### ENCLOSURE 3 AMENDMENTS TO VERMONTAIRPOLLUTIONCONTROL REGULATIONS SUBMITTEDAS REVISIONS TOTHEVERMONT SIP SUBCHAPTER11. PROHIBITIONS 5-253.16 Wood Furniture Manufacturing Packageincludes: Memoranda betweenthe Air PollutionControl Division and otherstate

officials during therule adoption process. Adopted rulewith line-out ofportions notto be included in this SIP submittal establishing RACT forwood furniture manufacturing sources in VT.(text linedout by red lineare NOT intended to be included as part of the Vermont SIP) Incorporation by Reference Statementwhich describes the sections ofthe Code ofFederal Regulationswhich areexplicitly mentioned in the adoptedVermont rule. These sections describe test methodsthat manufacturers subjectto the rule are required to use.

AMENDMENTS TO VERMONTSIPNARRATIVE Revised pages 63 through71 ofthe SIPNarrative whichincludes the first nine pagesofSECTION-6 STRATEGIES FORAMBIENTAIR QUALITY STANDARDATTAINMENT. (textwith changes is highlightedin redonly to allow easier comparisontothecurrent pages 63 to 71) Theserevised pages (including thered highlightedtext)are intended to fully replace the corresponding existing pages in the VermontSIP NARRATIVEdocument currentlyapproved by EPA .

### AMENDMENTS TO VERMONT AIRPOLLUTIONCONTROL REGULATIONS SUBMITTEDAS REVISIONS TOTHE VERMONTSIP

## 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. 3South, 103South 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 forWood Furniture Manufacturing #02P-051 Please accept forfiling the enclosed documents fora Final Proposed Ruleamending ourAir Pollution Control Regulations. The rulemaking includes a new §5-253.16, Wood Furniture Manufacturingaddition to our rules and some minoramendments to §5-101, Definitions. Enclosed are clean and annotated texts of both rule sections andsigned originals of the required APA forms. In addition, I have included a copy ofthe action taken by the Intra-agency Committee on Administrative Rules regardingthis rulemaking and a requestforan extension of time by the Legislative Committee on Administrative Rules. Please contact meat 241-3604 ifyou have anyquestions aboutthe rule and let me know when the Committeewill consider the rule and/or the request forextension.

Regional Offices - Barre/Essex Jct./Pittsford/RutiandlSpringfieldi'St JohnsburyPAVILIONOFFICE BUILDING MONTPELIER,VERMONT05609-0201

STATE OF VERMONT OFFICE OF THE SECRETARY TEL: (802) 828-3322 FAX: (802) 828-3320



## AGENCY OF ADMINISTRATION INTERAGEN

CYCOMMITTEE ONADMINISTRATIVE RULES TO : Doug Elliott

ANR 103 S. Main Street Waterbury, Vermont 

### FROM : Interagency Committeeon Administrative Rules DATE: October 29, 2002 SUBJECT:' Proposed Rule: Air Pollution Control Regulations -

Wood Furniture TheInteragency CommitteeonAdministrativeRules has made thefollowingdecisionconcerningthe proposed rule identified above: [ X] TheCommitteehas noobjectiontotheproposed rulebeingfiledwiththeSecretaryofState. The public involvement plan was deemed appropriate, with a recommendation for listing ways toobtain federal scientific information. [ ] 

## [] TheCommitteehas noobjectiontotheproposed rule beingfiledwith the SecretaryofState, The Committeerequests that theproposed rule not befiledwiththe SecretaryofStateuntil the questions listed belowhave 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: ScottJohnstone, Secretary, Agency ofNatural 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. 3South, 103South 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 Cw_ Air Pollution Control Division DATE: June 24, 2003 SUBJECT: Request for Extension ofTimeforAdoption of Final Proposed Rules forWood

Furniture Manufacturing #02P-051 - Pursuant to 3V .S.A. §843(c) Section 843(c) of Title 3of theVermont Statutes provides authoritytothe Legislative Committeeon Administrative Rulesto provide foran extension of theeight-month time period forthe adoption of a rule. No standard or guidance is given in the statute forthe exerciseof this authority by the Committee. It is apparently within the sound discretion of the Committee. An sixtydayextension 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 forconsideration of the rule by the Committeeand foranyactions consistentwith or in response tothe Committee's determination; This rulemaking brings within thejurisdiction of the state, and simplifies, requirements of an federal rule, concerned with hazardous air pollutants in coatings, sealersand adhesives, which is currently applicable towood furniture manufactures in Vermontby EPA ; The rulemaking also combines those requirements for hazardousair pollutants with similar requirements of an EPAmodel ruleforthe Ozone Transport Region concerned with volatile organic compoundswhich are also present in the same coatings, sealers and adhesives and are used by the same manufacturers; There has been public commentand some revisionswere 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 delayinfiling the Final Proposed Rule was caused, in part, by: the complexity of the rule and the related federal regulations which meantthat it took considerable time to respond to thetwoformal commentletters received; by a staffshortage (two staffmembers and a chiefengineer) in thepermit section of theAir Pollution Control Division,which alongwith ourenforcement section was responsiblefortechnicalwork on the rule; and by the Division's counsel being occupiedwith a number ofother 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 FORTHE HEARING IMPAIRED 1-800-253-0191 TDD>Voice 1-800-253-0195 Voioe>TDD 

