250-RICR-120-05-35
250-RICR-120-05-35. Air Pollution Control Regulation No. 35- Control of Volatile Organic Compounds and Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations (version Periodic Refile, 12/31/2001 to 07/19/2007)
Effective 7 March 1996
Last Amended 7 July 1996
AIR POLLUTION CONTROL REGULATION NO. 35
CONTROL OF VOLATILE ORGANIC COMPOUNDS AND
VOLATILE HAZARDOUS AIR POLLUTANTS FROM
WOOD PRODUCTS MANUFACTURING OPERATIONS
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RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
DIVISION OF AIR RESOURCES
AIR POLLUTION CONTROL REGULATION NO. 35
CONTROL OF VOLATILE ORGANIC COMPOUNDS AND
VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS
MANUFACTURING OPERATIONS
35.
Control of Volatile Organic Compounds and Volatile Hazardous Air Pollutants from
Wood Products Manufacturing Operations
35.1 Definitions
As used in this regulation, the following terms shall, where the context permits, be
construed as follows:
35.1.1. "Adhesive" means a chemical substance that is applied for the purpose of
bonding two surfaces together other than by mechanical means.
35.1.2. "Alternative method" means a method of sampling and analyzing for an air
pollutant that is not a reference or equivalent Environmental Protection Agency (EPA)
sampling method but that has been demonstrated to the EPA's satisfaction to, in specific
cases, produce results adequate for a determination of compliance.
35.1.3. "As applied" means the VOC, VHAP and solids content of the coating material as
it is used for coating the substrate, including the contribution of thinners.
35.1.4. "Basecoat" means a coat of colored material, usually opaque, that is applied
before graining inks, glazing coats, or other opaque finishing materials and is usually
topcoated for protection.
35.1.5. "Capture device" means a hood, enclosed room, floor sweep, or other means of
collecting solvent emissions or other pollutants into a duct so that pollutants can be
directed to a pollution control device such as an incinerator or a carbon adsorber.
35.1.6. "Capture efficiency" means the fraction of all organic vapors generated by a
process that are directed to a control device.
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35.1.7. "Certified product data sheet" or "CPDS" means documentation furnished by a
coating supplier or an outside laboratory that provides the VHAP content, VOC content,
solids content, and density of a finishing material, strippable booth coating, adhesive, or
solvent, measured using EPA Methods 24 and 311, or an equivalent or alternative method
(or formulation data if the coating meets the criteria specified in Subsection 35.8.1(b)).
The purpose of the CPDS is to assist the facility in demonstrating compliance with the
emission limitations presented in Sections 35.3, 35.4 and 35.5 of this regulation.
Therefore, the VOC and VHAP content should represent the maximum VOC and VHAP
emission potential of the finishing material, strippable booth coating, or solvent.
35.1.8. "Cleaning operations" means operations in which organic solvent is used to
remove coating materials from equipment used in wood products manufacturing
operations.
35.1.9. "Coating" means a protective, decorative, or functional material applied in a thin
layer to a surface. Such materials include, but are not limited to, paints, topcoats,
varnishes, sealers, stains, washcoats, basecoats, adhesives, inks, enamels, and temporary
protective coatings.
35.1.10. "Coating solids or solids" means the part of a coating that remains after the
coating is dried or cured; solids content is determined using data from EPA Method 24.
35.1.11. "Compliant coating" means a finishing material, adhesive, or strippable booth
coating that meets applicable emission limitations specified in Section 35.3 and 35.4 of
this regulation.
35.1.12. "Contact adhesive" means an adhesive that is applied to two substrates, dried,
and mated under only enough pressure to result in good contact. The bond is immediate
and sufficiently strong to hold pieces together without further clamping, pressure, or
airing.
35.1.13. "Continuous coater" means a finishing system that continuously applies
finishing materials onto wood parts moving along a conveyor system. Finishing materials
that are not transferred to the part are recycled to the finishing material reservoir. Several
types of application methods can be used with a continuous coater including spraying,
curtain coating, roll coating, dip coating, and flow coating.
