250-RICR-120-05-19
250-RICR-120-05-19. Control of Volatile Organic Compounds from Surface Coating Operations (version Amendment, 01/09/2017 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 OPERATIONS
Effective 13 November 1979
Last Amended: 9 January 2017
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 ...................................................... 13
19.6
Registration ................................................................................................................................................... 23
19.7
Compliance Demonstration/Testing .............................................................................................................. 23
19.8
Compliance Schedules .................................................................................................................................. 24
19.9
General Provisions ......................................................................................................................................... 26
APPENDIX A ............................................................................................................................................... 28
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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.
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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.
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.);
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(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 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 anti-chip 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;
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(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.
(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.
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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;
19.2
Applicability
19.2.1
Except as specified in Subsection 19.2.6, 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
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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;
(c)
If the limit in (a) is exceeded, the emission limitations specified in
Subsection 19.3.1 will immediately apply.
19.2.6
The emissions limits in Section 19.3 shall not apply to the use of any
adhesive, sealant, adhesive primer or sealant primer in an operation that is
subject to the emission limits of Rhode Island Air Pollution Control
Regulation No. 44, “Control of Volatile Organic Compounds from
Adhesives and Sealants.”
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.
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19.4.7
An approvable bubble must meet the following requirements:
(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.
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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:
(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:
n
i
i
iB
A
T
1
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;
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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.
(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 facility associated 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.
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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;
(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:
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(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 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:
Page 17 of 29
(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:
(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.
Page 18 of 29
(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:
(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,
Page 19 of 29
(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;
(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;
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(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.
(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:
Page 21 of 29
(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;
(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.
Page 22 of 29
(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:
(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
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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. By April 15th of
each year, unless otherwise specified, the following information must be
submitted:
(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 previous calendar year, 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 previous calendar year.
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.)
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:
Page 24 of 29
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 achieved after equipment is in satisfactory operation.
19.8.3
All compliance schedules based upon reformulation shall provide for
Page 25 of 29
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.
(c)
For paper, fabric and vinyl coating facilities having potential
Page 26 of 29
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.
Page 27 of 29
19.9.5
Effective Date
The foregoing regulation, "Control of Volatile Organic Compounds from Surface
Coating Operations”, as amended, is hereby adopted and filed with the Secretary of
State this 20th day of December, 2016, in accordance with the provisions of
Chapters 23-23, 42-35, 42-17.1, 42-17.6, of the General Laws of Rhode Island of
1956, as amended.
Janet Coit, Director
Department of Environmental Management
Notice Given on:
May 5, 2016
Filing Date:
December 20, 2016
Effective Date:
January 9, 2017
Page 28 of 29
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 29 of 29
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.