# MEMORANDUM TO : Louise Corliss, APAclerk

Secretary of State FROM : Conrad W

. Smith, Counsel Air Pollution Control Division DATE: June 24; 2003 SUBJECT: Air Pollution Control Division Bldg. 3South, 103South 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 forWood Furniture Manufacturing#02P-051 Please accept forfiling the enclosed documents fora Final Proposed Rule amending ourAir Pollution Control Regulations. The rulemaking includes a new §5-253.16, Wood Furniture Manufacturing addition to our rules and some minoramendments to §5-101, Definitions. Enclosed are clean and annotated texts of both rule sections and signed originals of the requiredAPA forms. Please contact me at 241-3604 ifyou have anyquestions aboutthe rule.

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

### FPCS-02 

## FINAL PROPOSAL: COVERSHEET SOS# (Do notcomplete) Note: File this formwith theappropriate attachmentswith the Secretary ofState andthe LegislativeCommittee onAdministrative Rules. Youmust file anadoptingpage, aneconomic impact statement, text oftherule, annotated text showingthechanges to existing rules and anexplanationofthe changesalongwiththis cover sheet. Youmust also file a scientific informationstatement and/or incorporation by reference statement if applicable. Please complete thefollowing. 1. Title offinal proposal : Air Pollution Control Regulations Furniture Manufacturing . Subchapter II Prohibitions, '5-253 .16 Wood 

### 2. Proposed Rule#previously assigned bythe SecretaryofState 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. Statutoryauthorityforthis rule: 10 V.S .A. 1554(2)and 1558. 

### 6 .This filing has ® has not El changed sincethefiling oftheproposed rule. Ifit haschanged, please attach aletter to this filing explaining indetail what changeswere made,citing chapter andsectionofthose changes whereapplicable. 7. Substantial argumentsand considerations were ® were not 0 raised foror against the original proposal . Please attach copies ofallwrittensubmissions and synopses oforal comments received foror against the original proposal . Ifsubstantial arguments and considerations were raised foror against theoriginal proposal or ifsuggestions with respectto separate requirements forsmall businesses were made, please attach a letter to this filing explaining indetail thereasons forthe agency's decision toreject or adoptthem . 8 . Give aconcise summaryexplaining the effect oftherule (150words 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 . Explanationofwhythis 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 ofpeople, enterprisesand 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. 

### Briefsummary ofeconomic impact ofthis rule (150words 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 formof 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 ofhearing(s), ifanywere held: Tuesday, December 10, 2002 7 :00 PM, Pavilion Auditorium, Pavilion Building, 109 State Street Montpelier, VT 

### 13. Thedeadline forpublic comments was: 12/17/02 CERTIFICATION

: AS THE ADOPTINGAUTHORITY (see 3V .S.A. § 801(b)(11) foradefinition) OF THIS RULE, I APPROVE THE CONTENTS OF THIS FILING .

Date: 06/24/03 

### C - l,1e 

# l (Signhere) Eliabeth McLain Secretary, Agency of Natural Resources



### (Typename 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 Coversheet ® Adopted Page ® Economic Impact Statement ® Scientific Information ® Public InputStatement ® Incorporation by Reference ® Text ofthe Rule ® AnnotatedText This boxforSecretary ofStateuseonly El Final Proposed Rule Cover Sheet " Adopted Page " Economic Impact Statement " Scientific Information OPlan for Maximizing Public Input 0Incorporation by Reference 0Text ofthe Rule 0Annotated Text Thesecomponents werefiledwith thisrule FilingAgent's Initials