35.1.14. "Continuous compliance" means that the facility is meeting the applicable
emission limitations and other applicable requirements of this regulation at all times and
is fulfilling all monitoring and recordkeeping provisions of the regulation in order to
demonstrate compliance.
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35.1.15. "Control device" means any equipment that reduces the quantity of a pollutant
that is emitted to the air. The device may destroy or secure the pollutant for subsequent
recovery. Control devices include, but are not limited to, incinerators, carbon adsorbers,
and condensers.
35.1.16. "Control device efficiency" means the ratio of the amount of pollutant released
by a control device to the amount of pollutant introduced to the control device, expressed
as a fraction.
35.1.17. "Control system" means the combination of capture and control devices used to
reduce emissions to the atmosphere.
35.1.18. "Conventional air spray" means a spray coating method in which the coating is
atomized by mixing it with compressed air at an air pressure greater than 10 pounds per
square inch (gauge) at the point of atomization. Airless, air assisted airless, and
electrostatic spray technologies are not considered conventional air spray methods.
35.1.19. "Day" means a period of 24 consecutive hours beginning at midnight local time,
or beginning at a time consistent with a facility's operating schedule.
35.1.20. "Disposed offsite" means sending used organic solvent or coatings outside of
the facility boundaries for disposal.
35.1.21. "Emission" means the release or discharge, directly or indirectly, of one or more
air pollutants into ambient air.
35.1.22. "Enamel" means a coat of colored, usually opaque material that is applied as a
protective topcoat over a basecoat, primer, or previously applied enamel coats. In some
cases, another finishing material may be applied as a topcoat over the enamel.
35.1.23. "Enforceable Document" is a construction permit or operating permit issued
according to the requirements of Air Pollution Control Regulation Nos. 9, 22, or 29; an
approval issued under this regulation; or a consent agreement.
35.1.24. "Equipment leak" means emissions of VOC or VHAP from pumps, valves,
flanges, or other equipment used to transfer or apply finishing materials, adhesives, or
organic solvents.
35.1.25. "Equivalent method" means a method of sampling and analyzing for an air
pollutant that EPA has determined to have a consistent and quantitatively known
relationship to the reference method, under specific conditions.
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35.1.26. "Facility" means all pollutant-emitting activities located in a building or
buildings on one or more adjacent properties owned or operated by the same person.
35.1.27. "Filler" means a finishing material which is applied to a wood surface primarily
to build up, or fill the voids and imperfections in, the wood surface to be coated. Edge
filler is included in this definition.
35.1.28. "Finishing application station" means the part of a finishing operation where the
finishing material is applied, e.g., a spray booth.
35.1.29. "Finishing material" means a coating other than an adhesive. For the wood
products manufacturing industry, such materials include, but are not limited to, basecoats,
stains, washcoats, enamels, sealers, and topcoats.
35.1.30. "Finishing operation" means those activities in which a finishing material is
applied to a substrate and is subsequently air-dried, cured in an oven, or cured by
radiation.
35.1.31. "Foam adhesive" means a contact adhesive used for gluing foam to fabric, foam
to foam, and fabric to wood.
35.1.32. "Gluing operation" means those operations in which adhesives are used to join
components, for example to apply a laminate to a wood substrate or foam to fabric.
35.1.33. "Halogenated Organic Compound" and "HOC" means the following
compounds:
(a)
CFC-11 (trichlorofluoromethane)
(b)
CFC-12 (dichlorodifluoromethane)
(c)
CFC-113 (1,1,1-trichloro 2,2,2-trifluoroethane)
(d)
CFC-114 (1,2-dichloro 1,1,2,2-tetrafluoroethane)
(e)
CFC-115 (chloropentafluoroethane)
(f)
HCFC-22 (chlorodifluoromethane)
(g)
HCFC-123 (1,1,1-trifluoro 2,2-dichloroethane)
(h)
HCFC-124 (2-chloro 1,1,1,2-tetrafluoroethane)
(i)
HCFC-141b (1,1-dichloro 1-fluoroethane)
(j)
HCFC-142b (1-chloro 1,1-difluoroethane)
(k)
methyl chloroform (1,1,1-trichloroethane)
(l)
methylene chloride (dichloromethane)
35.1.34. "Hazardous Air Pollutant" and "HAP" means an air pollutant which has been
listed pursuant to Section 112(b) of the Clean Air Act Amendments of 1990.
