subparagraphs (see 

EPA comment 11). 

§ 5-253 .16(g)(1)(iii) . 

The words "or VOC" have been added in three spots and a reference to EPA Method 24, the test 

method for VOCs in coatings, has also been added to clarify that the compliance statements 

regarding continuous coaters in the semi-annual reports must address not only the volatile 

hazardous air pollutant, but also the VOC, content of the coatings used (see EPA comment 1) . 
AP3-00 

ADOPTING PAGE 

Note: This form must be filed three times during the rulemaking process, viz., with the Proposed Rule Cover 

Sheet, Final Proposal Cover Sheet, and Adopted Rule Cover Sheet. 

Please complete the following: 

1 . Title of rule : 

Air Pollution Control Regulations, Subchapter II Prohibitions, '5-253 .16 Wood 

Furniture Manufacturing . 

2 . Agency: 

Agency of Natural Resources : Air Pollution Control Division of the Department 

of Environmental Conservation . 

3 . Agency's reference number, if any: 

4. This is a new rule ® an amendment N a repeal F~ of an existing rule. 

Except for new rules, please give the name of the existing rule and the date on which it was last amended or 

adopted : 

This filing includes both a new rule ('5-253 .16 Wood Furniture Manufacturing) 

and minor 'amendments (adding definitions) to an existing rule ('5-101 

Definitions) which was last amended on August 24, 1998 . 

Note: To satisfy the requirement for an annotated text, an agency must submit the entire rule in annotated 

form with the filings of proposed rules and final proposals. Filing a paragraph or page of a larger rule is not 

sufficient . Similarly, if the rules of the agency have been published as part of the Code of Vermont Rules, the 

agency shall file the annotated text, if possible, using the appropriate page or pages of the Code of Vermont 

Rules as a basis for the annotated version. New rules need not be accompanied by an annotated text . Rules 

which have been comprehensively revised are also exempted from the requirement for an annotated text, 

although a copy of the former rule is required . 
SIS-O 1 

SCIENTIFIC INFORMATION STATEMENT 

Note: In completing the Scientific Information Statement, an agency shall provide a brief summary of the 

scientific information including reference to any scientific studies upon which the proposed rule is based, 

for the purpose of validity . Where this form is insufficient for your purposes, please use additional 

sheets . 

Please complete the following: 

1. Title or subject of rule : 

Air Pollution Control Regulations, Subchapter II Prohibitions, '5-253 .16 Wood 

Furniture Manufacturing. 

2. Agency: 

Agency of Natural Resources : Air Pollution Control Llvisioii of tlle LeNaltllleilt 

of Environmental Conservation . 

3. A brief explanation of scientific information : 

None . 

' 4. Cite source of Scientific Information, and provide instruction on how to obtain this material: 

N/A 
PIM-O1 

PUBLIC INPUT STATEMENT 

Note: Complete this form only if the rule has not been pre-filed with ICAR (If pre-filed, please attach 

documentation of maximization plan). In completing the public input statement, an agency shall 

demonstrate a plan on how to maximize the involvement of the public in the development of the rule. 

Where this form is insufficient for your purposes, please use additional sheets . 

Please complete the following: 

1. Title or subject of rule: 

Air Pollution Control Regulations, Subchapter II Prohibitions, §5-253 .16 Wood 

Furniture Manufacturing . 

2 : Agency: 

Agency of Natural Resources : Air Pollution Control Division of the Department 

of Environmental Conservation . 

3. Please list the steps that will be taken to maximize public involvement in the development of the rule: 

Advertisements and public hearings will be held as required by the APA 

rulemaking process and contact will be initiated with affected groups (e .g ., 

industry, environmental groups, etc .) to involve them in the APA rulemaking 

process for this rule . Additionally, the rule adoption schedule will be 

available online through the APCD's website . 

4. Beyond general advertisements, please list the people and organizations that were notified of the 

hearing and the methods of notification : 

All twelve (12) potentially affected sources will be notified by U.S . mail as 

will the following organizations : Associated Industries of Vermont ; Vermont 

Wood Manufacturers Association ; Vermont Public Interest Research Group ; 

Conservation Law Foundation ; Vermont Natural Resources Council . 

5. Please list the ways in which the rule will be made available to the public once it has been adopted : 

In addition to sending each potentially affected source a copy of the rule, the 

rule will be made available on the APCD's website, it will be available upon 

request and it will be published and available in the next revision of the Air 

Pollution Control Regulations . 

6. Outline of the type of follow-up on public involvement your agency is likely to provide: 

In addition to a Response to Comments, the Division intends to acknowledge and 

directly communicate with each person who makes substantive comments . 
EIS-O1 

ECONOMIC IMPACT STATEMENT 

Note: In completing the economic impact statement, an agency analyzes the anticipated costs and benefits to be 

expected from adoption of the rule. Where this form is insufficient for your purposes, please use additional 

sheets . 

Please complete the following. 

1 . Title or subject of rule: 

Air Pollution Control Regulations, Subchapter II Prohibitions, '5-253 .16 Wood 

Furniture Manufacturing . 

2 . Agency: 

Agency of Natural Resources : Air Pollution Control Division of the Department 

of Environmental Conservation . 

3 . Please list categories of people, enterprises and government entities potentially affected by this rule and 

estimate for each the costs and benefits anticipated. If applicable, include small businesses, and complete 

items 4 and 5 of this sheet as well. Please be as specific as possible, giving full information on your 

assumptions, data base, and attempts to gather other information on the nature of the costs and benefits 

involved. Costs and benefits can include any tangible or intangible entities or forces which will make an 

impact on life without this rule. 

Large wood furniture mfg .facilities are the only entities regulated by this 

rule but coating mfr . will also be impacted since they will be expected to 

develop compliant coatings . 

Since the requirements of this rule have been in effect in other areas for 

several years, the costs associated with research and development of compliant 

coatings will be minimal . Manufacturers will need to conduct quality assurance 

testing that will mainly involve a commitment of time and personnel resources 

by the facilities . No capital cost are anticipated since the reformulated 

compliant coatings are expected to be "drop-in" replacements and the required 

HVLP spray guns are common in the industry . In addition, the compliant 

coatings are not expected to have a significant cost differential from 

noncompliant coatings . 

The rule does impose substantial ongoing recordkeeping and reporting 

requirements and the development of several implementation work plans . The 

Agency's proposed rule does not impose any additional requirements beyond the 

federal requirements and the Agency has streamlined these requirements where it 

was possible . 

No economic benefits are anticipated for the regulated facilities although some 

aspects of the rule may result in greater coating efficiency and thus less 

coating usage . The rule is intended to benefit the general public through 

decreased levels of VOCs and HAPs in the air we breathe . The facility workers 

should also benefit through decreased work exposure . 

4. Please compare the economic impact of the rule with the economic impact of other alternatives to the rule, 

including no rule on the subject or a rule having separate requirements for small business. 

No alternatives were considered . The proposed rule is based on the minimum 

federal requirements and does not impose any additional requirements beyond 

those minimums . 
EIS-O1 

5. Flexibility statement: Please compare the burden imposed on small business by compliance with the rule to 

the burden which would be imposed by alternatives considered in 3 V.S .A. § 832a. 

No alternatives were considered as noted above . 

CERTIFICATION: AS THE ADOPTING AUTHORITY (see 3 V.S .A. § 801(b)(11) for a definition) OF THIS 

RULE, I CONCLUDE THAT THIS RULE IS THE MOST APPROPRIATE METHOD OF ACHIEVING THE 

REGULATORY PURPOSE. IN SUPPORT OF THIS CONCLUSION, I HAVE ATTACHED ALL FINDINGS 

REQUIRED BY 3 V.S.A. § 832a. 

(Sign here) 

Date:06/24/03 Elizabeth McLain 

Secretary, Agency of 

Natural Resouces 

(Type name here please) 
ACS-03 

ADOPTED RULE: COVER SHEET 

SOS# 

(Do Not Complete) 

Note: File this form with the Secretary of State and the Legislative Committee on Administrative Rules. 

You must file an adopting page and the text of the adopted rule with this cover sheet. 

Please complete the following. 

1 . Title or subject of adopted rule: 

Wood Furniture Manufacturing 

2. Proposed Rule # previously assigned by the Secretary of State 0 2 P-051.' 

3 . Agency: 

Dept of Environmental Conservation/Agency of Natural Resources 

4. Statutory authority for this rule : 

10 V.S .A . §554(2) and §558 

5. This filing has E] has not ® changed since the filing of the final proposal. If it has changed, 

please attach a letter to this fiiing explaining in detail what changes were made, citing chapter and 

section of those changes where applicable, including changes in economic impact. 

6. The Legislative Committee on Administrative Rules did not object ® objected 0 to the final 

proposal. 

7. Procedural history of adoption: 

The rule was filed with ICAR on the following date : :09/25/02. 

This rule was filed in proposed form with the secretary of state on the following date: 10 / 17 / 0 2 . 

This rule was published in newspapers of record on 11 / 0 7 / 0 2 and 11 / 14 / 0 2 . 

This rule was the subject of public hearings held as follows (give date, time, and place) : 

Tuesday, December 10, 2002 ; 7 :00 PM, Pavilion Auditorium, 

Pavilion Building,109 State Street,Montpelier, VT 

The deadline for public comment for this rule was 12 / 17 / 0 2 . 

This rule was filed in its final proposed form with the secretary of state and with the Legislative 

Committee on Administrative Rules on 06/24/03. 

This rule was considered by the Legislative Committee on Administrative Rules on 0 7 / 31 / 0 3 . 

This rule is filed in its adopted form on 0 8 / 14 / 0 3 . 

Revised 2003 
A%-3-U3 

The effective date of this rule will be 0 3 / O 1 / 0 4 (must be no sooner than 15 days following the. 

filing of the adopted rule). 

.. .~ . .~ . ._. . . 

CERTIFICATION: AS THE ADOPTING AUTHORITY (see 3 V.S.A. § 801(b)(11) for a definition) OF 

THIS RULE, T_ HEREBY CERTIFY THAT THE PROCEDURAL . RR QT TTR RMRNTC QF TTTT .R I -.-

CHAPTER 25 HAVE BEEN MET. I ALSO APPROVE THE CONTENTS OF THIS FILING. 

Date: 08/14/03 

(Sign here) . 

Elizabeth ft; McLain, Sec . 

Agency of Natural Resourc 

(Type name here please) 

An adopting page and a text of the rule were filed with this coversheet APA Clerk's Initials' 

Revised 2003 
ADOPTING PAGE 

AP3-00 

Note: This form must be filed three times during the rulemaking process, viz., with the Proposed Rule 

Cover Sheet, Final Proposal Cover Sheet, and Adopted Rule Cover Sheet . 

Alcasc CviiIFi~,t~ li~,vrt~ o t1-.v ~l

F 1

0ii1?' ' ui~ . v'viiig : 

1 . Title of rule : 

Wood Furniture Manufacturing 

2. Agency: . 

Department of Environmental Conservation / Agency of Natural Resources 

. Agency's reference number, if any : 

[none] 

4. This is a(n) 

X Amendment- changes to an already existing rule. [Minor admendments to §5-101 Definitions] 

X New rule- adopts a rule that did not previouslv exist. fNew SS-253 .16 Wood Furniture Manufacturin¢1 

F~ Repeal-repeals a rule that previously existed. 

Except for new rules, please give the name of the existing rule and the date on which it was last amended or 

adopted: Air Pollution Control Regulations, Subchapter 1, §5-101 Definitions; Last amended August 24, 

1998. 

Note: To satisfy the requirement for an annotated text, an agency must submit the entire rule in 

annotated form with the filings of proposed rules and final proposals. Filing a paragraph or page of a larger 

rule is not sufficient. Similarly, if the rules of the agency have been published as part of the Code of 

Vermont Rules, the agency shall file the annotated text, if possible, using the appropriate page or pages of 

the Code of Vermont Rules as a basis for the annotated version. New rules need not be accompanied by an 

annotated text . 

. Revised 2003 
ADOPTED REGULATION §5-253 .16 

AGENCY OF NATURAL RESOURCES 

Waterbury, Vermont 

ENVIRONMENTAL PROTECTION REGULATIONS 

CHAPTER 5 

AIR POLLUTION CONTROL 

Subchapter II . Prohibitions 

5-253 .16 Wood Furniture Manufacturing 

(a) Applicability . 

(1) This subsection applies to all stationary sources that are 

engaged, either in part or in whole, in the manufacture of wood 

furniture or wood furniture components, except as provided in 

paragraphs (a) (2) and (3) below . 

(2) A stationary source engaged, either in part or in whole, in the 

manufacture of wood furniture or wood furniture components that 

has allowable VOC emissions of less than 25 tons per year and 

that is not located at a major source of hazardous air pollutants 

is exempt from all provisions of this subsection, except for 

paragraph (c) (4) regarding the control of individual hazardous 

air contaminants . 

(3) Stationary sources that are primarily engaged in the manufacture 

of products other than wood furniture or wood furniture 

components and that use no more than 100 gallons per month of 

finishing material er and contact adhesives combined in the 

manufacture of wood furniture or wood furniture components are 

not subject to this subsection, except that each such source 

shall maintain records of monthly finishing material and adhesive 

usage . 

(b) Definitions . For the purpose of this subsection, the following 

definitions apply, in addition to those of Section 5-101 of this 

chapter : 

"Adhesive" means any chemical substance that is applied for the purpose 

of bonding two surfaces together other than by mechanical means . 

Adhesives shall not be considered coatings or finishing materials . 

Products used on humans and animals, adhesive tape, contact paper, or 

any other product with an adhesive incorporated onto or in an inert 

substrate shall not be considered adhesives . 

"Aerosol Adhesive" means an adhesive that is dispensed from a 

pressurized container as a suspension of fine solid or liquid particles 

in gas . 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-1 
ADOPTED REGULATION §5-253.16 

"As Applied" means the VOC, HAP and solids content of the coating or 

contact adhesive that is actually used for coating or gluing the 

substrate. It includes the contribution of materials used for in-house 

dilution of the coating or contact adhesive . 

