250-RICR-120-05-19
250-RICR-120-05-19. Control of Volatile Organic Compounds from Surface Coating Operations (version Amendment, 07/19/2007 to 01/09/2017)
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
OFFICE OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO. 19
CONTROL OF VOLATILE ORGANIC COMPOUNDS
FROM SURFACE COATING OPERATION
Effective: 13 November 1979
Last Amended: 19 July 2007
AUTHORITY: These regulations are authorized pursuant to R.I. Gen. Laws § 42-
17.1-2(s) and 23-23, as amended, and have been promulgated pursuant to the
procedures set forth in the R.I. Administrative Procedures Act, R.I. Gen. Laws Chapter
42-35.
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
OFFICE OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO. 19
CONTROL OF VOLATILE ORGANIC COMPOUNDS
FROM SURFACE COATING OPERATION
TABLE OF CONTENTS
19.1
Definitions.....................................................................................................................................................1
19.2
Applicability..................................................................................................................................................6
19.3
Emission Limitations.....................................................................................................................................7
19.4
Alternative Standards Allowing Internal Offsets for Surface Coating Facilities (The Bubble
Concept)........................................................................................................................................................10
19.5
Compliance Certification, Recordkeeping and Reporting Requirements....................................................12
19.6
Registration .................................................................................................................................................22
19.7
Compliance Demonstration/Testing............................................................................................................22
19.8
Compliance Schedules.................................................................................................................................23
19.9
General Provisions........................................................................................................................................25
APPENDIX A .............................................................................................................................................27
Page 1 of 28
RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
OFFICE OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO. 19
CONTROL OF VOLATILE ORGANIC COMPOUNDS FROM
SURFACE COATING OPERATIONS
19.1 Definitions
Unless otherwise expressly defined in this section, the terms used in this regulation shall be
defined by reference to the Rhode Island Air Pollution Control General Definitions
Regulation. As used in this regulation, the following terms shall, where the context permits,
be construed as follows:
19.1.1 "Actual Emissions" means the quantity of volatile organic compounds emitted
from a source during a particular time period.
19.1.2 "Air-dried coating" means a coating that is dried by the use of air or forced
warm air at temperatures up to 90EC (194EF).
19.1.3 "Class II hardboard paneling finish" means finishes that meet the
specifications of Voluntary Product Standard PS-59-73 as approved by the
American National Standards Institute.
19.1.4 "Clear coating" means a coating that (1) either lacks color and opacity or is
transparent and (2) uses the surface to which it is applied as a reflective base or
undertone color.
19.1.5 "Coating applicator" means a device, mechanism, or apparatus used to apply a
surface coating. Common types of application techniques include knife, roll,
spray or dip.
19.1.6 "Coating line" means an operation or manufacturing process or device which
may be comprised of one or more coating applicators, one or more flash-off areas
and/or one or more ovens wherein a surface coating is dried and/or cured.
19.1.7 "Drum" means any cylindrical metal shipping container of 13- to 110-gallon
capacity.
19.1 8 "Emission Baseline" means a level of emissions calculated by multiplying two
factors:
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(a)
the lowest of the source's actual or allowable emission rate in emissions
per unit of production; and
(b)
the source's actual capacity utilization, or units of production, over some
representative time period. Generally, the time period is the preceding
two year average unless the source can demonstrate that those years were
not representative of historical production.
19.1.9 "Extreme performance coatings" means coatings intended for exposure to any
of the following; outdoor weather conditions all of the time, temperatures
frequently above 95EC (203EF), detergents, abrasive and scouring agents,
solvents, corrosive atmospheres, or similar environmental conditions.
19.1.10 "Hardboard" is a panel manufactured primarily from inter-felted ligno-
cellulosic fibers that are consolidated under heat and pressure in a hot press.
19.1.11 "Hardwood plywood" is plywood whose surface layer is a veneer of hardwood.
19.1.12 "Metal Cans" means any cylindrical single walled container, with or without a
top, cover, spout, and/or handle that is manufactured from metal sheets thinner
than 29 gauge (0.0141 inches) and into which solid or liquid materials are
packaged.
19.1.13 "Multicomponent coating" means a coating which is packaged in two or more
parts, which parts are combined before application, and where a coreactant from
one part of the coating chemically reacts, at ambient conditions, with a coreactant
from another part of the coating.
19.1.14 "Natural finish hardwood plywood panels" means panels whose original grain
pattern is enhanced by essentially transparent finishes frequently supplemented by
fillers and toners.
19.1.15 "Oven" means a chamber within which heat is used to bake, cure or polymerize
and/or dry a surface coating.
19.1.16 "Pail" means any cylindrical metal shipping container with a capacity of greater
than or equal to 1 and less than 13 gallons and constructed of 29-gauge and
heavier material.
19.1.17 "Prime Coat" means the first of two or more coatings applied to a surface.
19.1.18 "Printed interior panels" means panels whose grain or natural surface is
obscured by fillers and basecoats upon which a simulated grain or decorative
pattern is printed.
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19.1.19 "Refinishing" means the repainting of used equipment.
19.1.20 "Surface coating" means a process whereby a layer of one or more substances
containing VOC and solids are deposited on another material (substrate) in a
uniform manner across the surface of the substrate. The layer of coating may be
used for appearance, to decorate, bond, protect, strengthen, functionalize and/or
impart stability, water or acid repellence or mildew resistance. For purposes of
this regulation only, types of coating processes are defined as follows:
(a)
Paper coating - the application of a coating or coatings on paper, pressure-
sensitive tapes, plastic film or metal foil to impart any or all qualities
above.