## ATTACHMENTA

Changes Made to Proposed Rule# 02P-051 Prior to Filingas a Final Proposed Rule In response to thewritten and oral comments received onthis proposed rule during thepublic comment period, includingthe public hearing, the following changeswere madeto therule. For a more detailed explanationofthereasonsforthe changes, please seethe Summaryofand Response to Comments datedJune 20, 2003 (attached) . § 5-253.16(a)(3) Theexemptionfrom

therule for "incidentalwood furniture manufacturers" wasrevised to apply to those manufacturers that "use nomore than 100gallons per month offinishing material and contactadhesives combined"in response to EPA's concernthat Vermont hadmisinterpreted the federal regulation onthis point (see EPAcomment 6) . § 5-253.16(b) Definitions. "Certified Product Data Sheet (CPDS)"; "Coating Solids (or solids)" . Both oftheabovedefinitionswere changed to specifythat, ifan equivalent or alternative test method to an EPAtest method is used todeterminethe hazardousair pollutant ("HAP") or solids contentof amaterial, the method must beapproved notonly bythe VermontAir Pollution Control Division, but also by EPA(see EPAcomment 8) . § 5-253.16(c)(2)(i), (c)(2)(iii), (c)(3)(i), and (c)(3)(iii). In each ofthese divisions, theword "using" has been replaced by "use". Thesechangesare for grammatical reasons only (see EPAcomment 14). § 5-253.16(c)(4)(ii) . This provision has been revisedbasedonacomment fromEthanAllen, Inc. to make clear that, for anywater based or UV-cured coatings exempted by this subparagraph from§ 5-261 ofthe Regulations, theoperator has the option ofdemonstrating compliancewith the emission standards in § 5-253.16(c)(1), (2)and (3) bymeans ofmonthlyweighted averagingofthevolatile organiccompound ("VOC")or HAPcontent ofthe coatings, as is allowedfor othercoatings subject totheregulation (see EthanAllencomment 2) . § 5-253.16(e)(1)(iii), (e)(2)(iii) and(e)(3)(ii) . In all threedivisions, thewords"and monitoring requirements" have been addedafter "By achieving equivalent emission reductions throughthe use ofacontrol system..." to makeclear that anyowner or operator that chooses to use acontrol systemtoachieve compliance must obtain approval fromthe Air Pollution Control Division not onlyforthecontrol device, but also foranyrequired instrumentsandmethods needed to monitortheoperationofthecontroldevice (see EPAcomment 10) . § 5-253.16(e)(1)(iv) and (e)(2)(iv). Thewordsin both ofthese divisions have been reordered andthephrase "each as provided for above" has been added to each. Thepurpose ofthis change is to make a clearcross reference

### AttachmentA Page 2 betweenthese provisions andtheprecedingthree provisions in therespectivesubparagraphs (see EPAcomment 11). 

### § 5-253.16(g)(1)(iii). Thewords "orVOC" have been addedin three spots and areference to EPAMethod 24,thetest method forVOCs in coatings, has also been addedto clarifythat the compliancestatements regardingcontinuous coaters in the semi-annual reports must address notonly the volatile hazardous airpollutant, but alsotheVOC, content ofthe coatings used (see EPAcomment 1).

### AP3-00 

## ADOPTINGPAGE Note: This formmust be filed three times during the rulemaking process, viz., with the Proposed Rule Cover Sheet, Final Proposal Cover Sheet, andAdopted Rule Cover Sheet. Please complete thefollowing: 1. Titleofrule: 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, ifany: 4 . This is a new

rule ® an amendment N arepeal F~ ofan existing rule. Except for new

rules, please give the nameoftheexisting rule andthedate onwhichit was last amendedor 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 formwith 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 ofthe Code ofVermont Rules, the agency shall file the annotated text, if possible, using the appropriate page or pages of the Code ofVermont Rules as abasis for the annotated version . New rules need not be accompanied by an annotated text. Rules which have been comprehensively revised are also exempted fromthe requirement for an annotated text, although acopy oftheformer rule is required.

### SIS-O1 

## SCIENTIFIC INFORMATIONSTATEMENT Note: In completing theScientific Information Statement, an agencyshall providea briefsummary ofthe scientific information including referenceto any scientific studies uponwhich the proposed rule is based, for the purpose ofvalidity. Wherethis form is insufficient foryour purposes, please use additional sheets. Please complete thefollowing: 1. Title or subject ofrule: 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. Abrief 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 formonly if the rule has not been pre-filedwith ICAR(If pre-filed, please attach documentation of maximization plan). Incompleting thepublic inputstatement, an agencyshall demonstratea plan on how to maximize the involvement of the public in the development of therule. Wherethis formis insufficient foryour purposes, please use additional sheets. Please complete the following: 1. Title or subjectof 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 ofthe 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 thepeople and organizations that were notified ofthe hearing andthe methodsof 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 theways in whichtherulewill 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 . Outlineofthe type of follow-up on public involvementyour 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 completingthe economic impact statement, anagency analyzes theanticipated costs andbenefits to be expected fromadoption of the rule. Where this formis insufficient for your purposes, please use additional sheets. Please complete the following. 