"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 . 

"Certified Product Data Sheet (CPDS)" means documentation furnished by 

coating or adhesive suppliers or an outside laboratory that provides 

the HAP content of a finishing material, contact adhesive, or solvent, 

by percent weight, measured using EPA Method 311, or an equivalent or 

alternative method approved by the Air Pollution Control Officer and 

EPA; the VOC content and solids content of a finishing material, 

strippable booth coating, solvent or contact adhesive, by percent 

weight, measured using EPA Method 24, or an alternative or equivalent 

method approved by the Air Pollution Control Officer; and the density, 

measured by EPA Method 24 or an alternative or equivalent method 

approved by the Air Pollution Control Officer. Therefore, the 

reportable VOC and HAP contents should represent the maximum aggregate 

emissions potential of the finishing material, strippable booth 

coating, adhesive, or solvent in concentrations greater than or equal 

to 1 .0 percent by weight or 0 .1 percent for VOCs or HAPs that are 

carcinogens, as defined by the Occupational Safety and Health 

Administration Hazard Communication Standard (29 CFR 1910), as 

formulated . 

"Cleaning Operations" means operations in which organic solvent is used 

to remove coating materials or adhesives from equipment used in wood 

furniture manufacturing operations . 

"Coating" means a protective, decorative, or functional film applied in 

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

to, paints, topcoats, varnishes, sealers, stains, washcoats, basecoats, 

enamels, inks, and temporary protective coatings . 

"Coating Application Station" means the part of a coating operation 

where the coating is applied, e .g ., a spray booth . 

"Coating Operation" means those activities in which a coating is 

applied to a substrate and is subsequently air-dried, cured in an oven, 

or cured by radiation . 

"Coating Solids (or solids)" means the part of the coating which 

remains after the coating is dried or cured ; solids content is 

determined using data from the EPA Method 24, or an equivalent or 

alternative method approved by the Air Pollution Control Officer and 

EPA . 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-2 
ADOPTED REGULATION §5-253 .16 

"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 . 

"Continuous Coater" means a finishing system that continuously applies 

finishing materials onto furniture parts moving along a conveyor . 

Finishing materials that are not transferred to the part are recycled 

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

a continuous coater including spraying, curtain coating, roll coating, 

dip coating, and flow coating. 

"Conventional Air Spray" means a spray coating method in which the 

coating is atomized by mixing it with compressed air and applied at an 

air pressure greater than 10 pounds per square inch (gauge) at the 

point of atomization . Airless and air assisted airless spray 

technologies are not conventional air spray because the coating is not 

atomized by mixing it with compressed air . Electrostatic spray 

technology is also not considered conventional air spray because an 

electrostatic charge is employed to attract the coating to the 

workpiece . 

"Enamel" means a coat of colored material, usually opaque, 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 . 

"Equipment Leak" means emissions of volatile organic compounds or 

volatile hazardous air pollutants from pumps, valves, flanges, or other 

equipment used to transfer or apply coatings, adhesives, or organic 

solvents . 

"Finishing Material" means a coating used in the wood furniture 

industry . Such materials include, but are not limited to, stains, 

basecoats, washcoats, enamels, sealers, and topcoats . 

"Finishing Operation" means those operations in which a finishing 

material is applied to a substrate and is subsequently air-dried, cured 

in an oven, or cured by radiation. 

"Foam Adhesive" means a contact adhesive used for gluing foam to 

fabric, foam to foam, and fabric to wood . 

"Nonporous Substrate" means a surface that is impermeable to liquids . 

Examples include metal, rigid plastic, flexible vinyl, and rubber . 

"Normally Closed Container" means a container that is closed unless an 

operator is actively engaged in activities such as emptying or filling 

the container. 

"Organic Solvent" means a liquid containing volatile organic compounds 

or volatile hazardous air pollutant that is used for dissolving or 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-3 
ADOPTED REGULATION §5-253 .16 

dispersing constituents in a coating or contact adhesive, adjusting the 

viscosity of a coating or contact adhesive, or cleaning equipment . 

When used in a coating or contact adhesive, the organic solvent 

evaporates during drying and does not become a part of the dried film . 

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

substrate before additional coats of finishing material are applied. 

Special purpose finishing materials that are used in some finishing 

systems to optimize aesthetics are not sealers . 

"Solvent" means a liquid used in a coating or contact adhesive to 

dissolve or disperse constituents and/or to adjust viscosity. It 

evaporates during drying and does not become a part of the dried film . 

"Stain" means any color coat having a solids content by weight of no 

more than 8 .0 percent that is applied in single or multiple coats 

directly to the substrate. It includes, but is not limited to, 

nongrain raising stains, equalizer stains, prestains, sap stains, body 

stains, no-wipe stains, penetrating stains, and toners . 

"Strippable Spray Booth Coating" means a coating that : (1) is applied 

to a spray booth wall to provide a protective film to receive overspray 

during finishing operations ; (2) that is subsequently peeled off and 

disposed ; and (3) by achieving (1) and (2), reduces or eliminates the 

need to use organic solvents to clean spray booth walls . 

"Substrate" means the surface onto which a coating or contact adhesive 

is applied (or into which a coating or contact adhesive is 

impregnated) . 

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

contact adhesives (to reduce viscosity, color strength, and solids, or 

to modify drying conditions) . 

"Topcoat" means the last film-building finishing material that is 

applied in a finishing system . 

"Touchup and Repair" means the application of finishing materials to 

cover minor finishing imperfections . 

"Volatile Hazardous Air Pollutant (VHAP)" means any volatile hazardous 

air pollutant listed in Table 2 to Subart JJ of Title 40 of the Code of 

Federal Regulations (CFR) Part 63 . 

"Washcoat" means a transparent special purpose finishing material 

having a solids content by weight of 12 .0 percent by weight or less . 

Washcoats are applied over initial stains to protect, to control color, 

and to stiffen the wood fibers in order to aid sanding . 

"Washoff Operations" means those operations in which organic solvent is 

used to remove coating from wood furniture or a wood furniture 

component. 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-4 
ADOPTED REGULATION §5-253 .16 

"Wood Furniture" means any product made of wood, a wood product such as rattan or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes : 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599, or 5712 . 

AWood Furniture Component@ means any part that is used in the manufacture of wood furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions, and laminated tops . 

AWood Furniture Manufacturing Operations" means the finishing, gluing, cleaning, and/or washoff operations associated with the production of wood furniture or wood furniture components . 

(c) Standards 

(1) VOC Emission Limitations . Each owner or operator of a stationary 

source subject to this subsection which has allowable emissions of 25 tons per year or more of VOC shall limit VOC emissions from wood furniture manufacturing operations by : 

(i) Using only topcoats containing no more than 1 .8 lbs VOCIlb solids, as applied, and sealers containing no more than 1 .9 lbs VOCIlb solids, as applied, or the equivalent . Compliance shall be demonstrated by any of the compliance methods in (e)(1) ; 

(ii) Using acid-cured alkyd amino vinyl sealers containing no 

more than 2 .3 lbs VOCIlb solids, as applied, and acid-cured 

alkyd amino conversion varnish topcoats containing no more than 2 .0 lbs VOCIlb solids, as applied, or the equivalent . 

Compliance shall be demonstrated by any of the compliance 

methods in (e)(1) ; and 

(iii) Using only strippable spray booth coatings containing no 

more than 0 .8 lbs VOCIlb solids, as applied. 

(2) AZZA F'arh r, r.Tncr nr 

n= Pratnr nf a :9q5tire,e ciih~crt tn f-hi c ci;], .Spc;Li nn cTh ; r-h 

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l_11 T1 .ca nnl~i atainc

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fnrmal H PhWr'la nracont 

x i n fha i y r.rhcn i t i c 

Rule as Ad-opted (August 14, 1003 VGF46iQR) 

Page -2-6 
~ r~l i Prl _ Tha ctyrPnP r-nntcnt nf a ~ L ' y chal 1 

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nv Pmiccinnfi of vnlatila ha7arrlrYrn,c air rnntaminantc rncorl 

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n1pPr f- r rnm 1 i Ac Tri th tha ctanr`larrlc oatahl i ahcsL_ n 

~~^r^g~,t hC (r) ll 1 _ /71 anrl 4"2~ nf th i a ciihcanf i nn 

(d) Work Practice Standards 

(1) Work practice implementation plan . Each owner or operator of a 

stationary source subject to this subsection shall prepare, 

maintain and adhere to a written work practice implementation 

plan that defines environmentally desirable work practices for 

each wood furniture manufacturing operation and for all other 

finishing, gluing, cleaning and washoff operations at the source 

and addresses each of the work practice standards presented in 

sub paragraphs (2) through (11) of this paragraph. The plan 

shall be developed no more than 60 days after the compliance date 

for each subject source . The written work practice implementation 

plan shall be available for inspection by the Air Pollution 

Control Officer upon request . If the Air Pollution Control 

Officer determines that the work practice implementation plan 

does not adequately address each of the topics specified in 

paragraphs (2) through (11) of this paragraph, as applicable, or 

that the plan does not include sufficient mechanisms for ensuring 

that the work practice standards are being implemented, the Air 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-7 
ADOPTED REGULATION §5-253 .16 

Pollution Control Officer may require the owner or operator to 

modify the plan . 

(2) Operator training course . Each owner or operator of a stationary 

source subject to this subsection shall train all new and 

existing personnel, including contract personnel, who are 

involved in finishing, gluing, cleaning, and washoff operations 

or implementation of the requirements of this subsection . All 

new personnel shall be trained upon hiring . All existing 

personnel shall be trained within 6 months of the effective date 

of this subsection . All personnel shall be given refresher 

training annually . The owner or operator shall maintain a copy 

of the training program with the work practice implementation 

plan . The training program shall include, at a minimum, the 

following : 

(i) A list of all current personnel by name and job description 

that are required to be trained; 

(ii) An outline of the subjects to be covered in the initial and 

refresher training for each position or group of personnel; 

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

annual refresher training that include, at a minimum, 

appropriate application techniques, appropriate cleaning and 

washoff procedures, appropriate equipment setup and 

adjustment to minimize finishing material usage and 

overspray, and appropriate management of cleanup wastes ; and 

(iv) A description of the methods to be used at the completion of 

initial or refresher training to demonstrate and document 

successful completion . 

(3) Inspection and maintenance plan . Each owner or operator of a 

stationary source subject to this subsection shall prepare, 

maintain and adhere to a written equipment leak inspection and 

maintenance plan that specifies : 

(i) A minimum visual inspection frequency of once per month for 

all equipment used to transfer or apply coatings, adhesives, 

or organic solvents ; 

(ii) An inspection schedule ; 

(iii) Methods for documenting the date and results of each 

inspection and any repairs that were made ; 

(iv) The timeframe between identifying the leak and making the 

repair, which adheres, at a minimum, to the following 

schedule : 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-8 
ADOPTED REGULATION §5-253.16 

(A) A first attempt at repair (e .g ., tightening of packing glands) shall be made no later than five calendar days after the leak is detected ; and 

(B) Final repairs shall be made within 15 calendar days after the leak is detected, unless the leaking 

equipment is to be replaced by a new purchase, in which case repairs shall be completed within three months . 

(4) Cleaning and washoff solvent accounting system . Each owner or operator of a stationary source subject to this subsection shall develop and use an organic solvent accounting form to record : 

(i) The quantity and type of organic solvent used each month for 

washoff and cleaning ; 

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

washoff; and 

(iii) The quantity of spent organic solvent generated from each 

washoff and cleaning operation each month, and whether it is 

recycled onsite or disposed offsite . 

4-5-~ F.rh 

ntaner Or nt~aratnr nf a 

z . SiI h~ ort tn thi 

ciihCPrtinrn Chal l nnt rtca rlaaninn nr wachnff cr,lTroni-c thnt 

rnntai n an~7 nf i-ha p n] 1 r,tantc 1 i ctarl i n TAhl o A tn C,1F,A ri- .77 r,f 

7i tl a 4(1 nf tha C"nria nf Fariaral Ragiil ati nnq (r " FR~ Pari- F'2 , n 

rnnrantrati on -, crnh4 art tn MRT1C rPnnri-i nr. ac rcrrr, ; rod hv C11Zt, 7A 

(6) Spray booth cleaning . Each owner or operator of a stationary 

source subject to this subsection 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 . However, when the spray booth coating or other protective material used to cover the 

booth is being replaced, the owner or operator shall use no more than 1 .0 gallon of organic solvent per booth to prepare the surface of the booth prior to applying the booth coating. 

(7) Storage requirements . Each owner or operator of a stationary 

source subject to this subsection shall use normally closed containers for storing finishing, gluing, cleaning, and washoff materials . 

(8) Application equipment requirements . Each owner or operator of a 

stationary source subject to this subsection shall not use conventional air spray guns to apply finishing materials, except 

as provided below : 

(i) When applying finishing materials that have a VOC content no greater than 1 .0 lb VOC/lb solids, as applied; 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-9 
ADOPTED REGULATION §5-253 .16 

(ii) When performing touchup and repair under the following 

conditions : 

(A) The touchup and repair occurs after completion of the 

finishing operation; or 

(B) The touchup and repair occurs after the application of 

stain and before the application of any other type of 

finishing material, and the materials used for touchup 

and repair are applied from a container that has a 

volume of no more than 2 .0 gallons . 

(iii) When the spray gun is aimed and triggered automatically, not 

manually ; 

(iv) When emissions from the coating application station are 

directed to a VHAP or VOC control device ; 

(v) When the conventional air gun is used to apply finishing 

materials and the cumulative total usage of that finishing 

material is no more than 5 .0 percent of the total gallons of 

finishing material used during the semiannual reporting 

period ; or 

(vi) When the conventional air gun is used to apply stain on a 

part for which it is technically or economically infeasible 

to use any other spray application technology and the Air 

Pollution Control Officer has approved, in writing, a 

submission from the owner or operator demonstrating such 

infeasibility on the basis, alone or in combination, that : 

(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 . 