(b)
Fabric coating - the application of a coating or coatings on a textile
substrate to impart any or all qualities above.
(c)
Vinyl coating - the application of a coating or coatings on a vinyl coated
paper, vinyl coated fabric, or vinyl substrate or printing on vinyl-coated
fabric or vinyl sheets to impart any or all qualities above.
(d)
Miscellaneous metal parts and products (MMP) coating means the
application of a coating or coatings, including but not limited to adhesives,
on any metal part or metal product, even if attached to or combined with a
nonmetal part or product. Miscellaneous metal parts and products include,
but are not limited to:
(1)
Large farm machinery (harvesting, fertilizing and planting
machines, tractors, combines, etc.);
(2)
Small farm machinery (lawn and garden tractors, lawn mowers,
rototillers, etc.);
(3)
Small appliances (fans, mixers, blenders, crock pots,
dehumidifiers, vacuum cleaners, etc.);
(4)
Commercial machinery (office equipment, computers and auxiliary
equipment, typewriters, calculators, vending machines, etc.);
(5)
Industrial machinery (pumps, compressors, conveyor components,
fans, blowers, transformers, etc.);
(6)
Fabricated metal products (metal covered doors, frames, etc.);
(7)
Any other industrial category that coats metal parts or products
under the Standard Industrial Classification Codes of Major
Group 33 (primary metal industries), Major Group 34 (fabricated
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metal products), Major Group 35 (non-electric machinery), Major
Group 36 (electrical machinery), Major Group 37 (transportation
equipment), Major Group 38 (miscellaneous instruments), and
Major Group 39 (miscellaneous manufacturing industries); and
(8)
Application of underbody antic hip materials (e.g., underbody
plastisol) and coating application operations other than prime,
primer surface, topcoat, and final repair operations at automobile
and light-duty truck assembly plants.
(9)
Miscellaneous metal parts coating does not include the application
of a coating or coatings to the following:
(i)
Automobiles and light-duty trucks;
(ii)
Automobile and light duty truck refinishing;
(iii)
Customized top coating of automobiles and trucks, if
production is less than 35 vehicles per day;
(iv)
Metal cans;
(v)
Flat metal sheets and strips in the form of rolls or coils;
(vi)
Magnet wire for use in electrical machinery;
(vii)
Metal furniture; and
(viii) Large appliances.
(ix)
Exterior of completely assembled aircraft;
(x)
Exterior of major aircraft subassemblies, if approved by the
Director, and approved by EPA, as a Federal
Implementation Plan (FIP) or State Implementation Plan
(SIP) revision;
(xi)
Exterior of completely assembled marine vessels; or
(xii)
Exterior of major marine vessel subassemblies if approved
by the Director, and approved by EPA, as a FIP or SIP
revision; or
(xiii) Exterior of tanks used for bulk storage of chemicals at the
facility.
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(e)
Magnet wire coating - the application of a coating in which an electrically
insulating varnish or enamel is applied onto the surface of a wire for use in
electrical machinery.
(f)
Coil coating - the application of a coating to any continuous metal strip
with thickness of 0.006 inch or more that is packaged in a roll or coil.
(g)
Flat wood paneling coating - the application of a coating to flat wood
panels including: printed interior panels made of hardboard plywood and
thin particle board (i.e., less than or equal to 0.25 inches in thickness)
natural finish hardboard plywood panels; and hardboard paneling with
Class II finishes.
(1)
Flat wood paneling does not include: Class I hardboard panels,
particle board used in furniture or wood products, insulation board,
exterior siding, tile board, and soft wood plywood coating lines.
(h)
Metal furniture coating - the application of a coating to any furniture piece
made of metal or any metal part that will be assembled with other metal,
wood, fabric, plastic, or glass parts to form a furniture piece including, but
not limited to, tables, chairs, waste baskets, beds, desk, locker, benches,
shelving, file cabinets, and room dividers.
(i)
Large appliance coating - the application of a coating to the surface of
component metal parts (including, but not limited to, doors, cases, lids,
panels and interior parts) of any residential or commercial washer, dryer,
freezer, range, refrigerator, water heater, dishwasher, trash compactor, air
conditioner, or other similar products under Standard Industrial
Classification Code 363.
(1)
Large appliance coating does not include the use of quick drying
lacquers for repair of scratches and nicks that occur during
assembly, provided that the volume of coating does not exceed
0.25 gallons in any one 8 hour period.
19.1.21
"Thin particleboard" is a manufactured board that is 0.25 inch or less
in thickness made of individual wood particles that have been coated with a
binder and formed into flat sheets by pressure.
19.1.22
"Tile board" means paneling that has a colored, waterproof surface coating.
19.1.23
"Topcoat" means the final film or series of films of coating applied to a
surface;
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19.2
Applicability
19.2.1 The provisions of this regulation apply to all surface coating facilities for which
actual uncontrolled emissions from all operations in any one of the surface
coating categories listed as Subsections 19.1.20 (a)-(i) have been greater than 15
pounds of volatile organic compounds in any one day after December 31, 1989.
19.2.2 Where ever the term Volatile Organic Compound or VOC is used in Sections 19.2
through 19.8 and Subsection 19.1.1 this term should be read as Volatile Organic
Compound and Halogenated Organic Compound or VOC and HOC.
19.2.3 An owner or operator of a surface coating facility whose emissions are below the
applicability threshold in Subsection 19.2.1 shall comply with the certification,
recordkeeping, and reporting requirements of Subsection 19.5.1.