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35.1.35. "High-solids stains" means stains containing more than one pound of solids per
gallon and includes wiping stains, glazes, and opaque stains.
35.1.36. "Incinerator" means an enclosed combustion device that thermally oxidizes
volatile organic compounds to CO and CO2. This term does not include devices that burn
municipal or hazardous waste material.
35.1.37. "Ink" means a fluid that contains dyes and/or colorants and is used to make
markings, but not to protect surfaces.
35.1.38. "Low-solids stains" means stains containing one pound of solids per gallon, or
less.
35.1.39. "Major source of Hazardous Air Pollutants" means a facility that emits or has
the potential to emit, in the aggregate, 10 tons per year (tpy) or more of any Hazardous
Air Pollutant (HAP), 25 tpy or more of any combination of HAPs, or such lesser quantity
as the EPA may establish by rule.
35.1.40. "Malfunction" means any sudden, infrequent, and not reasonably preventable
failure of air pollution control equipment, process equipment, or a process to operate in a
normal or usual manner. Failures that are caused in part by poor maintenance or careless
operation are not malfunctions.
35.1.41. "Multi-colored coating" means a coating which exhibits more than one color
when applied, and which is packaged in a single container and applied as a single coat.
35.1.42. "Nonpermanent final finish" means a material such as a wax, polish,
nonoxidizing oil, or similar substance that must be periodically reapplied to a surface
over its lifetime to maintain or restore the reapplied material's intended effect.
35.1.43. "Operating day" means a day, or any part of a day, in which a facility is engaged
in manufacturing.
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35.1.44. "Operating parameter value" means a minimum or maximum value established
for a control device or process parameter that, if achieved by itself or in combination with
one or more other operating parameter values, determines that an owner or operator has
complied with an applicable emission limitation.
35.1.45. "Organic solvent" means a liquid containing VOC that is used for dissolving or
dispersing constituents in a coating, adjusting the viscosity of a coating, cleaning, or
washoff. When used in a coating, the organic solvent evaporates during drying and does
not become a part of the dried film.
35.1.46. "Overall control efficiency" means the efficiency of a control system, calculated
as the product of the capture and control device efficiencies, expressed as a percentage.
35.1.47. "Permanent total enclosure" means a permanently installed enclosure that
completely surrounds a source of emissions such that all emissions are captured and
contained for discharge through a control device. The enclosure must meet applicable
EPA criteria.
35.1.48. "Person" means an individual, trust, firm, joint stock company, corporation
(including a quasi-governmental corporation), partnership, association, syndicate,
municipality, municipal or state agency, fire district, club, non-profit agency or any
subdivision, commission, department, bureau, agency or department of state or federal
government (including quasi-governmental corporation) or of any interstate body.
35.1.49. "Pigmented coating" means an opaque coating which contains binders and
colored pigments and which is formulated to hide the wood surface, either as an
undercoat or topcoat.
35.1.50. "Potential to emit" means the maximum capacity of a stationary source to emit a
pollutant under its physical and operational design. Any physical or operational
limitation on the capacity of the source to emit a pollutant, including air pollution control
equipment and restrictions on hours of operation or on the type or amount of material
combusted, stored, or processed, shall be treated as part of the design if the limitation or
the effect it would have on emissions is specified in a federally enforceable document.
35.1.51. "Reasonably Available Control Technology" and "RACT" means the lowest
emission limitation that a particular coating line is capable of meeting by using measures
that are reasonably available in terms of technological and economic feasibility. Such
measures may include either control system(s) or coating reformulation(s) or both.
35.1.52. "Recycled onsite" means the reuse of an organic solvent at the facility in a
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process other than cleaning or washoff.
35.1.53. "Sealer" means a finishing material used to seal the pores or grains of a wood
substrate before additional coats of finishing material are applied. Washcoats, which are
used in some finishing systems to optimize aesthetics, are not sealers.