### 1. Title orsubject ofrule: 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 ofpeople, enterprises andgovernment entities potentiallyaffected by this rule and estimate foreach the costs andbenefits anticipated. Ifapplicable, includesmall businesses, andcomplete items 4and5ofthis sheetas well . Please beas specific as possible, giving full information onyour assumptions, database,and attempts to gather other informationon thenature ofthecosts andbenefits involved. Costs andbenefits can includeanytangible or intangibleentities or forces whichwill make an impact on lifewithoutthis 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 ofthe rule with the economic impact of other alternatives to the rule, including no rule on thesubjector 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 . Flexibilitystatement: Please comparetheburden imposed on small business by compliance with therule to theburdenwhichwouldbe imposed byalternatives considered in 3V .S.A. § 832a. No alternatives were considered as noted above . 

### CERTIFICATION

: AS THEADOPTINGAUTHORITY (see 3V .S.A . § 801(b)(11) for adefinition) OF THIS RULE, I CONCLUDETHATTHIS RULE IS THE MOSTAPPROPRIATE METHODOF ACHIEVINGTHE REGULATORY PURPOSE. INSUPPORT OF THIS CONCLUSION, I HAVE ATTACHEDALL FINDINGS REQUIREDBY 3 V.S.A. § 832a. (Signhere) Date:06/24/03 Elizabeth McLain Secretary, Agency of Natural Resouces



### (Type name here please)

### ACS-03 

## ADOPTEDRULE: COVERSHEET SOS# (DoNot Complete) Note: File this form

with the Secretary ofStateand the Legislative Committee onAdministrative Rules. Youmust file anadopting page andthetext ofthe adopted rulewith this cover sheet. 

### Please complete thefollowing. 1. Title or subjectofadopted rule: Wood Furniture Manufacturing 

### 2 . Proposed Rule#previously assigned by the Secretaryof State 02 P-051 .' 

### 3. Agency: Dept of Environmental Conservation/Agency of Natural Resources 4 . Statutory authorityforthis rule: 10 V.S .A. §554(2) and §558 5 . This filing has E] has not ® changed sincethe filing ofthefinal proposal . Ifit haschanged, please attach aletterto this fiiing explaining indetail what changes were made, citing chapter and sectionofthose changeswhereapplicable, including changesin economic impact. 6 . TheLegislativeCommitteeonAdministrative Rules didnot object ® objected 0 tothe final proposal . 

### 7 . Procedural history ofadoption: Therule wasfiledwith ICARon thefollowing date: :09/25/02. 

### This rulewasfiled inproposed form withthe secretary ofstate onthe followingdate: 10/ 17/02. This rule was published in newspapers ofrecord on 11 /07/02 and 11 / 14/02. This rule was the subject ofpublic 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 forpublic commentforthis rulewas 12/17/02. This rulewas filed in itsfinal proposed formwith thesecretary ofstate and with the Legislative Committee onAdministrative Ruleson 06/24/03. Thisrulewas considered by the LegislativeCommitteeonAdministrative Ruleson 07/31 /03. 

### This rule is filed inits adoptedformon 08/ 14/03. Revised 2003A%-3-U3



### The effectivedate ofthis rulewill be 03/O1/04 (must be nosooner than 15 days followingthe . filing oftheadoptedrule).



### ...~..~.._...CERTIFICATION: AS THEADOPTINGAUTHORITY (see 3V.S.A. § 801(b)(11) foradefinition) OF

THIS RULE,T_ HEREBY CERTIFY THAT THE PROCEDURAL . RR QTTTRRMRNTC QF TTTT .R I

-.- 

### CHAPTER25 HAVE BEENMET. I ALSOAPPROVE THE CONTENTS OF THIS FILING . Date: 08/14/03 (Signhere) . Elizabeth ft

; McLain, Sec . Agency of Natural Resourc



### (Type name here please)



### Anadoptingpage andatextofthe rulewerefiledwith this coversheet APAClerk's Initials'

Revised 2003

## ADOPTING PAGE AP3-00

Note: This formmust be filed three times during the rulemaking process, viz., with the Proposed Rule CoverSheet, Final Proposal Cover Sheet, and Adopted Rule Cover Sheet.