19.2.4 Any facility that was subject to the provisions of this regulation on or before
November 19, 1992 by having or having had the potential to emit 100 tons of
VOC per year from paper, fabric, or vinyl coating or becomes subject to the
provisions of this regulation after November 19, 1992 by exceeding the
applicability threshold in Section 19.2.1 will remain subject to these provisions
even if its emissions later fall below the applicability threshold.
19.2.5 Any surface coating facility which has actual emissions of 15 lbs VOC/day or
more in any one day from all operations in any one of the surface coating
categories listed as Subsections 19.1.20 (a)-(i), but has not had total actual VOC
emissions from surface coating operations exceeding 1,666 pounds in any
calendar month since December 31, 1989, may apply to the Director for
exemption from Section 19.3 of this regulation. Exemption will be given in the
form of an enforceable document, and will include the following conditions:
(a)
The total emissions from all surface coating operations shall not exceed
1,666 pounds in any one calendar month,
(b)
The facility shall maintain the following records at the facility for a period
of five years. This information shall be made available to DEM and EPA
upon request:
(1)
The name, identification number and amount used each month of
each coating, as applied, on each coating line or operation;
(2)
The mass of VOC per volume (excluding water), as applied, for
each coating used on each coating line or operation;
(3)
The type and amount of solvent used for diluents and cleanup
operations;
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(c)
If the limit in (a) is exceeded, the emission limitations specified in
Subsection 19.3.1 will immediately apply.
19.3
Emission Limitations
19.3.1 As outlined in the following table, surface coating lines must meet the emission
limitations given below in either pounds of VOC per gallon of coating (minus
water) or in pounds of VOC per gallon of solids, depending on the method of
compliance:
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TYPE OF SURFACE
EMISSION LIMITATION
lbs VOC/gallon of
coating minus water
lbs VOC/gallon of
solids
Paper
2.9
4.79
Fabric
2.9
4.79
Vinyl
3.8
7.86
Flat wood Paneling*
Printed Interior Wall Panels
Made of Hardwood Plywood and Thin
Particleboard
6.0*
Natural Finish Hardwood
Plywood Panels
12.0*
Class II Finishes for
Hardboard Paneling
10.0*
Miscellaneous Metal Parts**
Clear Coating
4.3
10.34
Steel Pail and Drum Interiors
4.3
10.34
Air Dried Coating
3.5
6.67
Extreme Performance Coating
3.5
6.67
All other coating on misc.
metal parts
3.0
5.06
Metal Furniture
3.0
5.06
Coil
2.6
4.02
Large Appliances
2.8
4.52
Magnet Wire
1.7
2.21
*Emission limits for flat wood paneling are expressed in terms of lbs VOC/1000 square feet coated.
**For miscellaneous metal parts coating, if more than one emission limitation applies to a specific coating, then
the least stringent emission limitation shall be applied.
For facilities complying without using add-on control equipment, the pounds of VOC per gallon of coating
(minus water) limit must be met. For facilities which bubble or use add-on control equipment, the pounds of
VOC/gallon of solids emission limit must be met.
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19.3.2 Compliance with the emission limitations of Subsection 19.3.1 shall be achieved,
through:
(a)
Installation of an approved control system such that the total emission
reduction from the controlled coating line is 95 percent or greater over
uncontrolled volatile organic compound emissions, or
(b)
Coating reformulation such that the emission limitation of Subsection
19.3.1 is met for all coatings on any coating lines using this method of
compliance, or
(c)
Installation of control equipment to reduce emissions to the equivalent of
the emission limitations of Subsection 19.3.1 as calculated on a solids
applied basis, or
(d)
Use of daily-weighted averaging, as determined by the procedures in
Appendix A of this regulation, to achieve the emissions limitations in
Subsection 19.3.1 for all surface coating operations except the coating of
flat wood paneling;
(e)
An alternative equivalent method of control as approved by the Director.
Approval of an alternative method must be approved by EPA as a source
specific State Implementation Plan (SIP) revision.
19.3.3 The emission limitations set forth in Subsection 19.3.1 may be relaxed on a case-
by-case basis as provided below:
(a)
The emission limitations set forth in Subsection 19.3.1 shall not apply to
surface coating facilities that comply with the following, if 6 months prior
to the final compliance date the owner or operator of the facility submits
for approval by the Director:
(1)
Economic and/or technical documentation to the satisfaction of the
Department and EPA that the applicable emission limitations set
forth in Subsection 19.3.1 cannot feasibly be met, and
(2)
A proposal to set emission limitations different from those of
Subsection 19.3.1 that will represent an Alternative Reasonably
Available Control Technology; and
(3)
A schedule for attaining the Alternative Reasonably Available
Control Technology emission limitations within two years of its
being approved.
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(b)
All compliance date and emission limitation relaxations made under
Subsections 19.3.3 (a) will not be final until approved by EPA as a SIP
revision.
(c)
A relaxation of the emissions limitations in 19.3.1 will be approved only if
the facility can demonstrate that economically, technically or both that
neither coating reformulation nor the installation of a control system is
feasible or even partially feasible.
(d)
The facility will undergo Reasonably Available Control Technology
review every three years after the compliance date as determined in
19.3.3(a)(3) until the final emission limitation is achieved as defined in
subsection 19.3.1.
19.4
Alternative Standards Allowing Internal Offsets for Surface Coating Facilities (The
Bubble Concept)
19.4.1 The Director may approve alternative volatile organic compound emission
standards in an applicable compliance schedule if:
(a)
the facility as a whole complies in a 24 hour period with the applicable
emission limitations of Subsection 19.3.1 by the applicable compliance
date, and
(b)
the requirements of Subsections 19.4.2 through 19.4.7 are met, and
(c)
the state is designated by EPA as Attainment or as Non-Attainment With
Approved Demonstration of Attainment for Ozone.