(9) Line cleaning . Each owner or operator of a stationary source 

subject to this subsection shall pump or drain all organic 

solvent used for line cleaning into a normally closed container. 

(10) Gun cleaning . Each owner or operator of a stationary source 

subject to this subsection shall collect all organic solvent used 

to clean spray guns into a normally closed container. 

(11) Washoff operations . Each owner or operator of a stationary 

source subject to this subsection shall control emissions from 

washoff operations by : 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-10 
ADOPTED REGULATION §5-253 .16 

(i) using normally closed tanks for washoff; and 

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

as much solvent as possible . 

(e) Compliance procedures and monitoring requirements 

(1) Each owner or operator of a stationary source subject to this subsection must demonstrate compliance with the provisions of (c)(1)(i) and (c)(1)(ii), as applicable, by using one of the following methods : 

(i) By use of compliant topcoats and sealers, including acidcured topcoats and sealers, as demonstrated by maintaining 

current certified product data sheets for each topcoat and 

sealer and by performing, prior to use, calculations to 

account for any dilution ; 

(ii) By use of topcoats and sealers with a monthly weighted 

average for each that achieves the emission limitations in pounds of VOC per pound solids of 1 .8 for topcoats and 1 .9 

for sealers, or 2 .3 for acid-cured alkyd amino vinyl sealers 

and 2 .0 for acid-cured alkyd amino conversion varnish 

topcoats, as demonstrated by using the following formula and 

by maintaining current certified product data sheets for 

each topcoat and sealer and by performing, prior to use, 

n 

21 M, C, 

i-1 Evoc = 

calculations to account for any dilution : 

where : 

EVOC= the average VOC content of the topcoats or 

sealer, respectively, in lbs VOC/lb solids ; 

C = the VOC content of a particular topcoat or 

sealer, in lbs VOC/lb solids, as applied; 

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

topcoat or sealer used during the monthly 

averaging period . 

(iii) By achieving equivalent emission reductions through the use of a control system and monitoring requirements approved by the Air Pollution Control Officer; or 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-11 
ADOPTED REGULATION §5-253.16 

(iv) By achieving equivalent emission reductions through the use 

of any combination, approved by the Air Pollution Control 

officer, of compliant topcoats and sealers, an averaging 

approach and a control system, each as provided for above . 

(9) Far-h ncTnar or n= aratnr nf a^,,h J crt tn th ; c 

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(i ) R~7 in-,P nf rnm= 1 iant ar7hPCivac~ nr 

( i j_) Rv ;;r-hi Pvi ngPqrni val Pnt Pmi cci nn rPrlr,rti nnc thrrn,nh H-,'= nec 

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1 

(f) Record keeping requirements . The owner or operator of a stationary 

source subject to this subsection shall maintain records of the 

following and shall retain such records for a minimum period of five 

years : 

(1) A certified product data sheet for each finishing material, 

thinner, contact adhesive, and strippable spray booth coating 

used at the source . 

(3) 

(4) 

(5) 

(6) 

'__^__ w-_^_7 matPria 1 0 th i nnar, anrl 

cntirrP . 

ThP ; ;4A F rnntPnt in lh [TF-TAPfII-, en1 ir-IT, g-,, app7j,~d nf o~r,h 

The VOC content in lb VOC/lb solids, as applied, of each topcoat, 

sealer, and strippable spray booth coating used at the source . 

The quantity of each finishing material, thinner, contact 

adhesive, and strippable spray booth coating used at the source 

each month. 

For stationary sources demonstrating compliance with (c)(1)(i), 

(c)(1)(ii), (c)(2)(i), or (c)(3)(i) through monthly averaging, 

the averaging calculation completed in accordance with (e)(1)(ii) 

and (e)(2)(ii), as applicable, for each month . 

For stationary sources with continuous coaters demonstrating 

compliance with (c) (1) (i) , (c) (1) (ii) , (c) (2) (i) , or (c) (3) (i) 

through the use of compliant coatings where the VHAP or VOC 

content of the coating in the reservoir is not calculated from 

records, the owner or operator shall maintain records of the 

following: 

(i) Solvent and coating additions to the continuous coater 

reservoir; 

(ii) Viscosity measurements ; and 

(iii) Data demonstrating that viscosity is an appropriate 

parameter for demonstrating compliance, as applicable . 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-13 
ADOPTED REGULATION §5-253 .16 

(7) For stationary sources demonstrating compliance with (c)(1)(i), 

(c) (1) (ii) , (c) (2) (i) , or (c) (3) (i) by use of a control device, 

any records required by the Air Pollution Control Officer. 

(8) The work practice implementation plan and all records associated 

with fulfilling the requirements of that plan, including, but not 

limited to : 

(i) Records demonstrating that the operator training program is 

in place; 

(ii) Records collected in accordance with the inspection and 

maintenance plan ; 

(iii) Records associated with the cleaning solvent accounting 

system ; 

(iv) 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 semiannual period ; and 

(v) Copies of documentation such as logs developed to 

demonstrate that the other provisions of the work practice 

implementation plan are followed . 

(9) All compliance status reports and all other information submitted 

with those reports . 

(g) Reporting requirements . 

(1) The owner or operator of a stationary source subject to this 

subsection shall submit a semi-annual compliance status report 

covering the previous 6 months of wood furniture manufacturing 

operations . The semiannual reports shall cover the periods 

January 1 through June 30 and July 1 through December 31 . The 

first report shall be submitted within 30 calendar days after the 

end of the 6-month period in which the source becomes subject to 

this subsection . Subsequent reports shall be submitted within 30 

calendar days after the end of the 6-month reporting periods . 

The semiannual reports shall include : 

(i) For stationary sources demonstrating compliance with 

(c) (1) (i), (c) (1) (ii), (c) (2) (i), or (c) (3) (i) through the 

use of compliant coatings, a statement that compliant 

coatings and thinners have been used each day in the 

semiannual reporting period ; 

(ii) For stationary sources demonstrating compliance with 

(c) (1) (i) , (c) (1) (ii) , (c) (2) (i) , or (c) (3) (i) through 

monthly averaging, the averaging calculations completed in 

accordance with ( e ) (1) (ii) and ( e ) (2) (ii) , as applicable, 

for each month within the semiannual reporting period and a 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-14 
ADOPTED REGULATION §5-253 .16 

statement that the source is in compliance with the 

respective standard ; 

(iii) For stationary sources with continuous coaters demonstrating 

compliance with (c) (1) (i) , (c) (1) (ii) , (c) (2) (i) or 

(c)(3)(i) through the use of compliant coatings : 

(A) A statement that compliant coatings, as determined by 

the VHAP or VOC content of the coating in the 

reservoir and the VHAP or VOC content as calculated 

from records, and compliant thinners have been used 

each day in the semiannual reporting period ; or 

(B) A statement that compliant coatings, as determined by 

the VHAP or VOC content of the coating in the 

reservoir, have been used each day in the semiannual 

reporting period . Additionally, a statement that the 

viscosity of the coating in the reservoir has not been 

less than the viscosity of the initial coating, that 

is, the coating that is initially mixed and placed in 

the reservoir, for any day in the semiannual reporting 

period . 

A stationary source is in violation of the standard when a 

sample of the as-applied coating exceeds the applicable 

limit, as determined using EPA Method 311 and/or Method 24, 

or the viscosity of the coating in the reservoir is less 

than the viscosity of the initial coating. 

(iv) For stationary sources demonstrating compliance with 

(c) (1) (i) , (c) (1) (ii) , (c) (2) (i) , or (c) (3) (i) by use of a 

control device, an excess emissions report that includes all 

elements required by the Air Pollution Control Officer. 

l Fnr cnr'nrrac rlcmnnctrati nn rnmnl i ;:inr-c w i th 

(c-) (7~ ,~i i ~ nr (r(1 " 3 ui i ) t-1-lrnligh thc li cc nf (-nmr,l i ant 

e&jqt-aez arn'hACicra,g,r a ctatamant that rnmnl i ant ----'---'- ~. v u ~. a ~ ~. 

anlhacitrPC haNro hPPn 11cPr1 aar,1-1 riaw in f-1-lo comi~nnl,cl 

rap nrt i ng YIP d ; 

(~Ti ,~ Fnr :9 t_ a t!j 29 19 ±QY Cynlirrac rlcmnnetrat'j nn rr,mpl ; nn(rc o r ; +-}, 

(r-~7ui i ~ r nr (r-) (~) ( j ) hx7 licc nf a rnntrnl rrlc-K r ; r- i= fnr 

- ar-1h PQ7~JP'F .'an PY(`PQc PmlcclnnQ rCYlnrt th~t in rll,rlcc 

all alamantc rarrliirarl h v thQ nffin~ 

(vii) A statement that compliant strippable spray booth coatings 

have been used each day in the semiannual reporting period ; 

(viii) A statement that the work practice implementation plan 

is being followed ; and 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-15 
ADOPTED REGULATION §6-263.16 

(ix) If the stationary source was in violation of any provision 

of this subsection, the measures taken to bring the source 

into compliance . 

(h) Compliance . A stationary source subject to this subsection shall be in 

compliance on or before the effective date of this rule, immediately 

upon commencement of operation, or when the source becomes subject to 

this subsection, whichever occurs later . 

ADOPTED : 

Date : By : 

Elizabeth McLain, Secretary 

Agency of Natural Resources 

Rule as Adopted (August 14, 2003 version) 

Effective March 1, 2004 Page 2-16 
IBR-01 

INCORPORATION BY REFERENCE STATEMENT 

Please complete the following, in addition to filing a copy.of any material incorporated by 

reference in this rule. 

1 . Title or subject of rule: 

Air Pollution Control Regulations, Subchapter II Prohibitions, 

'5-253 .16 Wood Furniture Manufacturing . 

2. Agency: 

Agency of Natural Resources: Air Pollution Control Division of the Department of 

Environmental Conservation 

3. Description of material to be incorporated by reference: 

Sections of the Code of Federal Regulations which are explicitly mentioned in the new 

rule which describe certain test methods that wood furniture manufacturers would are 

subject to the rule are required to use: Method 24, Determination of Volatile Matter 

Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings, 

found at 40 CFR 60 Appendix A; and Method 311, Analysis of Hazardous Air Pollutant 

Compounds in Paints and Coatings by Direct Injection into a Gas Chromatograph, found 

at 40 CFR 63 Appendix A 

4. Please explain how the material to be incorporated by reference can be obtained by 

the public and at what cost: 

The newly incorporated test methods are on file at the Agency of Natural Resources, 

Department of Environmental Conservation, Air Pollution Control Division, 103 South 

Main Street, Waterbury, Vermont 05671, (802) 241-3840 . The materials are also on file 

with the Secretary of State at the Redstone Building, 26 Terrace Street, Montpelier, VT 

05609-1101, (802) 828-2363 . They are available from those agencies at no cost, or for 

the cost of copying if specified in on the applicable public document rules for the agency 

from which the copies are sought . 

The methods are also at http ://www.access.gpo.gov/nara/cfr/cfr-table-search .html#pagel 

1 

06/23/03 

IBR Statement for Final Proposed Rule 
IBR-O1 

5. Please explain any modification in the matter incorporated, e.g., whether only part 

of the material supplied with this filing is adopted, and if so, which part: 

Each of the entire test methods is incorporated. 

6. Please explain why the agency decided not to reproduce the incorporated material 

in full text of the rule. 

The test methods are technical and would make the Vermont rules unnecessarily long. 

Certification : As the adopting authority (see 3 V.S .A. §801(b)(11)for definitions) of this rule, I 

hereby certify that the text of the matter incorporated has been reviewed by Conrad Smith, an 

official of the Agency. I further certify that the Agency has the capacity and intent to enforce the 

rule. 

Elizabeth McLain,. Secretary 

Agency of Natural Resources 

Date: 

2 

06/23/03 

IBR Statement for Final Proposed Rule 
1180 

METHOD 24 - DETERMINATION OF VOLATILE MATTER CONTENT, 

WATER CONTENT, DENSITY, VOLUME SOLIDS, AND 

WEIGHT SOLIDS OF SURFACE COATINGS 

1 .0 Scope and Application . 

1 .1 Analytes . 

Analyte CAS No . 

Volatile organic compounds No CAS Number assigned 

Water 7732-18-5 

1 :2 Applicability . This method is applicable for the 

determination of volatile matter content, water content, 

density, volume solids, and weight solids of paint, varnish, 

lacquer, or other related surface coatings . 

1 .3 Precision and Bias . Intra- and inter-laboratory 

analytical precision statements are presented in Section 

13 .1 . No bias has been identified . 

2.0 Summary of Method . 

2 .1 Standard methods are used to determine the 

volatile matter content, water content, density, volume 

solids, and weight solids of paint, varnish, lacquer, or 

other related surface coatings . 

3 .0 Definitions . 

3 .1 Waterborne coating means any coating which 

contains more than 5 percent water by weight in its volatile 

fraction . 
1181 

3 .2 Multicomponent coatings are coatings that are 

packaged in two or more parts, which are combined before 

application . Upon combination 

the coating chemically reacts, 

a coreactant from one part of 

at ambient conditions, with a 

coreactant from another part of the coating . 

3 .3 Ultraviolet (UV) radiation-cured coatings are 

coatings which contain unreacted monomers that are 

polymerized by exposure to ultraviolet light . 

4 .0 Interferences . 

5 .0 Safety . 

[Reserved] 

5 .1 Disclaimer . This method may involve hazardous 

materials, operations, and equipment . This test method may 

not address all of the safety problems associated with its 

use . It is the responsibility of the user of this test 

method to establish appropriate safety and health practices 

and to determine the applicability of regulatory limitations 

prior to performing this test method . 

5 .2 Hazardous Components . Several of 

that may be contained in 

method may be irritating 

heptane) or may be toxic 

the compounds 

the coatings analyzed by this 

or corrosive to tissues (e .g ., 

(e .g ., benzene, methyl alcohol) . 