Alcasc CviiIFi~,t~ l i~, vr t~ o t1- .v ~ l F 1 0ii1?' ' ui~. v'viiig: 

### 1. Titleofrule: 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) XAmendment- changes toanalreadyexisting rule. [Minor admendments to §5-101 Definitions] XNew

rule- adopts a rule that did not previouslv exist. fNewSS-253.16 Wood Furniture Manufacturin¢1 

### F~ Repeal-repeals arule that previously existed. Except for new

rules, please give the name ofthe existing rule andthedate onwhichit 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 annotatedform

with thefilings ofproposed rules and final proposals. Filing a paragraphor page of alarger 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 theCode ofVermont Rules as abasis for the annotated version. New rules need not be accompanied by an annotated text.

. Revised2003

### ADOPTEDREGULATION §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

### ADOPTEDREGULATION §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 maximumaggregate 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. 

### Ruleas Adopted (August 14, 2003version) Effective March 1, 2004 Page 2-2

### ADOPTEDREGULATION §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, 2003version) Effective March 1, 2004 Page 2-3

### ADOPTEDREGULATION §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 asAdopted (August 14, 2003version) Effective March 1, 2004 Page 2-4

### ADOPTEDREGULATION §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 i C 1 nrAtPC'3 at a ma4nr cni=a nf F-TAPc anrl rThi rh hcnan nnor~t ; r,ne x hafnra naramhAr F lAA4 chall " l_11 T1 .ca nnl~i atainc ., rr,vchi-natc~ caalarc,- tnzrr,ni-c~ hacann +-c nnrl

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### Rule as 

### Ad-opted (August 14, 1003 VGF46iQR) 

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nf ciihcPrtinnc ~4~ (r,) -(F, nf Cantinn S-9 til~ t.rhorc

ahl P, PXl'P=t that cai r'1 rarYrni rcmontc chal l nnt Ann] v tn nv Pmiccinnfi of vnlatila ha7arrlrYrn,c air rnntaminantc rncorl h~t tl-hp rnca nf tratar Yhacarl nnatinac nr rl,atin9cWr ror-l l-,_7 maanC nf tnl travi nl At rarii ati nn =rnvi rlorl t}-,at tho nrnnor r,r 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, 2003version) Effective March 1, 2004 Page 2-7

### ADOPTEDREGULATION §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 minimumvisual 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 2-8ADOPTED 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

### ADOPTEDREGULATION §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, 2003version) Effective March 1, 2004 Page 2-10

### ADOPTEDREGULATION §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

### ADOPTEDREGULATION §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 ^,,hJ crt tn th ; c cn}~carti nn must rlamnnctrata rn,m~nl i An r-p i7i th thc r,rnvi ci nnc nf lr- 1 I 7 1 l i 1 And _(r-1 IT ~r,1 T~,y a c aP=1 i (-,qh1 j- ,1-~= 7 71 c l n ~Qnc nf t1,o fnllntiinn mPthnrlc " I i j Rv rlca of rnm=1 i anim ai ntai ni nrr

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t. ; .., n~ _ .. . ;_e~_ 1 l cA~ r]ilrinrr t}-hc mnnthlcr ~~ ^NTPrA(Tl n('( YIPr Clro m .qtariale ac rlcmnnetrata 1,y

,arhi -,KTi nr-r jjj),RT a rnntrnl P ntli va l ant ami eci nn rarlrnrti nn thrn rrh the l,cc gw~gtam anr-1 mnni+-nring raTLl ;rcmant c n 1-i . .t4.. r6-it----1 nffirar_- nr tha A4 -:r- ( ivl Rv ar bl -Vi n(T-rflll CTal ont ami cci nn raa"" ^i" ^ - }tn'^ . _ rr1h t},o r,co

nf a . , Z1 L1vaI ev1Y~ . .tv1 t-nmhin^tinn~ atryprnvar-1 hy thc Z "] 7J~ ~~ "' /1 F~ i annrnarh nf r"nm=l i ant_ ~~ ^a- "" ,- ; -, 7 c ~ an ;:' 1rcr2ni nrr Ann nnntrnl cvetcm earh a nr vi fnr ~hn~roFarh ntanPr nr n=Pratnr nf a c h~crt tn th ;c s17hcPrti nn mr,et rlPmnnctratc rnm=l i Anrc w ; th tho_,r,rncri ci nnc nf (r) (7~ an r'1 (r) ir-ahlc~ hxz cinn nno nf tho fnllnwing mathnric- (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

nf a (-nntrnl CyRtPm an H mnni tnri nl7AT,i rcmcn~c annrnvorl 1-,v thP A33- n. .,-r . .z; ... .,, r., . .. .~ ..., ., nffir~ar7 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 ; ;4AF 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