19.4.2 (a)
The facility owner or operator specifies an emission limitation which
defines the alternative maximum allowable emission rate in pounds per
hour for each surface coating line which is part of the surface coating
facility, and which is eligible under the criteria in Subsection 19.4.2 (b),
and
(b)
To be eligible for consideration under this section the construction or
modification of the coating line must have commenced prior to the
effective date of the regulation, and
(c)
The combined actual emissions over a 24-hour period from all surface
coating in the bubble used at surface coating lines which are a part of the
surface coating facility and which are eligible as per subsection 19.4.2(b)
must be less than or equal to the allowable emission total (E) determined
by the following equation:
E = A1 x B1 + A2 x B2 + ... + An x Bn where:
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E = the allowable emissions from the surface coating facility in pounds
per day, A1, A2, ..., An = the applicable emission limitation for each
coating line as determined in Subsection 19.3.1 in pounds per gallon of
solids applied; B1, B2, ..., Bn = the amount of gallons of solids applied for
each coating in that 24-hour period.
(d)
All surface coating lines at the surface coating facility which are not
included in the internal offset must comply with other applicable portions
of this regulation. Non reactive VOC may not generate credit in a trade
against reactive VOC in a bubble.
19.4.3 In order for a facility to demonstrate compliance with the emission limitations
that were approved pursuant to Subsection 19.3.1, it is required that records shall
be maintained. The records shall be:
(a)
kept on a daily basis for each installation being bubbled; and
(b)
follow record keeping requirements of Subsection 19.5.2; and
(c)
maintained for a five-year period and be accessible for review by the
Director or the designated personnel of the Director.
19.4.4 Facilities applying to bubble will be assigned an emission baseline, as described
in Subsection 19.1.8 Capacity utilization will be based on the average production
during the two-year period prior to application to bubble. Facilities' annual
emissions may not exceed the limit set by the emission baseline. Emissions will
be reported monthly and compliance with the emission baseline will be met every
consecutive 12 month period or some shorter period approved by the Director.
19.4.5 The provisions and emission limitations of any emissions bubble shall be
incorporated in an approval, which must include source specific emission limits,
recordkeeping requirements, and test methods used to demonstrate compliance.
Facilities which are subject to an enforcement action need EPA approval to
bubble.
19.4.6 The ERC's used in an emissions bubble must be calculated on a solids applied
basis.
19.4.7 An approvable bubble must meet the following requirements:
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(a)
Emissions must be surplus. The reductions must not have been included
in those anticipated in the SIP for the affected source. Credit cannot be
taken for reductions made prior to the base year of the State's Approved
SIP. This is accomplished by not including any coatings that were in
compliance prior to the base year of the State's Approved SIP in the daily
calculation of actual emissions and the daily calculation of allowable
emissions in subsection 19.4.2 (c). Emissions reductions shown must not
have been required by current state regulations, and must not be used by
the source to meet any other regulatory requirement.
(b)
Emission reductions must be permanent. The amount and duration of the
reductions must be shown.
(c)
Emission reductions must be quantifiable. A reliable basis for calculating
the amount and rate of reductions must be used. Emission rates before
and after the reductions must be demonstrated.
(d)
Emission reductions must be enforceable. An approval containing
enforceable emissions rates will be issued. Demonstration of emission
reductions must follow recordkeeping guidelines listed in subsection
19.5.2.
(e)
All of the requirements of EPA's final Emission Trading Policy (51 FR
43814) must be met.
19.4.8 The Department shall not approve any emissions bubble without first giving
public notice at least 30 days prior to approval, and affording all interested
persons opportunity to comment. The public may request a hearing. Upon a
demonstration of significant public interest, the Director, in his discretion, may
hold a hearing. EPA shall be provided with the public notice, proposed approval
order, and technical support by the first day of the public comment period. Public
(and EPA) comments will be considered prior to final approval of the bubble
application. Upon issuance of final approval of the bubble, EPA will be mailed a
copy of the approval, new technical support, and response to public comments.
19.5
Compliance Certification, Recordkeeping and Reporting Requirements
19.5.1 Any owner or operator of a coating line or operation that is exempt from the
emission limitations in Section 19.3 because the facility's VOC emissions from all
operations in any one of the surface coating categories listed as Subsections
19.1.20 (a)-(i) have not exceeded 15 lbs/day, before the application of capture
systems and control devices, on any day since 31 December 1989, shall comply
with the following:
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(a)
Certification. By November 19, 1993, the owner or operator of a facility
referenced in Subsection 19.5.1 shall certify to the Director that the
facility is exempt by providing the following:
(1)
Name and location of the facility;
(2)
Name, address and telephone number of the person responsible for
the facility;
(3)
A declaration that the facility is exempt from the emission
limitations of Section 19.3 because the facility's VOC emissions
from all operations on each of the surface coating categories listed
as Subsections 19.1.20 (a) - (i) have not exceeded 15 lbs/day,
before the application of capture systems and control devices, on
any day since 31 December 1989;
(4)
Calculations that demonstrate that the combined VOC emissions
from all coating lines and operations at the facility for each of the
surface coating categories listed as Subsections 19.1.20 (a) - (i) for
a day representative of current maximum production levels are
15 pounds or less before the application of capture systems and
control devices. The following equation shall be used to calculate
total VOC emissions for that day for each surface coating
category:
Where:
T =
Total VOC emissions from coating lines and operations at the facility associated
with any one of the surface coating categories listed as Subsections 19.1.20 (a) -
(i), before the application of capture systems and control devices, in units of
lb/day;
n =
The number of different coatings applied on each coating line or each operation at
the facility associated with the surface coating category;
i =
Subscript denoting an individual coating;
Ai = Mass of VOC per volume of coating (i) (excluding water), as applied, used at the
facility in units of pounds VOC per gallon; and
Bi = Volume of coating (I) (excluding water), as applied, associated with the surface
Coating category, used at the facility in units of gallons per day. The instrument
or method by which the owner or operator accurately measured or calculated the
volume of each coating, as applied, used shall be described in the certification to
the Director.