35.1.54. "Shutdown" means the cessation of operation of wood products manufacturing
operations for any purpose.
35.1.55. "Solvent" means a liquid used in a coating for dissolving or dispersing
constituents in a coating, adjusting the viscosity of a coating, cleaning, or washoff. When
used in a coating, it evaporates during drying and does not become a part of the dried
film.
35.1.56. "Stain" means any color coat having a solids content by weight of not more than
8.0 percent that is applied in single or multiple coats directly to the substrate. Stains
include, but are not limited to, nongrain raising stains, equalizer stains, prestains, sap
stains, body stains, no-wipe stains, penetrating stains, and toners.
35.1.57. "Startup" means the setting in operation of wood products manufacturing
operations for any purpose.
35.1.58. "Strippable booth coating" means a coating that: (1) is applied to a booth wall
to provide a protective film to receive overspray during finishing operations; (2) is
subsequently peeled off and disposed; and (3) by achieving (1) and (2), reduces or
eliminates the need to use organic solvents to clean booth walls.
35.1.59. "Substrate" means the surface onto which coatings are applied or into which
coatings are impregnated.
35.1.60. "Thinner" means a volatile liquid that is used to dilute coatings to reduce
viscosity, color strength, and solids, or to modify drying conditions.
35.1.61. "Toner" means a stain which contains binders and dyes or pigments to add tint
to a coated surface or to even the color of an initial application of stain.
35.1.62. "Topcoat" means the last film-building finishing material applied in a finishing
system.
35.1.63. "Touch-up and repair" means the application of finishing materials to cover
minor finishing imperfections.
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35.1.64. "Volatile Hazardous Air Pollutant" and "VHAP" means any of the substances
listed in Table 1.
35.1.65. "Volatile organic compound" and "VOC" means any organic compound which
participates in atmospheric photochemical reactions. This includes any organic
compound other than the following compounds:
(a)
acetone
(b)
CFC-11 (trichlorofluoromethane)
(c)
CFC-12 (dichlorodifluoromethane)
(d)
CFC-113 (1,1,1-trichloro 2,2,2-trifluoroethane)
(e)
CFC-114 (1,2-dichloro 1,1,2,2-tetrafluoroethane)
(f)
CFC-115 (chloropentafluoroethane)
(g)
ethane
(h)
HCFC-22 (chlorodifluoromethane)
(i)
HCFC-123 (1,1,1-trifluoro 2,2-dichloroethane)
(j)
HCFC-124 (2-chloro 1,1,1,2-tetrafluoroethane)
(k)
HCFC-141b (1,1-dichloro 1-fluoroethane)
(l)
HCFC-142b (1-chloro 1,1-difluoroethane)
(m)
HFC-23 (trifluoromethane)
(n)
HFC-125 (pentafluoroethane)
(o)
HFC-134 (1,1,2,2-tetrafluoroethane)
(p)
HFC-134a (1,1,1,2-tetrafluoroethane)
(q)
HFC-143a (1,1,1-trifluoroethane)
(r)
HFC-152a (1,1-difluoroethane)
(s)
methane
(t)
methyl chloroform (1,1,1-trichloroethane)
(u)
methylene chloride (dichloromethane)
(v)
parachlorobenzotrifluoride (PCBTF)
(w)
cyclic, branched, or linear completely methylated siloxanes
(x)
The perfluorocarbon compounds which fall into these classes:
(1) Cyclic, branched, or linear, completely fluorinated alkanes;
(2) Cyclic, branched, or linear, completely fluorinated ethers with no
unsaturations;
(3) Cyclic, branched, or linear, completely fluorinated tertiary amines with
no unsaturations; and
(4) Sulfur containing perfluorocarbons with no unsaturations and with
sulfur bonds only to carbon and fluorine.
These compounds have been determined to have negligible photochemical reactivity. For
purposes of determining compliance with emission limitations, VOC will be measured by
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the approved test methods. Where such a method also inadvertently measures
compounds with negligible photochemical reactivity, as defined above, an owner or
operator may exclude these negligible photochemical reactive compounds when
determining compliance with an emissions standard.