### ADOPTEDREGULATION §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, 2003version) Effective March 1, 2004 Page 2-14

### ADOPTEDREGULATION §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 ----'---'-

~ . vu~ .a ~~. anlhacitrPC haNro hPPn 11cPr1 aar,1-1 riaw in f-1-lo comi~nnl,cl rapnrt i ng YIP d ; (~Ti ,~ Fnr :9t_a t!j 2919 ±QY Cynlirrac rlcmnnetrat'j nn rr,mpl ; nn(rc or; +-},

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

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

### ADOPTEDREGULATION §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 INCORPORATIONBY REFERENCE STATEMENT Pleasecomplete the following, in additionto filinga copy.ofany material incorporated by reference inthis rule. 1. Title or subjectof rule: Air Pollution Control Regulations, Subchapter II Prohibitions, '5-253 .16 Wood Furniture Manufacturing. 

### 2. Agency: AgencyofNatural Resources: Air Pollution Control Divisionofthe Department of Environmental Conservation 3 . Description of material to be incorporated by reference: Sections ofthe CodeofFederal Regulationswhichare explicitly mentioned in the new rulewhichdescribecertaintest methodsthat wood furniture manufacturerswouldare subject totherule are required to use: Method 24, DeterminationofVolatile Matter Content, Water Content, Density, Volume Solids, andWeight Solids ofSurfaceCoatings, found at 40CFR60Appendix A ; and Method 311, Analysis ofHazardous Air Pollutant Compounds in Paints andCoatings by Direct Injection intoaGasChromatograph, found at 40CFR63Appendix A 4 . Please explain how thematerial to be incorporated by reference can be obtained by thepublic and at what cost: Thenewlyincorporated test methods areon file at the Agency ofNatural Resources, Department ofEnvironmental Conservation, Air PollutionControl Division, 103South Main Street,Waterbury,Vermont05671, (802) 241-3840. Thematerials arealsoon file with the SecretaryofStateat the Redstone Building, 26Terrace Street, Montpelier, VT 05609-1101, (802) 828-2363. They areavailable fromthoseagencies at no cost, or for the cost ofcopyingifspecified in on the applicable public document rules forthe agency from which thecopies aresought. Themethodsarealso at http://www .access.gpo.gov/nara/cfr/cfr-table-search.html#pagel

1 06/23/03 IBRStatement for Final Proposed Rule

### IBR-O1

5. Please explain any modification in thematter incorporated, e.g.,whetheronly part 

### of the material supplied withthis filing is adopted, andifso,which part: Eachofthe entire test methods is incorporated. 6 . Please explainwhythe agency decided notto reproduce theincorporated material in full text of the rule. 

### The test methods aretechnical and would maketheVermont rules unnecessarilylong. Certification: As the adopting authority (see 3V.S.A. §801(b)(11)for definitions) ofthis rule, I herebycertifythat thetext ofthematter incorporated has been reviewed byConrad Smith , an official oftheAgency. I furthercertifythat theAgencyhas the capacityand intent to enforcethe rule. Elizabeth McLain, . Secretary Agency ofNatural Resources Date:

2 06/23/03 IBRStatementforFinalProposed Rule1180 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 ASTMD 1475-60, 80, or 90, Standard Test Method for Density of Paint, Varnish, Lacquer, and Related Products . 6 :2 ASTMD 2369-81, 87, 90, 92, 93, or 95, Standard Test Method for Volatile Content of Coatings . 6 .3 ASTMD 3792-79 or 91, Standard Test Method for Water Content of Water Reducible Paints by Direct Injection into a Gas Chromatograph . 6.4 ASTMD 4017-81, 90, or 96a, Standard Test Method for Water in Paints and Paint Materials by the Karl Fischer Titration Method . . 6 .5 ASTM4457-85 (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 ASTMD 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 limits1184 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 ASTMmethods 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 ASTMD 5403 to determine the volatile matter content of the coating except the curing test described in NOTE 2 of ASTMD 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, followSection 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 is1185 greater than or equal to 225 cm2 (35 in') then the coating or ink is considered a thin-filmUV radiation-cured coating and ASTMD 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 screwtop 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 ASTMD2369, 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 newone . Similarly, prepare a1187 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, followSection 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 ASTMD 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 ASTMD 3792 or ASTMD 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 ASTMD 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 ASTMprocedures 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, (in2)

. 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. 24-11191 12 .3 Calculate W for each analysis as shown below : WlOW 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 WVOWW 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 ASTMD 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 sampleincluding, 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 referencestandards (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 newpipets (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 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 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 newpipet (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,screwcap, 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 areno 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 eachday 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 willresult 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, newsamples 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 fromup 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 containerfor 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 . ASTMDesignation 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 : 

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### AMENDMENTS TO VERMONT SIP NARRATIVE

### SECTION-6 

## STRATEGIES FORAMBIENTAIRQUALITY STANDARD ATTAINMENT There are no SIPstrategies 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 informEPAofnew violations of the National AmbientAirQualityStandards ona timely basis ifandwhen they occur. 