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(b)
Recordkeeping. On and after November 19, 1993, the owner or operator
of a facility referenced in Subsection 19.5.1 shall collect and record all of
the following information each year and maintain the information at the
facility for a period of 5 years:
(1)
The name and identification number of each coating, as applied;
(2)
The mass of VOC per volume (excluding water) and the volume of
coating
(excluding water), as applied, used each year;
(3)
The total VOC emissions from coating lines and operations at the
facilityassociated with each of the surface coating categories listed
as Subsections 19.1.20 (a) - (i), before the application of capture
systems and control devices, as calculated using the equation in
Section 19.5.1(a)(5), and
(4)
The type and amount of solvent used for diluents and cleanup
operations.
(c)
Reporting. On and after November 19, 1993, the owner or operator of a
facility referenced in Subsection 19.5.1 of this regulation shall notify the
Director of any record
showing that the facility's VOC emissions from all operations in any one of the surface
coating categories listed as Subsections 19.1.20 (a) - (i), before the application of
capture systems and control devices, exceed 15 pounds on any day.
19.5.2 Any owner or operator of a coating line or operation that meets the applicability
threshold in Subsection 19.2.1 and complies with or intends to comply with
Subsection
19.3.1 by the use of daily-weighted averaging shall comply with the following:
(a)
Initial Compliance Certification Plan: By November 19, 1993, or upon
startup of a new coating line or operation, or upon changing the method of
compliance for an existing subject coating line or operation from control
devices or complying coatings to the use of daily-weighted averaging, the
owner or operator of a coating line or operation referenced in Subsection
19.5.2 shall certify to the Director that the coating line or operation is or
will be in compliance with the requirements of Subsection 19.3.1 on and
after the compliance dates specified in Subsection 19.8.5. Such
certification shall include:
(1)
The name and location of the facility;
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(2)
The name, address and telephone number of the person responsible
for the facility;
(3)
An identification of subject sources;
(4)
The name and identification number of each coating line or
operation which will comply by means of daily-weighted
averaging;
(5)
The instrument or method by which the owner or operator will
accurately measure or calculate the volume of each coating
(excluding water), as applied,used each day on each coating line or
operation;
(6)
The method by which the owner or operator will create and
maintain records each day as required by Subsection 19.5.2(b);
(7)
The time at which the facility's day begins if a time other than
midnight local time is used to define a day.
(b)
Final Compliance Certification: By the compliance dates
specified in Subsection 19.8.5, the owner or operator of
sources identified in Subsection 19.5.2 shall certify to the
Director that the facility is in compliance with the emission
limitations in Subsection
19.3.1 by the use of daily-
weighted averaging. This certification shall include:
(1)
The name, identification number, mass of VOC per volume (minus
water) and the volume of each coating (minus water), as applied,
on each coating line or operation and the calculation of the daily-
weighted average for each day of the previous month using the
procedure outlined in Appendix A of this regulation, or
(2)
The name, identification number, mass of VOC per volume (minus
water) and the volume of each coating (minus water), as applied,
on each coating line or operation, the density of each coating as
applied, and the volume fraction solids content of each coating, as
applied and the calculation of the daily-weighted average for each
day of the previous month using the procedure outlined in
Appendix A of this regulation, and
(3)
An identification of any changes from the initial compliance
certification plan.
(c)
Recordkeeping. On and after the compliance dates specified in Subsection
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19.8.5, the owner or operator of a coating line or operation referenced in
Subsection 19.5.2 and complying by the means of daily- weighted
averaging shall collect and record all of the following information each
day for each coating line or operation and maintain the information at the
facility for a period of 5 years:
(1)
The name and identification number of each coating, as applied, on
each coating line or operation,
(2)
The mass of VOC per volume coating (excluding water) and the
volume of each coating (excluding water), as applied, used each
day on each coating line or operation,
(3)
The daily-weighted average VOC content of all coatings, as
applied on each coating line or operation calculated according to
the procedure in Appendix A of this regulation
(4)
The type and amount of solvent used for diluents and cleanup
operations.
(d)
Reporting. On and after the compliance dates specified in Subsection
19.8.5, the owner or operator of a subject coating line or operation
referenced in Subsection 19.5.2 shall:
(1)
Notify the Director of any record showing noncompliance with the
applicable daily weighted average requirements by sending a copy
of the record to the Director within 30 calendar days following the
occurrence, and,
(2)
At least 30 calendar days before changing the method of
compliance from daily-weighted averaging to the use of complying
coatings or control devices, comply with all requirements of
Subsections 19.5.3 or 19.5.4, respectively. Upon changing the
method of compliance from the use of daily-weighted averaging to
complying coatings or control devices, the owner or operator shall
comply with all requirements of the sections of this regulation
applicable to that compliance method.