Nearly all are fire hazards . Appropriate precautions can be 

found in reference documents, such as Reference 3 of Section 

16 .0 . 
1182 

6 .0 Equipment and Supplies . 

The equipment and supplies specified in the ASTM 

methods listed in Sections 6 .1 through 6 .6 (incorporated by 

reference - see § 60 .17 for acceptable versions of the 

methods) are required : 

6 .1 ASTM D 1475-60, 80, or 90, Standard Test Method 

for Density of Paint, Varnish, Lacquer, and Related 

Products . 

6 :2 ASTM D 2369-81, 87, 90, 92, 93, or 95, Standard 

Test Method for Volatile Content of Coatings . 

6 .3 ASTM D 3792-79 or 91, Standard Test Method for 

Water Content of Water Reducible Paints by Direct Injection 

into a Gas Chromatograph . 

6 .4 ASTM D 4017-81, 90, or 96a, Standard Test Method 

for Water in Paints and Paint Materials by the Karl Fischer 

Titration Method . . 

6 .5 ASTM 4457-85 (Reapproved 1991), Standard Test 

Method for Determination of Dichloromethane and 1,1,1-

Trichloroethane in Paints and Coatings by Direct Injection 

into a Gas Chromatograph . 

6 .6 ASTM D 5403-93, Standard Test Methods for 

Volatile Content of Radiation Curable Materials . 

7 .0 Reagents and Standards . 
1183 

7 .1 The reagents and standards specified in the ASTM 

methods listed in Sections 6 .1 through 6 .6 are required . 

8 .0 Sample Collection, Preservation, Storage, and 

Transport . 

8 .1 Follow the sample collection, preservation, 

storage, and transport procedures described in Reference 1 

of Section 16 .0 . 

9 .0 Quality Control . 

9 :1 Reproducibility (NOTE : Not applicable to UV 

radiation-cured coatings) . The variety of coatings that may 

be subject to analysis makes it necessary to verify the 

ability of the analyst and the analytical procedures to 

obtain reproducible results for the coatings tested . 

Verification is accomplished by running duplicate analyses 

on each sample tested (Sections 11 .2 through 11 .4) and 

comparing the results with the intra-laboratory precision 

statements (Section 13 .1) for each parameter . 

9 .2 Confidence Limits for Waterborne Coatings . 

Because of the inherent increased imprecision in the 

determination of the VOC content of waterborne coatings as 

the weight percent of water increases, measured parameters 

for waterborne coatings are replaced with appropriate 

confidence limits (Section 12 .6) . These confidence limits 
1184 

are based on measured parameters and inter-laboratory 

precision statements . 

10 .0 Calibration and Standardization . 

10 .1 Perform the calibration and standardization 

procedures specified in the ASTM methods listed in Sections 

6 .1 through 6 .6 . 

11 .0 Analytical Procedute . 

Additional guidance can be found in Reference 2 of 

Section 16 .0 . 

, 11 .1 Non Thin-film Ultraviolet Radiation-cured (UV 

radiation-cured) Coatings . 

11 .1 .1 Volatile Content . Use the procedure in ASTM D 

5403 to determine the volatile matter content of the coating 

except the curing test described in NOTE 2 of ASTM D 5403 is 

required . 

11 .1 .2 Water Content . To determine water content, 

follow Section 11 .3 .2 . 

11 .1 .3 Coating Density . To determine coating 

density, follow Section 11 .3 .3 . 

11 .1 .4 Solids Content . To determine solids content, 

follow Section 11 .3 .4 . 

11 .1 .5 To determine if a coating or ink can be 

classified as a thin-film UV cured coating or ink, use the 

equation in Section 12 .2 . If C is less than 0 .2 g and A is 
1185 

greater than or equal to 225 cm2 (35 in') then the coating 

or ink is considered a thin-film UV radiation-cured coating 

and ASTM D 5403 is not applicable . 

NOTE : As noted in Section 1 .4 of ASTM D 5403, this 

method may not be applicable to radiation curable materials 

wherein the volatile material is water . 

11 .2 Multi-component Coatings . 

11 .2 .1 Sample Preparation . 

11 .2 .1 .1 Prepare about 100 ml of sample by mixing the 

components in a storage container, such as a glass jar with 

a screw top or a metal can with a cap . The storage 

container should be just large enough to hold the mixture . 

Combine the components (by weight or volume) in the ratio 

recommended by the manufacturer . Tightly close the 

container between additions and during mixing to prevent 

loss of volatile materials . However, most manufacturers 

mixing instructions are by volume . Because of possible 

error caused by expansion of the liquid when measuring the 

volume, it is recommended that the components be combined by 

weight . When weight is used to combine the components and 

the manufacturer's recommended ratio is by volume, the 

density must be determined by Section 11 .3 .3 . 
1186 

11 .2 .1 .2 Immediately after mixing, take aliquots from 

this 100 ml sample for determination of the 

content, water content, and density . 

total volatile 

11 .2 .2 Volatile Content . To determine total volatile 

content, use the apparatus and reagents described 

D2369 Sections 3 and 4 (incorporated by reference 

60 .17 for the approved versions of the standard), 

respectively, and use the following procedures : 

in ASTM 

- see § 

11 .2 .2 .1 Weigh and record the weight of an aluminum 

foil weighing dish . Add 3 ± 1 ml of suitable solvent as 

specified in ASTM D2369 to the weighing dish . Using a 

syringe as specified 

difference, a sample 

coatings believed to 

weight percent, a 

coatings believed 

weight percent, a 

in ASTM D2369, weigh to 1 mg, by 

of coating into the weighing dish . 

have a volatile content less than 40 

suitable size is 0 .3 ± 0 .10 g, but 

to have a volatile content greater 

suitable size is 0 .5 ± 0 .1 g . 

For 

for 

than 40 

NOTE : If the volatile content determined pursuant to 

Section 12 .4 is not in the range corresponding to the sample 

size chosen repeat the test with the appropriate sample 

size . Add the specimen dropwise, shaking (swirling) the 

dish to disperse the 

the material forms a 

specimen completely in the solvent . If 

lump that cannot be dispersed, discard 

the specimen and prepare a new one . Similarly, prepare a 
1187 

duplicate . The sample shall stand for a minimum of 1 hour, 

but no more than 24 hours prior to being oven cured at 

110 + 50C (230 ± 90F) for 1 hour . 

11 .2 .2 .2 Heat the aluminum foil dishes containing the 

dispersed specimens in the forced draft oven for 60 min at 

110 ± 50C (230 ± 90F) . Caution -- provide adequate 

ventilation, consistent with accepted laboratory practice, 

to prevent solvent vapors from accumulating to a dangerous 

level . . 

11 .2 .2 .3 Remove the dishes from the oven, place 

immediately in a desiccator, cool to ambient temperature, 

and weigh to within 1 mg . 

11 .2 .2 .4 Run analyses in pairs (duplicate sets) for 

each coating mixture until the criterion in Section 11 .4 is 

met . Calculate Wv following Equation 24-2 and record the 

arithmetic average . 

11 .2 .3 Water Content . To determine water content, 

follow Section 11 .3 .2 . 

11 .2 .4 Coating Density . To determine coating 

density, follow Section 11 .3 .3 . 

11 .2 .5 Solids Content . To determine solids content, 

follow Section 11 .3 .4 . 

11 .2 .6 Exempt Solvent Content . To determine the 

exempt solvent content, follow Section 11 .3 .5 . 
1188 

NOTE : For all other coatings (i .e ., water- or 

solvent-borne coatings) not covered by multicomponent or UV 

radiation-cured coatings, analyze as shown below : 

11 .3 Water- or Solvent-borne coatings . 

11 .3 .1 Volatile Content . Use the procedure in ASTM D 

2369 to determine the volatile matter content (may include 

water) of the coating . 

11 .3 .1 .1 Record the following information : 

Wi = weight of dish and sample before heating, g 

, WZ = weight of dish and sample after heating, g 

W, = sample weight, g . 

11 .3 .1 .2 Calculate the weight fraction of the 

volatile matter (Wv) for each analysis as shown in Section 

12 .3 . 

11 .3 .1 .3 Run duplicate analyses until the difference 

between the two values in a set is less than or equal to the 

intra-laboratory precision statement in Section 13 .1 . 

11 .3 .1 .4 Record the arithmetic average (Aj . 

11 .3 .2 Water Content . For waterborne coatings only, 

determine the weight fraction of water (Ww) using either 

ASTM D 3792 or ASTM D 4017 . 

11 .3 .2 .1 Run duplicate analyses until the difference 

between the two values in a set is less than or equal to the 

intra-laboratory precision statement in Section 13 .1 . 
1189 

11 .3 .2 .2 Record the arithmetic average (Ww) . 

11 .3 .3 Coating Density . Determine the density (Dc, 

kg/1) of the surface coating using the procedure in ASTM D 

1475 . 

11 .3 .3 .1 Run duplicate analyses until each value in a 

set deviates from the mean of the set by no more than the 

intra-laboratory precision statement in Section 13 .1 . 

11 .3 .3 .2 Record the arithmetic average (Dc) . 

11 .3 .4 Solids Content . Determine the volume fraction 

(V$) solids of the coating by calculation using the 

manufacturer's formulation . 

11 .3 .5 Exempt Solvent Content . Determine the weight 

fraction of exempt solvents (WE) by using ASTM Method D4457 . 

Run a duplicate set of determinations and record the 

arithmetic average (WE) . 

11 .4 Sample Analysis Criteria . For W, and W,,, run 

duplicate analyses until the difference between the two 

values in a set is less than or equal to the intralaboratory precision statement for that parameter. For D,, 

run duplicate analyses until each value in a set deviates 

from the mean of the set by no more than the intralaboratory precision statement . If, after several attempts, 

it is concluded that the ASTM procedures cannot be used for 

the specific coating with the established intra-laboratory 

precision (excluding UV radiation-cured coatings), the U.S . 
1190 

Environmental Protection Agency (EPA) will assume 

responsibility for providing the necessary procedures for 

revising the method or precision statements upon written 

request to : Director, Emissions, Monitoring, and Analysis 

Division, MD-14, Office of Air Quality Planning and 

Standards, U.S . Environmental Protection Agency, Research 

Triangle Park, NC 27711 . 

12 .0 Calculations and Data Analysis . 

12 .1 Nomenclature . 

, A = Area of substrate, cm2, (in 2) 

. 

C = Amount of coating or ink added to the substrate, 

g~ 

Dc = Density of coating or ink, g/cm' (g/in3) . 

F = Manufacturer's recommended film thickness, cm 

(in) . 

Wo = Weight fraction of nonaqueous volatile matter, 

g/g~ 

Wg = Weight fraction of solids, g/g . . 

W = Weight fraction of the volatile matter, g/g . 

WW = Weight fraction of the water, g/g . 

12 .2 To determine if a coating or ink can be 

classified as a thin-film UV cured coating or ink, use the 

following equation : 

C 0 F A DC Eq . 24-1 
1191 

12 .3 Calculate W for each analysis as shown below : 

Wl OW Z WO ° W 3 

12 .4 Nonaqueous Volatile Matter . 

12 .4 .1 Solvent-borne Coatings . 

Eq . 24-2 

WO O WV Eq . 24-3 

12 .4 .2 Waterborne Coatings . 

- WO O WVO WW Eq . 24-4 

12 .4 .3 Coatings Containing Exempt Solvents . 

Wo O W'OWEOWW Eq .- 24-5 

12 .5 Weight Fraction Solids . 

W3 O lOWV Eq . 24-6 

12 .6 Confidence Limit Calculations for Waterborne 

Coatings . To calculate the lower confidence limit, subtract 

the appropriate inter-laboratory precision value from the 

measured mean value for that parameter . To calculate the 

upper confidence limit, add the appropriate inter-laboratory 

precision value to the measured mean value for that 

parameter . For W and D,, use the lower confidence limits ; 
1192 

for WW, use the upper confidence limit . Because Ws is 

calculated, there is no adjustment for this parameter . 

13 .0 Method Performance . 

13 .1 Analytical Precision Statements . The intra- and 

inter-laboratory precision statements are given in Table 

24-1 in Section 17 .0 . 

14 .0 Pollution Prevention . [Reserved] 

15 .0 Waste Management . [Reserved] 

16 .0 References . 

Same as specified in Section 6 .0, with the addition of 

the following : 

1 . Standard Procedure for Collection of Coating and 

Ink Samples for Analysis by Reference Methods 24 and 24A . 

EPA-340/1-91-010 . U .S . Environmental Protection Agency, 

Stationary Source Compliance Division, Washington, D .C . 

September 1991 . 

2 . Standard Operating Procedure for Analysis of 

Coating and Ink Samples by Reference Methods 24 and 24A . 

EPA-340/1-91-011 . U .S . Environmental Protection Agency, 

Stationary Source Compliance Division, Washington, D .C . 

September 1991 . 

3 . Handbook of Hazardous Materials : Fire, Safety, 

Health . Alliance of American Insurers . Schaumberg, IL . 

1983 . 
1193 

17 .0 Tables, Diagrams, Flowcharts, and Validation Data . 
1194 

TABLE 24-1 . ANALYTICAL PRECISION STATEMENTS . 

Intra-laboratory Inter-laboratory 

Volatile matter 

content, W, 

± 0 .015 A, ± 0 .047 W, 

Water content, WW ± 0 .029 WW ± 0 .075 WW 

Density, Dc ± 0 .001 kg/1 ± 0 .002 kg/1 
3 . Appendix A of part 63 is amended by adding Method 311 to 

read as follows : 

Appendix A to Part 63-Test Methods 

Method 311 - Analysis of Hazardous Air Pollutant Compounds 

in Paints and Coatings by Direct Injection into a 

Gas Chromatograph 

1 . Scope and Anblication 

1 .1 Applicability . This method is applicable for 

determination of most compounds designated by the U. S . 