## STRATEGIES TOADDRESSOZONE NON-ATTAINMENT INTHE

NORTHEAST OZONETRANSPORT REGION The SIP revision of August 1993 incorporates several newregulations 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 newregulations 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 followingdiscussion. TheVermont Air PollutionControl Regulations for the ControlofVolatile 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 followwhen 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 subjectto 5-253will be able to utilize alternative VOC control plans to those required by the regulations only if there is a concurrent submittal to EPAby 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 aTitleVpermit forthesource.

## GASOLINE STORAGE ANDDISTRIBUTION

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

LIQUIDSTORAGE IN FIXEDROOF 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 . BULKGASOLINE TERMINALS Theregulations 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 VOCrelease to the atmosphere during product loading or transfer meets reasonably available control technology standards. Bulk gasoline terminals are defined as gasoline storageand distribution facilities with an average daily throughput of more than 20,000 gallons of gasoline on a 3-day rolling averagebasis. BULKGASOLINE PLANTS The regulations describe the acceptable procedures and standards to be met for delivery of liquid products into gasoline tanks fromincoming gasoline trucks orviceversa 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 minimizedduring producttransfer. Bulk gasoline plants are definedas gasoline storage anddistribution facilities with anaveragedailythroughput of less than or equalto 20,000gallons ofgasoline ona 30-day rollingaveragebasis. GASOLINE TANKTRUCKS 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 ofthis term in theregulation.

### STAGE IVAPORRECOVERY CONTROLSAT GASOLINE DISPENSING FACILITIES The regulations require all gasoline dispensing facilities (basically gasoline service stations), which receive deliveries fromdelivery 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 fromthe delivery trucks. The systemmust be one in which gasoline vapors are forced fromthe storage tank into a vapor-tight gasoline tank truck or collection systemthrough direct displacement by the gasoline loaded intothe tank ("Stage I"). 

## PAPERCOATING Section 5-253.10ofthe Air Pollution Control Regulations has been amendedto meet thefederal standard forcontrol . Therule affects at least two businesses in Vermont, which are engaged in paper coating forvarious purposes. It specifies acceptable control methods and technology for reducing emissions of VOCs by paper coating operations and lowers the applicable emission thresholdfromwhat ithadbeen prior toits adoption in the SIP. 

## COATINGOF FLAT WOODPANELING 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 fromthe coatingoperations conducted. 

## COATINGOF MISCELLANEOUS METAL PARTS Section 5-253.13 oftheAir PollutionControl Regulations requires businesses that engage in the coating of metal parts to reduce air pollution by either low polluting coatings that complywith the emission standards or by using control devices to reduce their emissions ofVOCs. 

## SOLVENT METAL CLEANING Section 5-253.14oftheAir PollutionControl Regulations requires approximately 60businesses in Vermont to install new control devices or retrofit existing equipment in order to control emission ofVOCs fromdegreasing units if solvents areused to cleanmetal .

## WOODFURNITURE MAN UFACTURING Section 5-253. 16 of the Air Pollution Control Regulations restricts the emissions of VOCs and volatile hazardous air pollutants (VHAP) fromwood furniture manufacturing facilities that exceed therespective applicability threshold contained in the regulation. Air emissions ofthese pollutants are restricted by either limiting the content ofthese pollutants in the various coatings o r by achieving equivalent limits by use of a control device. The regulation also imposes work ractice reauirements including thedevelopmentofawork practice implementation plan. 

## OTHERSOURCESTHAT EMIT VOLATILE ORGANICCOMPOUNDS Section 5-253.20 of the Air Pollution Control Regulations regulates the emissions of VOCs fromany 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 50tons or more ofVOCs per year. Sources that once become subject to this subsection remain subject to it even if allowableemissions fall below 50tons ofVOCperyear. 