19.5.3 Any owner or operator of a coating line which meets the applicability threshold in
Subsection 19.2.1 of this regulation and complies with or intends to comply with
Subsection 19.3.1 by the use of complying coatings shall comply with the
following:
Page 17 of 28
(a)
Initial Compliance Certification Plan: By November 19, 1993, or upon
startup of a new coating line or operation, or upon changing the method of
compliance for an existing subject coating line or operation from daily-
weighted averaging or control devices to the use of complying coatings,
the owner or operator of a coating line or operation referenced in
Subsection 19.5.3 shall certify to the Director that the coating line or
operation is or will be in compliance with the applicable emission
limitations in this regulation on and after the compliance dates specified in
Subsection 19.8.5. Such certification shall include:
(1)
The name and location of the facility;
(2)
The name, address and telephone number of the person responsible
for the facility;
(3)
Identification of subject sources;
(4)
The name and identification number of each coating, as applied, on
each coating line or operation;
(5)
The mass of VOC per volume coating (excluding water) and the
volume of each coating (excluding water), as applied, and
(6)
The time at which the facility's day begins if a time other than
midnight local time is used to define a day.
(b)
Final Compliance Certification: By the compliance dates specified in
Subsection 19.8.5, the owner or operator of sources identified in
Subsection 19.5.2 shall certify to the Director that the facility is in
compliance with the emission limitations in Subsection 19.3.1 by the use
of complying coatings. This certification shall include:
(1)
The name, identification number, mass of VOC per volume (minus
water) and the volume of each coating (minus water), as applied,
on each coating line or operation and
(2)
An identification of any changes from the initial compliance
certification plan.
(c)
Recordkeeping. On and after the compliance dates specified in Subsection
19.8.5, the owner or operator of a coating line or operation referenced in
Subsection 19.5.3 shall collect and record all of the following information
each month for each coating line or operation and maintain the
information at the facility for a period of 5 years:
Page 18 of 28
(1)
The name and identification number of each coating, as applied, on
each coating line or operation, and
(2)
The mass of VOC per volume of each coating (excluding water),
as applied, used each month on each coating line or operation.
(3)
The type and amount of solvent used for diluents and cleanup
operations.
(d)
Reporting. On and after the compliance dates specified in Subsection
19.8.5, the owner or operator of a subject coating line or operation
referenced Subsection 19.5.3 shall:
(1)
Notify the Director of any record showing use of any non-
complying coatings by sending a copy of such record to the
Director within 30 calendar days following that use, and,
(2)
At least 30 calendar days before changing the method of
compliance from the use of complying coatings to daily-weighted
averaging or control devices, comply with all requirements of
Subsections 19.5.2 or 19.5.4, respectively. Upon changing the
method of compliance from the use of complying coatings to daily-
weighted averaging or control devices, the owner or operator shall
comply with all requirements of the section of this regulation
applicable to that compliance method.
19.5.4 Any owner or operator of a coating line or operation that meets the applicability
threshold in subsection 19.2.1 and complies with or intends to comply with
subsection 19.3.1 by means of control devices shall comply with the following:
(a)
Initial Compliance Certification Plan: By November 19, 1993, or upon
startup of a new coating line or operation, or upon changing the method of
compliance for an existing coating line or operation from the use of
complying coatings or daily-weighted averaging to control devices, the
owner or operator of the subject coating line or operation shall certify to
the Director that the coating line will be in compliance with the applicable
emission limits in this regulation on and after the compliance dates
specified in Subsection 19.8.5. Such certification shall include:
(1)
The name and location of the facility;
(2)
The name, address and telephone number of the person responsible
for the facility;
(3)
Identification of subject sources;
Page 19 of 28
(4)
The name and identification number of each coating, as applied, on
each coating line or operation;
(5)
The mass of VOC per volume coating solids applied and the
gallons of solids of each coating applied;
(6)
Identification of each control device which will be or has been
installed pursuant to the requirements in this regulation and date of
installation;
(7)
Identification of coating lines which will be controlled by each
control device and documentation of expected capture and
destruction efficiency or reduction efficiency;
(8)
Control device design information;
(i)
For thermal incinerators - design combustion temperature
(oF);
(ii)
For catalytic incinerators - design exhaust gas temperature
(oF), design temperature rise across catalyst bed (oF),
anticipated frequency of catalyst change, and catalyst
changes;
(iii)
For condensers - design inlet temperature of cooling
medium (oF), design exhaust gas temperature (oF);
(iv)
For carbon adsorbers - design pressure drop across the
adsorber, VOC concentration at breakthrough.
(b)
Final Compliance Certification: By the compliance dates specified in
Subsection 19.8.5, the owner or operator of sources identified in
Subsection 19.5.4 shall certify to the Director that control devices have
been installed which reduce emissions from subject lines. This
certification shall include:
(1)
An identification of each control device installed, including the
identification number, model number, installation date and coating
lines controlled.
Page 20 of 28
(2)
Results of compliance tests and associated calculations
demonstrating a 95% overall reduction of VOC emissions from
subject lines or reduction of emissions to the equivalent of the
emission limitations of Subsection 19.3.1 as calculated on a solids
applied basis. Overall reduction efficiency shall be calculated as
the product of the capture efficiency and the control device
destruction or removal efficiency. Testing shall be performed
according to Section 19.7. Capture efficiency shall be determined
by methods approved by the Department and EPA.
(3)
An identification of any changes from the initial compliance
certification plan.