Environmental Protection Agency as volatile hazardous air 

pollutants (HAP's) (See Reference 1) that are contained in paints 

and coatings . Styrene, ethyl acrylate, and methyl methacrylate 

can be measured by ASTM D 4827-93 or ASTM D 4747-87 . 

Formaldehyde can be measured by ASTM PS 9-94 or ASTM D 1979-91 . 

Toluene diisocyanate can be measured in urethane prepolymers by 

ASTM D 3432-89 . Method 311 applies only to those volatile HAP's 

which are added to the coating when it is manufactured, not to 

those which may form as the coating cures (reaction products or 

cure volatiles) . A separate or modified test procedure must be 

used to,measure these reaction products or cure volatiles in 

order to determine the total volatile HAP emissions from a 

coating . Cure volatiles are a significant component of the total 

HAP content of some coatings . The term "coating" used in this 

method shall be understood to mean paints and coatings . 

1 .2 Principle . The method uses the principle of gas 

chromatographic separation and quantification using a detector 

that responds to concentration differences . Because there are 

many potential analytical systems or sets of operating conditions 

that may represent useable methods for determining the 

concentrations of the compounds cited in Section 1 .1 in the 

applicable matrices, all systems that employ this principle, but 

differ only in details of equipment and operation, may be used as 

alternative methods, provided that the prescribed quality 

control, calibration, and method performance requirements are 

met . Certified product data sheets (CPDS) may also include 

information relevant to the analysis of the coating sample 

including, but not limited to, separation column, 'oven 

temperature, carrier gas, injection port temperature, extraction 

solvent, and internal standard . 

2 . ummar,y . of Method 

Whole coating is added to dimethylformamide and a suitable 

internal standard compound is added . An aliquot of the sample 

mixture is injected onto a chromatographic column containing a 

stationary phase that separates the analytes from each other and 

from other volatile compounds contained in the sample . The 

concentrations of the analytes are determined by comparing the 

detector responses for the sample to the responses obtained using 

known concentrations of the analytes . 

3, pPf ;nitions [Reserved] 
4 . Interferences . 

4 .1 Coating samples of unknown composition may contain the 

compound used as the internal standard . Whether or not this is 

the case may be determined by following the procedures of 

Section 11 and deleting the addition of the internal standard 

specified in Section 11 .5 .3 . If necessary, a different internal 

standard may be used . 

4 .2 The GC column and operating conditions developed for 

one coating formulation may not ensure adequate resolution of 

target analytes for other coating formulations . Some 

formulations may contain nontarget analytes that coelute with 

target analytes . If there is any doubt about the identification 

or resolution of any gas chromatograph (GC) peak, it may be 

necessary to analyze the sample using a different GC column or 

different GC operating conditions . 

4 .3 Cross-contamination may occur whenever high-level and 

low-level samples are analyzed sequentially . The order of sample 

analyses specified in Section 11 .7 is designed to minimize this 

problem . 

4 .4 Cross-contamination may also occur if the devices used 

to transfer- coating during the sample preparation process or for 

injecting the sample into the GC are not adequately cleaned 

between uses . All such devices should be cleaned with acetone or 

other suitable solvent and checked for plugs or cracks before and 

after each use . - 

5 . Safetv 

5 .1 Many solvents used in coatings are hazardous . 

Precautions should be taken to avoid unnecessary inhalation and 

skin or eye contact . This method may involve hazardous 

materials, operations, and equipment . This test method does not 

purport to address all of the safety problems associated with its 

use . It is the responsibility of the user of this test method to 

establish appropriate safety and health practices and to 

determine the applicability of regulatory limitations in regards 

to the performance of this test method . 

5 .2 Dimethylformamide is harmful if inhaled or absorbed 

through the skin . The user should obtain relevant health and 

safety information from the manufacturer . Dimethylformamide 

should be used only with adequate ventilation . Avoid contactwith skin, eyes, and clothing . In case of contact, immediately 

flush skin or eyes with plenty of water for at least 15 minutes . 

If eyes are affected, consult a physician . Remove and wash 

contaminated clothing before reuse . 

5 .3 User's manuals for the gas chromatograph and other 

related equipment should be consulted for specific precautions to 

be taken related to their use . 

6 . Equipment and Supplies 

NOTE : Certified product data sheets (CPDS) may also include 

information relevant to the analysis of the coating sample 
including, but not limited to, separation column, oven 

temperature, carrier gas, injection port temperature, extraction 

solvent, and internal standard . 

6 .1 Sample Collection . 

6 .1 .1 Sampling Containers . Dual-seal sampling containers, 

four to eight fluid ounce capacity, should be used to collect the 

samples . Glass sample bottles or plastic containers with 

volatile organic compound (VOC) impermeable walls must be used 

for corrosive substances (e .g ., etch primers and certain coating 

catalysts such as methyl ethyl ketone (MEK) peroxide) . Sample 

containers, caps, and inner seal liners must be inert to the 

compounds in the sample and must be selected on a case-by-case 

basis . 

6 .1 .1 .1 Other routine sampling supplies needed include 

waterproof marking pens, tubing, scrappers/spatulas, clean rags, 

paper towels, cooler/ice, long handle tongs, and mixing/stirring 

paddles . 

6 .1 .2 Personal safety equipment needed includes eye 

protection, respiratory protection, a hard hat, gloves, steel toe 

shoes, etc . 

6 .1 .3 Shipping supplies needed include shipping boxes, 

packing material, shipping labels, strapping tape, etc . 

6 .1 .4 Data recording forms and labels needed include 

coating data sheets and sample can labels . 

NOTE : The actual requirements will depend upon the conditions 

existing at the source sampled . 

6 .2 Laboratory Equipment and Supplies . . 

6 .2 .1 Gas Chromatograph (GC) . Any instrument equipped with 

a flame ionization detector and capable of being temperature 

programmed may be used . Optionally, other types of detectors 

(e .g ., a mass spectrometer), and any necessary interfaces, may be 

used provided that the detector system yields an appropriate and 

reproducible response to the analytes in the injected sample . 

Autosampler injection may be used, if available . 

6 .2 .2 Recorder . If available, an electronic data station 

or integrator may be used to record the gas chromatogram and 

associated data . If a strip chart recorder is used, it must meet 

the following criteria : A 1 to 10 millivolt (mV) linear response 

with a full scale response time of 2 seconds or less and a 

maximum noise level of ±0 .03 percent of full scale . Other types 

of recorders may be used as appropriate to the specific detector 

--installed provided that the recorder has a full scale response 

time of 2 seconds or less and a maximum noise level of ±0 .03 

percent of full scale . 

6 .2 .3 Column . The column must be constructed of materials 

that do not react with components of the sample (e .g ., fused 

silica, stainless steel, glass) . The column should be of 

appropriate physical dimensions (e .g ., length, internal diameter) 
and contain sufficient suitable stationary phase to allow 

separation of the analytes . DB-5, DB-Wax, and FFAP columns are 

commonly used for paint analysis ; however, it is the 

responsibility of each analyst to select appropriate columns and 

stationary phases . 

6 .2 .4 Tube and Tube Fittings . Supplies to connect the GC 

and gas cylinders . 

6 .2 .5 Pressure Regulators . Devices used to regulate the 

pressure between gas cylinders and the GC . 

6 .2 .6 Flow Meter . A device used to determine the carrier 

gas flow rate through the GC . Either a -digital flow meter or a 

soap film bubble meter may be used to measure gas flow .rates . 

6 .2 .7 Septa . Seals on the GC injection port through which 

liquid or gas samples can be injected using a syringe . 

6 .2 .8 Liquid Charging Devices . Devices used to inject 

samples into the GC such as clean and graduated 1, 5, and 10 

microliter (01) capacity syringes . 

6 .2 .9 Vials . Containers that can be sealed with a septum 

in which samples may be prepared or stored . The recommended size 

is 25 ml capacity . Mininert° valves have been found satisfactory 

and are available from Pierce Chemical Company, Rockford, 

Illinois . 

6 .2 .10 Balance . Device used to determine the weights of 

standards and samples . An analytical balance capable of 

accurately weighing to 0 .0001 g is required . 

7 . Reagents and Standards 

7 .1 Purity of Reagents . Reagent grade chemicals shall be 

used in all tests . Unless otherwise specified, all reagents 

shall conform to the specifications of the Committee on 

Analytical Reagents of the American Chemical Society, where such 

specifications are available . Other grades may be used provided 

it is first ascertained that the reagent is of sufficient purity 

to permit its use without lessening the accuracy of 

determination . 

7 .2 Carrier Gas . Helium carrier gas shall have a purity of 

99 .995 percent or higher . High purity nitrogen may also be used . 

Other carrier gases that are appropriate for the column system 

and analyte may also be used . Ultra-high purity grade hydrogen 

gas and zero-grade air shall be used for the flame ionization 

detector . 

7 .3 Dimethylformamide (DMF) . Solvent for all standards and 

samples . Some other suitable solvent may be used if DMF is not 

compatible with the sample or coelutes with a target analyte . 

NOTE : DMF may coelute with ethylbenzene or p-xylene under the 

conditions described in the note under Section 6 .2 .3 . 

7 .4 Internal Standard Materials . The internal standard 

material is used in the quantitation of the analytes for this 

method . It shall be gas chromatography spectrophotometric 

quality or, if this grade is not available, the highest quality 

available . Obtain the assay for the internal standard material 
and maintain at that purity during use . The recommended internal 

standard material is 1-propanol ; however, selection of an 

appropriate internal standard material for the particular coating 

and GC conditions used is the responsibility of each analyst . 

7 .5 Reference Standard Materials . The reference standard 

materials are the chemicals cited in Section 1 .1 which are of 

known identity and purity and which are used to assist in the 

identification and quantification of the analytes of this method . 

They shall be the highest quality available . Obtain the assays 

for the reference standard materials and maintain at those 

purities during use . 

7 .6 Stock Reference Standards . Stock reference standards 

are dilutions of the reference standard materials that may be 

used on a daily basis to prepare calibration standards, 

calibration check standards, and quality control check standards . 

Stock reference standards may be prepared from the reference 

standard materials or purchased as certified solutions . 

7 .6 .1 Stock reference standards should be prepared in 

dimethylformamide for each analyte expected in the coating 

samples to be analyzed . The concentrations of analytes in the 

stock reference standards are not specified but must be adequate 

to prepare the calibration standards required in the method . A 

stock reference standard may contain more than one analyte 

provided all analytes are chemically compatible and no analytes 

coelute . The actual concentrations prepared must be known to 

within 0 .1 percent (e .g ., 0 .1000 ± 0 .0001 g/g solution) . The 

following procedure is suggested . Place about 35 ml of 

dimethylformamide into a tared ground-glass stoppered 50 ml 

volumetric flask . Weigh the flask to the nearest 0 .1 mg . Add 

12 .5 g of the reference standard material and reweigh the flask . 

Dilute to volume with dimethylformamide and reweigh . Stopper the 

flask and mix the contents by inverting the flask several times . 

Calculate the concentration in grams per gram of solution from 

the net gain in weights, correcting for the assayed purity of the 

reference standard material . 

NOTE : Although a glass-stoppered volumetric flask is convenient, 

any suitable glass container may be used because stock reference 

standards are prepared by weight . 

7 .6 .2 Transfer the stock reference standard solution into 

one or more Teflon-sealed screw-cap bottles . Store, with minimal 

headspace, at -100C to O0C and protect from light . 

7 .6 .3 Prepare fresh stock reference standards every six 

months, or sooner if analysis results from daily calibration 

check standards indicate a problem . Fresh stock reference 

standards for very volatile HAP's may have to be prepared more 

frequently . 

7 .7 Calibration Standards . Calibration standards are used 

to determine the response of the detector to known amounts of 

reference material . Calibration standards must be prepared at a 

minimum of three concentration levels from the stock reference 
standards (see Section 7 .6) . Prepare the calibration standards 

in dimethylformamide (see Section 7 .3) . The lowest concentration 

standard should contain a concentration of analyte equivalent 

either to a concentration of no more than 0 .01% of the analyte in 

a coating or to a concentration that is lower than the actual 

concentration of the analyte in the coating, whichever 

concentration is higher . The highest concentration standard 

should contain a concentration of analyte equivalent to slightly 

more than the highest concentration expected for the analyte in a 

coating . The remaining calibration standard should contain a 

concentration of analyte roughly at the midpoint of the range 

defined by the lowest and highest concentration calibration 

standards . The concentration range of the standards should thus 

correspond to the expected range of analyte concentrations in the 

prepared coating samples (see Section 11 .5) . Each calibration 

standard should contain each analyte for detection by this method 

expected in the actual coating samples (e .g ., some or all of the 

compounds listed in Section 1 .1 may be included) . Each 

calibration standard should also contain an appropriate amount of 

internal standard material (response for the internal standard 

material is within 25 to 75 percent of full scale on the 

attenuation .setting for the particular reference standard 

concentration level) . Calibration Standards should be stored for . 

1 week only in sealed vials with minimal headspace . If the stock 

reference standards were prepared as specified in Section 7 .6, 

the calibration standards may be prepared by either weighing each 

addition of the stock reference standard or by adding known 

volumes of the stock reference standard and calculating the mass 

of the standard reference material added . Alternative 1 

(Section 7 .7 .1) specifies the procedure to be followed when the 

stock reference standard is added by volume . Alternative 2 

(Section 7 .7 .2) specifies the procedure to be followed when the 

stock reference standard is added by weight . 

NOTE : To assist with determining the appropriate amount of 

internal standard to add, as required here and in other sections 

of this method, the analyst may find it advantageous to prepare a 

curve showing the area response versus the amount of internal 

standard injected into the GC . 

7 .7 .1 Preparation Alternative 1 . Determine the amount of 

each stock reference standard and dimethylformamide solvent 

needed to prepare approximately 25 ml of the specific calibration 

concentration level desired . To a tared 25 ml vial that can be 

sealed with a crimp-on or MininertO valve, add the total amount 

of dimethylformamide calculated to be needed . As quickly as 

practical, add the calculated amount of each stock reference 

standard using new pipets (or pipet tips) for each stock 

reference standard . Reweigh the vial and seal it . Using the 

known weights of the standard reference materials per ml in the 

stock reference standards, the volumes added, and the total 

weight of all reagents added to the vial, calculate the weight 
percent of each standard reference material in the calibration 

standard prepared . Repeat this process for each calibration 

standard to be prepared . 