## TEST METHODS, CALCULATIONPROCEDURES, RECORDKEEPING, ANDMONITORING REQUIREMENTS NECESSARY FORTHE IMPLEMENTATIONOF VOCCONTROL MEASURES FOR ADDRESSING REGIONAL OZONE NON-ATTAINMENT

Except as otherwise specified belowor 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 followtest 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 EPAdocuments "Model Volatile Organic Compound Rules for Reasonably Available Control Technology (unnumbered June 1992), "Control ofVolatile Organic Compound Emissions fromWood Furniture Manufacturing Operations" (EPA-453/R96-007) , and 40 CF R Part 63 Subpart JJ - National Emission Standards for Wood Furniture Manufacturing Operations The Air Pollution Control Officerwill not allowthe use ofany test methods as alternatives to established EPAtest methods without priorapproval of EPA . Some of the procedures and methods believed to be applicable to sources regulated under Vermont Regulation 5-253 are presented belowto assist the regulated community. The Air Pollution Control Officer will consider these listed procedures as non-discretionary requirements for complyingwith 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 usingthefollowing

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 ofdifferent coatings as applied each day, Vi is the volume in gallonsof each particular coating, Ci is the VOCcontent in pounds of VOCper gallon of each coating, and VT is the total volume of all coating in gallons. In all casesthe volumes should be applied excluding water andexempt compounds. 2 . Procedure for determining the required overall emission reductionefficiency for control systems subjectto 5-253.13(d)(1)(ii) : The required overall emission reduction efficiency needed to demonstrate compliance is determined eachdayusingthefollowing steps: (1) Calculate the emission limitation (S) on a solids basis by using the appropriate emission limitation (C) fromthe regulation on a pounds VOCpergallon basis (excluding water and exempt compounds) and a standard conversion density equal to 7.36 pounds per gallon in the followingequation: C

S = 1- ( C)

7.36 (2) Calculate therequired overall emission reductionefficiency (E) ofthe control system

forthe dayusingthe following equation: (VOC S) E _ *100 VOC

### where: VOC =The maximum VOCcontent 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 . belowentitled "Procedures for determining the VOC content of coatings under 5-253.13" . 3. Procedure fordeterminingthe achieved overall emission reductionefficiency for control systemssubjectto 5-253.13(d)(1)(ii) : i) Achieved reductionefficiency 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 ofcapture efficiency is notnecessary, however, acomparison 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 givenin 40 CFR60.433:

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 rollingperiod. The recovery efficiency for each day is computed as the ratio ofthe total recoveredVOCfor that day andthe prior 6 consecutive operating days to the total solvent usage for the same7-dayperiod used forthe recoveredVOC .

### 4

. Procedures for determiningtheVOCcontentofcoatings under 5-253.13:

(a) Sampling procedures shall followthe guidelines presented in "Standard Procedure for Collection of Coating and Ink Samples for VOCContent Analysis by Reference Method 24 and Reference Method 24A", EPA340/1-91-010. (b) For single component coatings, analytical Method 24 of 40 CFRPart 60, Appendix Ashall be usedtodetermine totalvolatile content, water content, and density of coatings. Samples used for total volatile content determination shall be oven-dried at 100 degrees centigradefor onehour. (c) For multi-component coatings, Method 24should 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 fromthe 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 100degrees 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 ofan incinerator or regenerative carbonadsorber to comply with anypart of 5-253.13 must be accompanied by the installation of a continuous emission monitoring system(CEMS) to monitorthefollowing 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 . VOCconcentrationofthe outlet fromeachcarbon adsorption bed. 6 . Additional recordkeeping requirements forcompliancewith 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 VOCemissions at the facility for adayrepresentativeof maximum

production levels. Adaily-weighted averageofthe combined VOCemissions fromall operations at the facility shall be calculated using theequation below : n T= i 1Ai* Bi i where n = number ofdifferent coatings appliedoneachcoatingunit,

each coatingline, or each operationat thefacility. Ai = Mass ofVOCpervolume of coating (excluding waterand exempt compounds),as applied, usedat thefacility in lbsVOC/gallon. Bi = Volume of coating (excluding water and exempt compounds), as applied, usedat the facility in gallons/day. 7. Testing andrecord keepingrequirements 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 ofthe carbon adsorption unit and records containing the results of all tests conducted for a period of fiveyears. The submittal of an initial compliance certification fromall 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, andmust 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 ofcomputations to determine themagnitude ofthe excess emissions, and also the proposedcorrective actions to eliminate theexcess emissions.

### Excess emissions related torefrigerated chillers, carbonadsorbers, or any other control systemdemonstrated 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. Aperformance test of the control device for its ability to achieve compliancewith 5-253.14. 2 . Maintenance records for a period of five years of performance parameters related totheperformance ofthe 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 maintenancedetails andduration ofanyoutages. 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 averageVOC concentration or the reading of organics in the exhaust gases is more than 20percent 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 paragraphat the startofthis section.