(c)
Recordkeeping. On and after the compliance dates specified in Subsection
19.8.5, the owner or operator of a coating line or operation referenced in
Subsection 19.5.4 shall collect and record all of the following information
each month for each coating line or operation and maintain the
information at the facility for a period of 5 years:
(1)
The name and identification number of each coating used on each
coating line or operation;
(2)
For sources complying with Subsection 19.3.2 (a):
(i)
The mass of VOC per unit volume of coating solids, as
applied, the volume solids content, as applied, and the
volume, as applied, of each coating used each month on
each coating line or operation;
(3)
For sources complying with Subsection 19.3.2 (c):
(i) The maximum VOC content (mass of VOC per unit volume of
coating solids, as applied) or the daily-weighted average VOC
content (mass of VOC per unit volume of coating solids, as
applied) of the coatings used each day on each coating line or
operation;
(4)
The type and amount of solvent used for diluents and clean up
operations;
(5)
A log of operating time for the capture system, control device,
monitoring equipment, and the associated coating line or
operation;
Page 21 of 28
(6)
A maintenance log for the capture system, control device, and
monitoring equipment detailing all routine and non-routine
maintenance performed including
dates and duration of any outages;
(7)
For thermal incinerators:
(i)
All 3-hour periods of operation in which the average
combustion temperature was more than 28EC (50EF)
below the average combustion temperature during the most
recent performance test that demonstrated that the facility
was in compliance, and
(ii) The operating temperature.
(8)
For catalytic incinerators:
(i)
All periods where the temperature increase across the
catalyst bed is less than 80% of the temperature increase
recorded during the most recent performance test that
demonstrated that the facility was in compliance, and
(ii)
The inlet and outlet temperatures and temperature rise
across the catalyst bed.
(9)
For carbon adsorbers:
(i)
All 3-hour periods of operation during which the average
VOC concentration or reading of organics in the exhaust
gases is more than 20 percent greater than the average
exhaust gas concentration or reading measured by the
organics monitoring device during the most recent
determination of the recovery efficiency of the carbon
adsorber that demonstrated that the facility was in
compliance, and
(ii)
The pressure drop across the adsorber and the hydrocarbon
levels for breakthrough.
(d)
Reporting. On and after the compliance dates specified in Subsection
19.8.5, the owner or operator of a subject coating line or operation
referenced in Subsection 19.5.4 shall:
Page 22 of 28
(1)
Notify the Director of any record showing noncompliance with the
applicable requirements for control devices by sending a copy of
the record to the Director within 30 calendar days following the
occurrence, and
(2)
At least 30 calendar days before changing the method of
compliance from control devices to the use of complying coatings
or daily- weighted averaging, comply with all requirements of
Subsections 19.5.3 or 19.5.2, respectively. Upon changing the
method of compliance from control devices to the use of
complying coatings or daily-weighted averaging, the owner or
operator shall comply with all requirements of the section of this
regulation applicable to the coating line or operation referenced in
Subsection 19.5.4
19.6
Registration
19.6.1 Any person who meets the applicability threshold in Subsection 19.2.1 must
register annually with the Office of Air Resources. No later than 45 days
following the end of a calendar year, the following information must be submitted
on forms supplied by the Director:
(a)
The name and address of the company and the name and telephone
number of a responsible corporate official submitting the registration, and
(b)
A description of all operations in the facility where volatile organic
compounds are emitted, and
(c)
Quantities of coatings, solvents, dissolvers, viscosity reducers, diluents,
thinners, reagents, cleaning agents, enamels, lacquers, or paints consumed
during the calendar year of record, and
(d)
The amount of volatile organic compound per gallon of coating solution
(pounds per gallon) for each coating, enamel, lacquer, or paint consumed
at the facility during the calendar year of record.
19.7
Compliance Demonstration/Testing
19.7.1 Compliance with emission limitations of Subsections 19.3.1 and 19.3.3 and
Section 19.4 shall be demonstrated in accordance with 40 CFR 60, Appendix A,
Methods 24, 24A, 25 as amended or any other EPA approved method which has
been accepted by the Director. A one hour bake time must be used for Methods
24 and 24A and, further, Methods 24 and 24A apply to multicomponent coatings.
19.7.2 (Reserved for stack exhaust sampling techniques.)
Page 23 of 28
19.7.3 Facilities using add on controls to comply with RACT must show that the
equipment meets specific capture and control efficiency limits which will be set
in an enforceable document. Control efficiency of the equipment will be
determined using EPA-approved test methods. Calculations will be done on a
solids applied basis. Continuous compliance will be maintained at all times.
Compliance averaging times will be met according to the control device chosen
and EPA test methods (as codified in 40 CFR 60), as follows:
Compliance Method
EPA Reference Test
Method
Test Averaging Time
Reformulation
24
instantaneous
Solvent destruction or
solvent recovery except
carbon adsorption
25
3 hours
Carbon adsorption
25 or other test method as
appropriate
The length of adsorption
cycle or 24-hours, which-
ever is less.
or other methods approved by the Director and EPA. Once the control efficiency has
been determined for any add-on control device by Reference Method 25, or any
alternative method approved by the Department and EPA, compliance shall be
determined on an instantaneous basis time period (e.g. determined control efficiency
shall be used to calculate whether samples from the process meet the applicable
emissions limit.)
19.8
Compliance Schedules
19.8.1 Persons owning, leasing or controlling the operation of any surface coating
facility and subject to the emission limitations set forth in Subsection 19.3.1 shall
achieve compliance according to the dates set forth in Subsection 19.8.5.
Proposed plans and compliance schedules for paper, fabric, and vinyl coating
facilities which have or have had actual emission of 100 tons of VOC per year
will be submitted to the Director no later than 1 March 1980. The Director may
require other subject facilities to submit compliance schedules after review of
initial compliance certification.
19.8.2 All compliance schedules for process equipment replacement or modification or
installation of control equipment shall provide for periodic increments of progress
to document such, including but not limited to:
(a)
Submittal of engineering plans,
(b)
Ordering of equipment plan approval,
(c)
Installation date after confirmation of order by the manufacturer, and
(d)
Date by which the applicable regulatory emission limitations will be
Page 24 of 28
achieved after equipment is in satisfactory operation.