7 .7 .2 Preparation Alternative 2 . Determine the amount of 

each stock reference standard and dime thylformamide solvent 

needed to prepare approximately 25 ml of the specific calibration 

concentration level desired . To a tared 25 ml vial that can be 

sealed with a crimp-on or Mininert° valve, add the total amount 

of dimethy1formamide calculated to be needed . As quickly as 

practical, add the calculated amount of a stock reference 

standard using a new pipet (or pipet tip) and reweigh the vial . 

Repeat this process for each stock reference standard to be 

added . Seal the vial after obtaining the final weight . Using 

the known weight percents of the standard reference materials in 

the stock reference standards, the weights of the stock reference 

standards added, and the total weight of all reagents added to 

the vial, calculate the weight percent of each standard reference 

material in the calibration standard prepared . Repeat this 

process for each calibration standard to be prepared . 

8 . Sample Collection Preservation Transport and Storage 

8 .1 Copies of material safety data sheets (MSDS's) for each 

sample should be obtained prior to sampling . The MSDS's contain 

information on the ingredients, and physical and chemical 

properties data . The MSDS's also contain recommendations for 

proper handling or required safety precautions . Certified 

product data sheets (CPDS) may also include information relevant 

to the analysis of the coating sample including, but not limited 

to, separation column, oven temperature, carrier gas, injection 

port temperature, extraction solvent, and internal standard . 

8 .2 A copy of the blender's worksheet can be requested to 

obtain data on the exact coating being sampled . A blank coating 

data sheet form (see Section 18) may also be used . The 

manufacturer's formulation information from the product data 

sheet should also be obtained . 

8 .3 Prior to sample collection, thoroughly mix the coating 

to ensure that a representative, homogeneous sample is obtained . . 

It is preferred that this be accomplished using a coating can 

shaker or similar device ; however, when necessary, this may be 

accomplished using mechanical agitation or circulation systems . 

8 .3 .1 Water-thinned coatings tend to incorporate or entrain 

air bubbles if stirred too vigorously ; mix these types of 

coatings slowly and only as long as necessary to homogenize . 

8 .3 .2 Each component of multicomponent coatings that harden 

when mixed must be sampled separately . The component mix ratios 

must be obtained at the facility at the time of sampling and 

submitted to the analytical laboratory . 

8 .4 Sample Collection . Samples must be collected in a 

manner that prevents or minimizes loss of volatile components and 

that does not contaminate the coating reservoir . A suggested 

procedure is as follows . Select a sample collection container 
which has a capacity at least 25 percent greater than the 

container in which the sample is to be transported . Make sure 

both sample containers are clean and dry. Using clean, longhandled tongs, turn the sample collection container upside down 

and lower it into the coating reservoir . The mouth of the sample 

collection container should be at approximately the midpoint of 

the reservoir (do not take the sample from the top surface) . 

Turn the sample collection container over and slowly bring it to 

the top of the coating reservoir . Rapidly pour the collected 

coating into the sample container, filling it completely . It is 

important to fill the sample container completely to avoid any 

loss of volatiles due to volatilization into the headspace . 

Return any unused coating to the reservoir or dispose as 

appropriate . 

NOTE : If a company requests a set of samples for its own 

analysis, a separate set of samples, using new sample containers, 

should be taken at the same time . 

8 .5 Once the sample is collected, place the sample 

container on ,a firm surface and insert the inner seal in the 

container. by placing the seal inside the rim of the container, 

inverting a,screw cap, and pressing down on the screw cap which 

will evenly force the inner seal into the container for a tight 

fit . Using clean towels or rags, remove all residual coating 

material from the outside of the sample container after insertingthe inner seal . Screw the cap onto the container . 

8 .5 .1 Affix a sample label (see Section 18) clearly 

identifying the sample, date collected, and person collecting the 

sample . 

8 .5 .2 Prepare the sample for transportation to the 

laboratory . The sample should be maintained at the coating's 

recommended storage temperature specified on the Material Safety 

Data Sheet, or, if no temperature is specified, the sample should 

be maintained within the range of 50C to 380C . 

8 .9 The shipping container should adhere to U .S . Department 

of Transportation specification DOT 12-B . Coating samples are 

considered hazardous materials ; appropriate shipping procedures 

should be followed . 

9 . OualitX Control 

9 .1 Laboratories using this method should operate a formal 

quality control program . The minimum requirements of the program 

should consist of an initial demonstration of laboratory 

capability and an ongoing analysis of blanks and quality control 

samples to evaluate and document quality data . The laboratory 

must maintain records to document the quality of the data 

generated . When results indicate atypical method performance, a 

quality control check standard (see Section 9 .4) must be analyzed 

to confirm that the measurements were performed in an in-control 

mode of operation . 

9 .2 Before processing any samples, the analyst must 

demonstrate, through analysis of a reagent blank, that there are 
no interferences from the analytical system, glassware, and 

reagents that would bias the sample analysis results . Each time 

a set of analytical samples is processed or there is a change in 

reagents, a reagent blank should be processed as a safeguard 

against chronic laboratory contamination . The blank samples 

should be carried through all stages of the sample preparation 

and measurement steps . _ 

9 .3 Required instrument quality control parameters are 

found in the following sections : 

9 .3 .1 Baseline stability must be demonstrated to be 

<5 percent of full scale using the procedures given in 

Section 10 .1 . 

9 .3 .2 The GC calibration is not valid unless the retention 

time (RT) for each analyte at each concentration is within 

±0 .05 min of the retention time measured for that analyte in the 

stock standard . 

9 .3 .3 The retention time (RT) of any sample analyte must be 

within ±0 .05 min of the average RT of the analyte in the 

calibration standards for the analyte to be considered 

tentatively identified . 

9 .3 .4 .The GC system must be calibrated as specified in 

Section 10 .2 . 

9 .3 .5 A one-point daily calibration check must be performed 

as specified in Section 10 .3 . 

9 .4 To establish the ability to generate results having 

acceptable accuracy and precision, the analyst must perform the 

following operations . 

9 .4 .1 Prepare a quality control check standard (QCCS) 

containing each analyte expected in the coating samples at a 

concentration expected to result in a response between 25 percent 

and 75 percent of the limits of the calibration curve when the 

sample is prepared as described in Section 11 .5 . The QCCS may be 

prepared from reference standard materials or purchased as 

certified solutions . If prepared in the laboratory, the QCCS 

must be prepared independently from the calibration standards . 

9 .4 .2 Analyze three aliquots of the QCCS according to the 

method beginning in Section 11 .5 .3 and calculate the weight 

percent of each analyte using Equation 1, Section 12 . 

9 .4 .3 Calculate the mean weight percent (®) for each 

analyte from the three results obtained in Section 9 .4 .2 . 

9 .4 .4 Calculate the percent accuracy for each analyte using 

the known concentrations (T ;) in the QCCS using Equation 3, 

Section 12 . 

9 .4 .5 Calculate the percent relative standard deviation 

(percent RSD) for each analyte using Equation 7, Section 12, 

substituting the appropriate values for the relative response 

factors (RRF's) in said equation . 

9 .4 .6 If the percent accuracy (Section 9 .4 .4) for all 

analytes is within the range 90 percent to 110 percent and the 

percent RSD (Section 9 .4 .5) for all analytes is <_20 percent, 
system performance is acceptable and sample analysis may begin . 

If these criteria are not met for any analyte, then system 

performance is not acceptable for that analyte and the test must 

be repeated for those analytes only . Repeated failures indicate 

a general problem with the measurement system that must be 

located and corrected . In this case, the entire test, beginning 

at Section 9 .4 .1, must be repeated after the problem is 

corrected . 

9 .5 Great care must be exercised to maintain the integrity 

of all standards . It is recommended that all standards be stored 

at -100C to OOC in screw-cap amber glass bottles with Teflon 

liners . 

9 .6 Unless otherwise specified, all weights are to be 

recorded within 0 .1 mg . 

10 . Calibration and Standardization . 

10 .1 Column Baseline Drift . Before each calibration and 

series of determinations and before the daily calibration check, 

condition the column using procedures developed by the laboratory 

or as specified by the column supplier . Operate the GC at 

initial (i .e ., before sample injection) conditions on the lowest 

attenuation .to be used during sample analysis . Adjust the 

recorder pen to zero on the chart and obtain a baseline for at 

least one minute . Initiate the GC operating cycle that would be 

used for sample analysis . On the recorder chart, mark the pen 

position at the end of the simulated sample analysis cycle . 

Baseline drift is defined as the absolute difference in the pen 

positions at the beginning and end of the cycle in the direction 

perpendicular to the chart movement . Calculate the percent 

baseline drift by dividing the baseline drift by the chart width 

representing full-scale deflection and multiply the result by 

100 

10 .2 Calibration of GC . Bring all stock standards and 

calibration standards to room temperature while establishing the 

GC at the determined operating conditions . 

10 .2 .1 Retention Times (RT's) for Individual Compounds . 

NOTE : The procedures of this subsection are required only for the 

initial calibration . However, it is good laboratory practice to 

follow these procedures for some or all analytes before each 

calibration . The procedures were written for chromatograms 

output to a strip chart recorder . More modern instruments (e .g ., 

integrators and electronic data stations) determine and print out 

or display retention times automatically . 

The RT for each analyte should be determined before 

calibration . This provides a positive identification for each 

peak observed from the calibration standards . Inject an 

appropriate volume (see NOTE in Section 11 .5 .2) of one of the 

stock reference standards into the gas chromatograph and record 

on the chart the pen position at~the time of the injection (see 

Section 7 .6 .1) . Dilute an aliquot of the stock reference 

standard as required in dimethylformamide to achieve a 
concentration that will result in an on-scale response . Operate 

the gas chromatograph according to the determined procedures . 

Select the peak (s) that correspond to the analyte(s) [and 

internal standard, if used] and measure the retention time (s) . 

If a chart recorder is used, measure the distance (s) on the chart 

from the injection point to the peak maxima . These distances, 

divided by the chart speed, are defined as the RT's of the 

analytes in question . Repeat this process for each of the stock 

reference standard solutions . 

NOTE : If gas chromatography with mass spectrometer detection 

(GC-MS) is used, a stock reference standard may contain a group 

of analytes, provided all analytes are adequately separated 

during the analysis . Mass spectral library matching can be used 

to identify the analyte associated with each peak in the gas 

chromatogram . The retention time for the analyte then becomes 

the retention time of its peak in the chromatogram . 

10 .2 .2 Calibration . The GC must be calibrated using a 

minimum of three concentration levels of each potential analyte . 

(See Section 7 .7 for instructions on preparation of the 

calibration standards .) Beginning with the lowest concentration 

level calibration standard, carry out the analysis procedure as 

described beginning in Section 11 .7 . Repeat the procedure for 

each progressively higher concentration level until all 

calibration standards have been analyzed . 

10 .2 .2 .1 Calculate the RT's for the internal standard and 

for each analyte in the calibration standards at each 

concentration level as described in Section 10 .2 .1 . The RT's for 

the internal standard must not vary by more than 0 .10 minutes . 

Identify each analyte by comparison of the RT's for peak maxima 

to the RT's determined in Section 10 .2 .1 . 

10 .2 .2 .2 Compare the retention times (RT's) for each 

potential analyte in the calibration standards for each 

concentration level to the retention times determined in Section 

10 .2 .1 . The calibration is not valid unless all RT's for all 

analytes meet the criteria given in Section 9 .3 .2 . 

10 .2 .2 .3 Tabulate the area responses and the concentrations 

for the internal standard and each analyte in the calibration 

standards . Calculate the response factor for the internal 

standard (RFis) and the response factor for each compound 

relative to the internal standard (RRF) for each concentration 

level using Equations 5 and 6, Section 12 . 

10 .2 .2 .4 Using the RRF's from the calibration, calculate 

the percent relative standard deviation (percent RSD) for each 

analyte in the calibration standard using Equation 7, Section 12 . 

The percent RSD for each individual calibration analyte must be 

less than 15 percent . This criterion must be met in order for 

the calibration to be valid . If the criterion is met, the mean 

RRF's determined above are to be used until the next calibration . 

10 .3 Daily Calibration Checks . The calibration curve 

(Section 10 .2 .2) must be checked and verified at least once each 
day that samples are analyzed . This is accomplished by analyzing 

a calibration standard that is at a concentration near the 

midpoint of the working range and performing the checks in 

Sections 10 .3 .1, 10 .3 .2, and 10 .3 .3 . 

10 .3 :1 For each analyte in the calibration standard, 

calculate the percent difference in the RRF from the last 

calibration using Equation 8, Section 12 . If the percent 

difference for each calibration analyte is less than 10 percent, 

the last calibration curve is assumed to be valid . If the 

percent difference for any analyte is greater than 5 percent, the 

analyst should consider this a warning limit . If the percent 

difference for any one calibration analyte exceeds 10 percent, 

corrective action must be taken . If no source of the problem can 

be determined after corrective action has been taken, a new 

three-point (minimum) calibration must be generated . This 

criterion must be met before quantitative analysis begins . 

10 .3 .2 If the RFi$ for the internal standard changes by 

more than ±20 percent from the last daily calibration check, the 

system must be inspected for malfunctions and corrections made as 

appropriate . 

10 .3 .3 The retention times for the internal standard and 

all calibration check analytes must be evaluated . If the 

retention time for the internal standard or for any calibration 

check analyte changes by more than 0 .10 min from the last 

calibration, the system must be inspected for malfunctions and 

corrections made as required . 

11 . Procedure 

11 .1 All samples and standards must be allowed to warm to 

room temperature before analysis . Observe the given order of 

ingredient addition to minimize loss of volatiles . 

11 .2 Bring the GC system to the determined operating 

conditions and condition the column as described in Section 10 .1 . 