19.8.3 All compliance schedules based upon reformulation shall provide for periodic
increments of progress to document such, including but not limited to:
(a)
Submittal of research, engineering plans, and formulation,
(b)
Operating and maintenance procedures,
(c)
Schedules for research and development,
(d)
Purchase orders for reformulations,
(e)
Commencement and completion of process modifications, product
marketability testing, and
(f)
Date by which regulatory emission limitations will be achieved.
19.8.4 Any compliance schedule based on the provisions of Sections 19.3 and Section
19.4 shall not allow a facility to supersede any applicable emission limitations
including but not limited to:
(a)
Best Available Control Technology determinations, or
(b)
Lowest Achievable Emissions Rate determinations, or
(c)
Federal New Source Performance Standards, or National Emission
Standards of Hazardous Air Pollutants, or
(d)
Any other condition or standard that is specifically required by the Clean
Air Act (as amended) for new or modified sources.
(e)
In the case of a bubble issued under Section 19.4, the emission baseline as
defined by Subsection 19.1.8
19.8.5 Compliance schedules submitted in accordance with the requirements of
Subsection 19.8.1 are subject to review and approval by the Director.
Compliance shall be achieved as follows:
(a)
For paper, vinyl, and fabric coating facilities with actual emissions in
excess of 100 tons per year prior to 1985, no later than July 1, 1985.
(b)
For paper, fabric, and vinyl coating facilities having actual emissions of
100 tons per year or more between July 1, 1985 and December 10, 1989,
no later than one year after having become an actual 100 ton per year
source.
Page 25 of 28
(c)
For paper, fabric and vinyl coating facilities having potential emissions in
excess of 100 tons per year or more prior to 1990, no later than December
10, 1990.
(d)
For any surface coating facility covered by this regulation, which exceeds
the applicability threshold in Subsection 19.2.1 on or after November 19,
1992 and which does not come under Subsections (a) through (c) above,
no later than May 31, 1995. All coating lines commencing operation after
November 19, 1992 must be in compliance with the emission limits
specified in Section 19.3 upon commencing operation.
19.9
General Provisions
19.9.1
Purpose
The purpose of this regulation is to limit the emissions of volatile organic
compounds from surface coating operations.
19.9.2
Authority
These regulations are authorized pursuant to R.I. Gen. Laws § 42-17.1-2(s) and 23-
23, as amended, and have been promulgated pursuant to the procedures set forth in
the R.I. Administrative Procedures Act, R.I. Gen. Laws Chapter 42-35
19.9.3
Application
The terms and provisions of this regulation shall be liberally construed to permit the
Department to effectuate the purposes of state law, goals and policies.
19.9.4
Severability
If any provision of this regulation or the application thereof to any person or
circumstance, is held invalid by a court of competent jurisdiction, the validity of the
remainder of the regulation shall not be affected thereby.
19.9.5
Effective Date
The foregoing regulation, "Control of Volatile Organic Compounds from Surface
Coating Operations”, as amended, after due notice, is hereby adopted and filed with
the Secretary of State this _________ day of _______________, 20___ to become
effective twenty (20) days thereafter, in accordance with the provisions of Chapters
Page 26 of 28
23-23, 42-35, 42-17.1, 42-17.6, of the General Laws of Rhode Island of 1956, as
amended.
W. Michael Sullivan, PhD., Director
Department of Environmental Management
Notice Given on: February 21, 2007
Public Hearing held: March 23, 2007
Filing Date:
June 29, 2007
Effective Date: July 19, 2007
APPENDIX A
Procedure for Calculating the Daily-Weighted Averages
1. 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 coatings used on a
day on a coating line or operation shall be calculated using the following equation:
T
n
i
i
i
w
V
C
V
VOC
∑
=
=
1
where:
VOCw =
The daily-weighted average VOC content of the coatings, as applied, used
on a coating line or operation in units of pounds of VOC per gallon of
coating, excluding water and exempt compounds;
n =
The number of different coatings, as applied, each day on a coating line or
operation;
Vi =
The volume of each coating (i), as applied, used in a day on a coating line
or operation in units of gallons, excluding water and exempt compounds;
Ci =
The VOC content of each coating (i), as applied, used in a day on a
coating line or operation in units of pounds VOC per gallon of coating,
excluding water and exempt compounds; and
VT =
The total volume of all coating, as applied, used in a day on a coating line
or operation in units of gallons, excluding water and exempt compounds.
Page 27 of 28
2. The daily-weighted average VOC content, as applied, of the coatings used on a coating
line or operation in units of mass of VOC per unit volume of coating solids shall be
calculated by the following equation:
∑
∑
=
=
=
n
i
i
i
n
i
i
i
VOC
ws
VS
V
V
D
W
VOC
i
1
1
where:
VOCws =
The daily-weighted average VOC content, as applied, of the coatings used
on a coating line or operation in units of mass of VOC per unit volume of
coating solids;
n =
The number of different coatings, as applied, used in a day on a coating
line or operation;
Vi =
The volume of each coating (i), as applied, used in a day on a coating line
or operation in units of gallons,
WVOCi =
The weight fraction of VOC in each coating (i), as applied, used in a day
on a coating line or operation in units of pounds VOC per pound of
coating;
Di =
The density of each coating (i) as applied, used in a day on a coating line
or operation in units of pounds VOC per gallon of coating (lb/gal); and
VSi =
The volume fraction solids content of each coating (i), as applied, used in
a day on a coating line or operation in units of gallons solids/gallons
coating.
Page 28 of 28