NOTE : The temperature of the injection port may be an especially 

critical parameter . Information about the proper temperature may 

be found on the CPDS . 

11 .3 Perform the daily calibration checks as described in 

Section 10 .3 . Samples are not to be analyzed until the criteria 

in Section 10 .3 are met . 

11 .4 Place the as-received coating sample on a paint 

shaker, or similar device, and shake the sample for a minimum of 

5 minutes to achieve homogenization . 

11 .5 NOTE : The steps in this section must be performed 

rapidly and without interruption to avoid loss of volatile 

organics . These steps must be performed in a laboratory hood 

free from solvent vapors . All weights must be recorded to the 

nearest 0 .1 mg . 

11 .5 .1 Add 16 g of dimethylformamide to each of two tared 

vials (A and B) capable of being septum sealed . 

11 .5 .2 To each vial add a weight of coating that will 
result in the response for the major constituent being in the 

upper half of the linear range of the calibration curve . NOTE : 

The magnitude of the response obviously depends on the amount of 

sample injected into the GC as specified in Section 11 .8 . This 

volume must be the same as used for preparation of the 

calibration curve, otherwise shifts in compound retention times 

may occur . If a sample is prepared that results in a response 

outside the limits of the calibration curve, new samples must be 

prepared ; changing the volume injected to bring the response 

within the calibration curve limits is not permitted . 

11 .5 .3 Add a weight of internal standard to each vial (A 

and B) that will result in the response for the internal standard 

being between 25 percent and 75 percent of the linear range of 

the calibration curve . 

11 .5 .4 Seal the vials with crimp-on or Mininert® septum 

seals . 

11 .6 Shake the vials containing the prepared coating 

samples for 60 seconds . Allow the vials to stand undisturbed for 

ten minutes .- If solids have not settled out on the bottom after 

10 minutes, then centrifuge at 1,000 rpm for 5 minutes . The 

analyst ,also has the option of injecting the sample without 

allowing the solids to settle . 

11 .7 Analyses should be. conducted in the following order : 

daily calibration check sample, method blank, up to 10 injections 

from sample vials (i .e ., one injection each from up to five pairs 

of vials, which corresponds to analysis of 5 coating samples) . 

11 .8 Inject the prescribed volume of supernatant from the 

calibration check sample, the method blank, and the sample vials 

onto the chromatographic column and record the chromatograms 

while operating the system under the specified operating 

conditions . NOTE : The analyst has the option of injecting the 

unseparated sample . ' 

12 . Data Analysis and Calculations 

12 .1 Qualitative Analysis . An analyte (e .g ., those cited 

in Section 1 .1) is considered tentatively identified if two 

criteria are satisfied : (1) elution of the sample analyte within 

±0 .05 min of the average GC retention time of the same analyte in 

the calibration standard ; and (2) either (a) confirmation of the 

identity of the compound by spectral matching on a gas 

chromatograph equipped with a mass selective detector or 

(b) elution of the sample analyte within ±0 .05 min of the average 

GC retention time of the same analyte in the calibration standard 

analyzed on a dissimilar GC column . 

12 .1 .1 The RT of the sample analyte must meet the criteria 

specified in Section 9 .3 .3 . 

12 .1 .2 When doubt exists as to the identification of a peak 

or the resolution of two or more components possibly comprising 

one peak, additional confirmatory techniques (listed in 

Section 12 .1) must be used . 

12 .2 Quantitative Analysis . When an analyte has been 
identified, the quantification of that compound will be based on 

the internal standard technique . 

12 .2 .1 A single analysis consists of one injection from 

each of two sample vials (A and B) prepared using the same 

coating . Calculate the concentration of each identified analyte 

in the sample as follows : 

where : 

HAPwt% 0 100 x (A" ) 

(Ais ) (RRF,) (W,) 

Eq. (1) 

HAPwtt = weight percent of the analyte in coating . 

A, = Area response of the analyte in the sample . 

W;$ = Weight of internal standard added to sample, g . 

Ais = Area response of the internal standard in the 

sample . 

RRFX = Mean relative response factor for the analyte 

in the calibration standards . 

WX = Weight of coating added to the sample solution, 

. - 9- 

12 .2 .2 Report results for duplicate analysis (sample 

vials A and B) without correction . 

12 .3 Precision Data . Calculate the percent difference 

between the measured concentrations of each analyte in vials A 

and B as follows . 

12 .3 .1 Calculate the weight percent of the analyte in each 

of the two sample vials as described in Section 12 .2 .1 . 

12 .3 .2 Calculate the percent difference for each analyte 

as : 

%Difi 0 100 x JA' ~ B'I 

(A; 0 B) 

2 

Eq . (2) 
where Ai and Bi are the measured concentrations of the analyte in 

vials A and B . 

12 .4 Calculate the percent accuracy for analytes in the 

QCCS (See Section 9 .4) as follows : 

% AccuracyX 0 100 x X" 

TX Eq. (3) 

where ®X is the mean measured value and TX is the known true 

value of the analyte in the QCCS . 

12 .5 Obtain retention times (RT's) from data station or 

integrator or, for chromatograms from a chart recorder, calculate 

the RT's for analytes in the calibration standards (See 

Section 10 .2 .2 .2) as follows : 

RT p Distance from injection to peak maximum 

Recorder chart speed 

12 .6 Calculate the response factor for the internal 

standard (See Section 10 .2 .2 .3) as follows : 

Eq. (4) 

RFiS 0 C Eq~ (5) 

where : 

Aig = Area response of the internal standard . 

Ci9 = Weight percent of the internal standard . 

12 .7 Calculate the relative response factors for analytes 

in the calibration standards (See Section 10 .2 .2 .3) as follows : 

RRFX 0 A" Eq . (6) 

RFis C 

where : 

RRFX = Relative response factor for an individual 

analyte . 

Ax = Area response of the analyte being measured . 

C, = Weight percent of the analyte being measured . 

12 .8 Calculate the percent relative standard deviation of 

the relative response factors for analytes in the calibration 

standards (See Section 10 .2 .2 .4) as follows : 
0 (RRFX 0 RRF),)2 

n01 

RRFX 

where : 

n = Number of calibration concentration levels used 

an analyte . 

RRFX = Individual RRF for an analyte . 

RRFX = Mean of all RRF' s for an analyte . 

Eq. (7) 

for 

12 .9 Calculate the percent difference in the relative 

response factors between the calibration curve and the daily 

calibration checks (See Section 10 .3) as follows : 

0 RRF 0 RRFC 0 

% Difference 0 " x 100 

RRFX 

%RSD 0 100 x ~ 

where : 

13 . 

14 . 

15 . 

16 . 

Eq . (8) 

RRFX = mean relative response factor from last calibration . 

RRFc = relative response factor from calibration check 

standard . 

Measurement of Reaction Bvnroducts That are HAP rReservedl 

Method Performance . rReservedl 

Pollution Prevention . rReservedl 

Waste Management 

16 .1 The coating samples and laboratory standards and 

reagents may contain compounds which require management as 

hazardous waste . It is the laboratory's responsibility to ensure 

all wastes are managed in accordance with all applicable laws and 

regulations . 

16 .2 To avoid excessive laboratory waste, obtain only 

enough sample for laboratory analysis . 

16 .3 It is recommended that discarded waste coating solids, 

used rags, used paper towels, and other nonglass or nonsharp 

waste materials be placed in a plastic bag before disposal . A 

separate container, designated "For Sharp Objects only," is 

recommended for collection of discarded glassware and other 

sharp-edge items used in the laboratory . It is recommended that 

unused or excess samples and reagents be placed in a solventresistant plastic or metal container with a lid or cover designed 

for flammable liquids . This container should not be stored in 

the area where analytical work is performed . It is recommended 

that a record be kept of all compounds placed in the container 
for identification of the contents upon disposal . 

17 . References 

1 . Clean Air Act Amendments, Public Law 101-549, Titles I-XI, 

November, 1990 . 

2 . Standard Test Method for Water Content of Water-Reducible 

Paints by Direct Injection into a Gas Chromatograph . ASTM 

Designation D3792-79 

3 . Standard Practice for Sampling Liquid Paints and Related 

Pigment Coatings . ASTM Designation D3925-81 . 

4 . Standard Test Method for Determination of Dichloromethane 

and 1,1,1-Trichloroethane in Paints and Coatings by Direct 

Injection into a Gas Chromatograph . ASTM Designation D4457-

85 . 

5 . Standard Test Method for Determining the Unreacted Monomer 

Content of Latexes Using Capillary Column Gas 

Chromatography . ASTM Designation D4827-93 . 

6 . Standard Test Method for Determining Unreacted Monomer 

Content of Latexes Using Gas-Liquid Chromatography . ASTM 

Designation D 4747-87 . 

7 . Method 301 - "Field Validation of Pollutant Measurement 

Methods from Various Waste Media," 40 CFR 63, Appendix A. 

8 . "Reagent Chemicals, American Chemical Society 

Specifications," American Chemical Society, Washington, DC . 

For suggestions on the testing of reagents not listed by the 

American Chemical Society, see "Reagent Chemicals and 

Standards" by Joseph Rosin, D . Van Nostrand Co ., Inc ., New 

York, NY and the "United States Pharmacopeia ." 
18 . Tables Diagrams, Flowcharts and Validation Data 

Agency : Inspector : 

Sample ID# : Date/Time : 

Source ID : 

Coating Name/Type : 

Plant Witness : 

Type Analysis Required : 

Special Handling : 

Sample Container Label 
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Lot Number : 

Purity : 

Name of Solvent Material : Dimethylformamide 

Supplier Name : 

Lot Number : 

Purity : 

Date Prepared : Prepared By : 

Notebook/page no . : 

Preparation Information 

1 . Weight Empty Flask : 

2 . Weight Plus DMF : 

3 . Weight Plus Reference Material : 

4 . Weight .After Made to Volume : 

5 . Weight DMF (lines 2-1+3-4) : 

6 . Weight Ref . Material (lines 3-2) : 

7 . -Corrected Weight of Reference 

Material (line 6 times purity) 

8 . Fraction Reference Material in 

Standard (Line 7 = Line 5) : 

soln 

9 . Total Volume of Standard Solution : 

10 . Weight Reference Material per ml 

of Solution (Line 7 = Line 9) : 

Laboratory ID No . for this Standard : 

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Calibration Date : Calibrated By : 

PART 2 . Analysis of Calibration Standards 

Analyte Calib. STD ID No. 

- Calib. STD ID No. 

- Calib. STD ID No. 

Name: 

Name: 

Name: 

Name: 

Name: 

Name: 

Conc. in STD 

Area Response 

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Name: 

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Date : Analyst : 

Calibration Check Standard ID No . : 

Expiration Date : 

Analyte Retention Time (RT) Response Factor (RF) 

Last This Difference' Last This Difference b 

'Retention time (RT) change (difference) must be less than t0.10 minutes. 

'Response factor (RF) change (difference) must be less than 20 percent for each analyte and for the internal standard. 
SAMPLE ANALYSIS 

Vial A ID No . : 

Vial B ID No . : 

Analyzed By : Date : 

Sample preparation information Vial A 

(g) Vial B 

(g) 

Measured : 

wt empty vial 

wt plus DMF 

wt plus sample 

wt plus internal standard 

Calculated : 

wt DMF 

wt sample 

wt internal standard 

Analysis Results : Duplicate Samples 

Analyte Area response RF Wt percent in sample 

Vial A Vial_B Vial A Vial B Average 

Internal-Standard 
AMENDMENTS TO 

VERMONT SIP NARRATIVE 
SECTION-6 

STRATEGIES FOR AMBIENT AIR QUALITY STANDARD 

ATTAINMENT 

There are no SIP strategies to address Vermont non-attainment being implemented at present in 

Vermont, since all areas of the state are designated as attainment areas or unclassified areas for 

those criteria pollutants for which federal attainment/non-attainment designations apply. The 

designation of any area as non-attainment or attainment represents a dynamic process. 

Adjustments may be made to any designated area's status or to its boundaries based on more 

recent or future validated air monitoring data and/or on more detailed analysis by acceptable 

modeling methods. For example, future violations may cause portions of Vermont to become 

designated non-attainment areas for which attainment strategies would then be required . The 

State, through its monitoring data reporting commitments, will inform EPA of new violations of 

the National Ambient Air Quality Standards on a timely basis if and when they occur. 

STRATEGIES TO ADDRESS OZONE NON-ATTAINMENT IN THE 

NORTHEAST OZONE TRANSPORT REGION 

The SIP revision of August 1993 incorporates several new regulations which are meant to 

establish consistent levels of control on particular categories of sources of volatile organic 

compounds (VOCs) and nitrogen oxides (NOX) located within the Northeast Ozone Transport 

Region. For the most part these new regulations are meant to ensure that ozone precursor 

emissions are not transported into other areas of the Region where violations of the ozone 

standard may then be caused or exacerbated. The regulations incorporated in the SIP as 

regional control strategies are summarized in the following discussion . 

The Vermont Air Pollution Control Regulations for the Control of Volatile Organic Compounds 

(§5-253) require certain test methods, procedures, monitoring, and record keeping activities to 

be conducted in order to ensure compliance with the regulations. The Air Pollution Control 

Officer must specify the acceptable techniques to be used in meeting the intent of these 

activities . The discussion below includes a section addressing the policies and criteria, which 

the Air Pollution Control Officer will follow when specifying how these activities, will be 

carried out. The discussion clarifies how the actual regulations will be implemented to meet 

requirements of the 1990 Clean Air Act as amended. Sources subject to 5-253 will be able to 

utilize alternative VOC control plans to those required by the regulations only if there is a 

concurrent submittal to EPA by the Vermont Air Pollution Control Division of a single source 

SIP revision containing the alternative plan or if the requirements of the alternative VOC 

control plan are included in a Title V permit for the source . 
GASOLINE STORAGE AND DISTRIBUTION 

Sections 5-253 .1 thru 5-253 .5 of the Air Pollution Control Regulations require a variety of 

sectors of the gasoline marketing chain to install control equipment to prevent the release of 

gasoline vapors into the atmosphere . The different sectors treated by the regulations are listed 

below: 

PETROLEUM LIQUID STORAGE IN FIXED ROOF TANKS 

The regulations require above ground fixed roof storage tanks with a capacity greater 

than 40,000 gallons used to store petroleum liquid to equip the tank with an internal 

floating roof equipped with seals to close the space between the roof edge and the tank 

wall. 

BULK GASOLINE TERMINALS 

The regulations describe the acceptable procedures and standards to be met for delivery 

of liquid products into gasoline tank trucks using loading racks at bulk gasoline 

terminals. The standards to be met insure that VOC release to the atmosphere during 

product loading or transfer meets reasonably available control technology standards. 

Bulk gasoline terminals are defined as gasoline storage and distribution facilities with an 

average daily throughput of more than 20,000 gallons of gasoline on a 3-day rolling 

average basis . 

BULK GASOLINE PLANTS 

The regulations describe the acceptable procedures and standards to be met for delivery 

of liquid products into gasoline tanks from incoming gasoline trucks or vice versa using 

loading racks at bulk gasoline plants with throughputs of 3,000 gallons or greater. 

Submerged fill pipes and vapor balance systems are prescribed to insure that VOC 

release to the atmosphere is minimized during product transfer. Bulk gasoline plants are 

defined as gasoline storage and distribution facilities with an average daily throughput of 

less than or equal to 20,000 gallons of gasoline on a 30-day rolling average basis. 

GASOLINE TANK TRUCKS 

The regulations require all gasoline tank truck owners or operators to ensure that the 

gasoline tank truck is tested and certified as vapor-tight under the meaning of this term 

in the regulation. 
STAGE I VAPOR RECOVERY CONTROLS AT GASOLINE DISPENSING 

FACILITIES 

The regulations require all gasoline dispensing facilities (basically gasoline 

service stations), which receive deliveries from delivery trucks with capacities 

greater than or equal to 4000 gallons to install, operate, and maintain a system 

for vapor recovery when receiving shipments of gasoline from the delivery 

trucks . The system must be one in which gasoline vapors are forced from the 

storage tank into a vapor-tight gasoline tank truck or collection system through 

direct displacement by the gasoline loaded into the tank ("Stage I"). 

PAPER COATING 

Section 5-253 .10 of the Air Pollution Control Regulations has been amended to meet the federal 

standard for control. The rule affects at least two businesses in Vermont, which are engaged in 

paper coating for various purposes. It specifies acceptable control methods and technology for 

reducing emissions of VOCs by paper coating operations and lowers the applicable emission 

threshold from what it had been prior to its adoption in the SIP . 

COATING OF FLAT WOOD PANELING 

Section 5-253 .12 of the Air Pollution Control Regulations requires one flat wood paneling 

business in Vermont to install and operate emissions control devices to reduce emissions of 

VOCs released during the coating of panels and to keep records of the emissions from the 

coating operations conducted. 

COATING OF MISCELLANEOUS METAL PARTS 

Section 5-253 .13 of the Air Pollution Control Regulations requires businesses that engage in the 

coating of metal parts to reduce air pollution by either low polluting coatings that comply with 

the emission standards or by using control devices to reduce their emissions of VOCs. 

SOLVENT METAL CLEANING 

Section 5-253.14 of the Air Pollution Control Regulations requires approximately 60 businesses 

in Vermont to install new control devices or retrofit existing equipment in order to control 

emission of VOCs from degreasing units if solvents are used to clean metal. 
WOOD FURNITURE MANUFACTURING 

Section 5-253 . 16 of the Air Pollution Control Regulations restricts the emissions of VOCs and 

volatile hazardous air pollutants (VHAP) from wood furniture manufacturing facilities that 

exceed the respective applicability threshold contained in the regulation. Air emissions of these 

pollutants are restricted by either limiting the content of these pollutants in the various coatings 

or by achieving equivalent limits by use of a control device . The regulation also imposes work 

ractice reauirements including the development of a work practice implementation plan. 

OTHER SOURCES THAT EMIT VOLATILE ORGANIC COMPOUNDS 

Section 5-253 .20 of the Air Pollution Control Regulations regulates the emissions of VOCs 

from any source not otherwise regulated under another subsection of Section 5-253 if it has 

operations or processes that as a group have allowable emissions of 50 tons or more of VOCs 

per year. Sources that once become subject to this subsection remain subject to it even if 

allowable emissions fall below 50 tons of VOC per year. 

TEST METHODS, CALCULATION PROCEDURES, RECORD KEEPING, 

AND MONITORING REQUIREMENTS NECESSARY FOR THE 

IMPLEMENTATION OF VOC CONTROL MEASURES FOR 

ADDRESSING REGIONAL OZONE NON-ATTAINMENT 

Except as otherwise specified below or as otherwise specified in the Vermont Air Pollution 

Control Regulations, with respect to Vermont regulations related to the control of VOC 

emissions (§5-253), all sources subject to such regulations will be required to follow test 

methods calculation procedures record keeping, and monitoring requirements contained in the 

U.S . Environmental Protection Agency regulations and guidance documents or alternative 

recordkeeping and monitoring_ consistent with EPA's regulations as approved by the Air 

Pollution Control Officer. Some of these requirements as may be applicable are specified in, 

but not necessarily limited to the EPA documents "Model Volatile Organic Compound Rules 

for Reasonably Available Control Technology (unnumbered June 1992), "Control of Volatile 

Organic Compound Emissions from Wood Furniture Manufacturing Operations" (EPA-453/R96-007), and 40 C F R Part 63 Subpart JJ - National Emission Standards for Wood Furniture 

Manufacturing Operations The Air Pollution Control Officer will not allow the use of any test 

methods as alternatives to established EPA test methods without prior approval of EPA. Some 

of the procedures and methods believed to be applicable to sources regulated under Vermont 

Regulation 5-253 are presented below to assist the regulated community. The Air Pollution 

Control Officer will consider these listed procedures as non-discretionary requirements for 

complying with procedures required under 5-253 . 
l . Procedure for calculation of daily-weighted average VOC content under 5-

253 .13(c)(2) and 5-253 .20(b)(2): 

The daily-weighted average VOC content, in units of mass of VOC per unit 

volume of coating, excluding water and exempt compounds, as applied, of the 

coating used on a day on a coating unit, line, or operation shall be calculated 

using the following 

VOCW = 

n 

i ~ Vi * Ci 

i 

VT 

where VOC is the daily-weighted average VOC content referred to in the 

regulation and n is the number of different coatings as applied each day, Vi is the 

volume in gallons of each particular coating, Ci is the VOC content in pounds of 

VOC per gallon of each coating, and VT is the total volume of all coating in 

gallons. In all cases the volumes should be applied excluding water and exempt 

compounds. 

2. Procedure for determining the required overall emission reduction efficiency for 

control systems subject to 5-253 .13(d)(1)(ii) : 

The required overall emission reduction efficiency needed to demonstrate 

compliance is determined each day using the following steps : 

(1) Calculate the emission limitation (S) on a solids basis by using the 

appropriate emission limitation (C) from the regulation on a pounds 

VOC per gallon basis (excluding water and exempt compounds) and a 

standard conversion density equal to 7.36 pounds per gallon in the 

following equation: 

C 

S = 

1- ( C ) 

7.36 

(2) Calculate the required overall emission reduction efficiency (E) of the 

control system for the day using the following equation: 

(VOC S) 

E _ *100 

VOC 
where : 

VOC =The maximum VOC content of the coatings, as applied, used 

each day on the subject coating unit, line, or operation, in units of 

pounds VOC/gal of coating solids, using procedures specified in 4. 

below entitled "Procedures for determining the VOC content of 

coatings under 5-253.13". 

3 . Procedure for determining the achieved overall emission reduction efficiency for 

control systems subject to 5-253 .13(d)(1)(ii) : 

i) Achieved reduction efficiency for non-solvent recovery control devices 

The achieved overall emission reduction efficiency needed to demonstrate 

compliance must be determined each day as the product of the capture 

efficiency and the control device destruction or removal efficiency . The 

results of valid testing done to determine capture efficiency and removal 

efficiency remain valid for each day until subsequent valid test is 

performed. 

Capture efficiency must be determined using the capture 

efficiency test methods and procedures as specified in 40 CFR 

Part 51, Appendix M. 

ii) Achieved reduction efficiency for solvent recovery systems (e .g . carbon 

adsorber) 

In the case of a solvent recovery system being employed, a specific 

measurement of capture efficiency is not necessary, however, a comparison 

of the liquid VOC recovery to the liquid input for determining achieved 

reduction efficiency must use the test protocol specified at 40 CR 60.433 

with the following modification which substitutes a 7-day period rather 

than the 30-day weighted average as given in 40 CFR 60.433 : 

The source owner or operator shall obtain data each day for the 

solvent usage and solvent recovery. The solvent recovery 

efficiency of the system each day is determined using a 7-day 

rolling period . The recovery efficiency for each day is computed 

as the ratio of the total recovered VOC for that day and the prior 6 

consecutive operating days to the total solvent usage for the 

same7-day period used for the recovered VOC. 
4. Procedures for determining the VOC content of coatings under 5-253 .13 : 

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

Procedure for Collection of Coating and Ink Samples for VOC Content 

Analysis by Reference Method 24 and Reference Method 24A", EPA340/1-91-010. 

(b) For single component coatings, analytical Method 24 of 40 CFR Part 60, 

Appendix A shall be used to determine total volatile 

content, water content, and density of coatings . Samples used for total 

volatile content determination shall be oven-dried at 100 degrees 

centigrade for one hour. 

(c) For multi-component coatings, Method 24 should be used along with the 

following additional procedures : 

A. Mix the components in the same proportions as those in 

the coating, as applied. Mixing shall be accomplished by 

introducing the weighed components into a container that 

is closed between additions and during mixing. Prepare 

about 100 milliliters of coating in a container that is just 

large enough to hold the mixture prior to withdrawing a 

sample. 

B. For determining volatile content, a sample shall be 

withdrawn from the mixed coating and then transferred to 

a dish where the sample shall stand for at least one hour, 

but no more than 24 hours, prior to being oven-dried at 

100 degrees centigrade for one hour. 

C. Water content and density shall be determined from a 

sample taken from the same 100 milliliter mixture of 

coating which is analyzed by the appropriate ASTM 

methods referenced in Method 24 of 40 CFR Part 60, 

Appendix A. 

5 . Monitoring equipment specified for compliance with 5-253 .13 : 

a) Use of an incinerator or regenerative carbon adsorber to comply with any part of 

5-253 .13 must be accompanied by the installation of a continuous emission 

monitoring system (CEMS) to monitor the following parameters: 

A. Combustion chamber temperature of each thermal incinerator or 

afterburner. 
B. Temperature rise immediately before the catalyst bed and across each 

catalytic incinerator bed. 

C. VOC concentration of the outlet from each carbon adsorption bed. 

6. Additional recordkeeping requirements for compliance with 5-253 .13 : 

In addition to the information specified in 5-253.13(e)(1)(i) and (ii), sources subject to 

5-253 .13 must report total daily VOC emissions at the facility for a day representative of 

maximum production levels . A daily-weighted average of the combined VOC emissions 

from all operations at the facility shall be calculated using the equation below: 

n 

T= i 1Ai * Bi 

i 

where n = number of different coatings applied on each coating unit, 

each coating line, or each operation at the facility. 

Ai = Mass of VOC per volume of coating (excluding water and exempt 

compounds), as applied, used at the facility in lbs VOC/gallon. 

Bi = Volume of coating (excluding water and exempt compounds), as 

applied, used at the facility in gallons/day. 

7. Testing and record keeping requirements for compliance with 5-253.14(d) : 

The owner or operator of any source subject to 5-253 .14 shall maintain readily 

accessible records of equipment maintenance such as replacement of the carbon 

adsorption unit and records containing the results of all tests conducted for a 

period of five years. 

The submittal of an initial compliance certification from all sources subject to 5-

253 .14 will be required by the Air Pollution Control Officer. This certification 

must contain all the information pertinent to determination of compliance with 

the regulation, and must be submitted prior to November 15, 1994. 

Within 30 days of becoming aware of any excess emissions occurrence at a 

source, the owner or operator will be required by the Air Pollution Control 

Officer to report such occurrence to the Air Division. The report of excess 

emissions must contain all the information pertinent to the cause of the excess 

emissions, including at a minimum when it occurred, its duration, and the details 

of computations to determine the magnitude of the excess emissions, and also the 

proposed corrective actions to eliminate the excess emissions. 
Excess emissions related to refrigerated chillers, carbon adsorbers, or any 

other control system demonstrated to have a control efficiency equivalent 

or greater than these techniques will be considered to require the 

following additional actions on the part of the owner or operator of the 

source . 

1 . A performance test of the control device for its ability to achieve 

compliance with 5-253.14 . 

2. Maintenance records for a period of five years of performance 

parameters related to the performance of the control device, including 

but not limited to, periods of exceedance of parameter boundaries 

established during the performance testing and a log of operating 

times for a) the capture system, b) the control device, c) the 

monitoring equipment, and d) the source . The log should include 

maintenance details and duration of any outages. 

Note : For carbon adsorbers, the periods of operation during which 

parameter boundaries are exceeded includes : 

All 3-hour periods of operation during which either the average VOC 

concentration or the reading of organics in the exhaust gases is more 

than 20 percent greater than the average exhaust gas concentration or 

reading measured by the organics monitoring device during the most 

recent determination of the recovery efficiency demonstrating 

compliance. 

8. Testing, record keeping, and reporting requirements under 5-253.20 

With respect to the specification of any of these requirements by the Air 

Pollution Control Officer, it shall be the policy of the Air Pollution Control 

Officer to specify test methods and procedures identified or described in the 

appropriate portion of EPA's regulations or guidance documents, referenced in 

the introductory paragraph at the start of this section.