35.1.66. "Washcoat" means a transparent special purpose coating having a solids content
by weight of 12.0 percent or less. Washcoats are applied over initial stains to protect and
control uniformity of color, to stiffen the wood fibers, to prepare the wood surface for
sanding, and to partially seal the wood from subsequent staining operations.
35.1.67. "Washoff operations" means those operations in which organic solvent is used
to remove coating from a substrate.
35.1.68. "Wood products facility" means a facility which is engaged in coating the
surface of products manufactured of wood or wood products, including, but not limited
to, particle board, reed, rattan and wicker. Wood product coating does not include
coating of flat wood panels, as defined in Air Pollution Control Regulation No. 19.
35.1.69. "Wood products manufacturing operations" means the finishing, gluing,
cleaning and washoff operations conducted at a wood products facility.
35.2
Applicability
35.2.1 The provisions of this regulation apply to any wood products facility which has
the potential to emit 25 tons per year or more of volatile organic compounds (VOC) from
wood products manufacturing operations or which is located at a major source of
Hazardous Air Pollutants (HAP).
35.2.2 The owner or operator of a wood products facility which has emissions below the
applicability thresholds specified in Subsection 35.2.1 but above 15 pounds of VOC in
any day shall comply with the recordkeeping and reporting requirements in Paragraphs (a)
and (c) of Subsection 35.7.1 but the facility shall not be subject to any other provisions of
this regulation. If the facility becomes subject to the regulation at a future date due to an
increase in emissions of VOC or VHAP, the facility shall be subject to applicable
requirements in this regulation on and after the date that the applicability thresholds are
reached or the date that the applicable requirement becomes effective, whichever is later.
35.2.3 Where ever the term Volatile Organic Compound or VOC is used in Sections
35.2 through 35.8 and Subsections 35.1.3, 35.1.7, 35.1.24, and 35.1.45, this term should
be read as Volatile Organic Compound and Halogenated Organic Compound or VOC and
HOC.
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35.2.4 The owner or operator of a facility which is a major source of Hazardous Air
Pollutants (HAP) but which has not emitted more than 10 tons of any one HAP or more
than 25 tons of any combination of HAP, including emissions from source categories
other than wood products, in any 12 month period since December 1994 may apply to the
Director for an exemption from the VHAP emissions limitations in Subsections 35.3.2,
35.3.3, 35.4.2 and 35.4.3 of this regulation. Exemption will be given in the form of an
enforceable document, and will include the following conditions:
(a) Average monthly emissions from the facility in any consecutive twelve month period
shall not exceed 1,666 pounds of any one HAP or 4,166 pounds of any combination of
HAP; and
(b) The following records shall be maintained at the facility for a period of five years and
made available to the Division or the EPA upon request:
(1) The name, identification number, and amount of each finishing, gluing and
washoff material used each month at the facility; and
(2) Certified Product Data Sheets showing the VOC and VHAP content of each
finishing, gluing, and washoff material used at the facility; and
(3) The type and amount of solvent used as thinners and in cleaning operations
each month at the facility;
(4) The average monthly emissions of each HAP from the facility, calculated
monthly for the previous twelve month period.
(c) If the limit in Paragraph 35.2.4.(a) is exceeded, applicable VHAP emission
limitations specified in Sections 35.3 and 35.4 shall immediately apply.
35.3
Emission Limitations for Finishing Operations
35.3.1 VOC Emission Limitations for Finishing Operations
(a) On and after March 7, 1996, the owner or operator of a facility subject to this
regulation which has the potential to emit greater than or equal to 25 tons per year of
volatile organic compounds (VOC) shall limit VOC emissions from wood products
finishing operations by:
(1) Using finishing materials which comply with the emissions limitations in
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pounds of VOC per gallon of coating minus water and exempt compounds listed
in Table 2; or
(2) Using a control system that achieves the emissions limitations in pounds of
VOC per pound of solids listed in Table 2; or
(3) Using finishing materials with a weighted average VOC content, within a
particular category of coatings as identified in Table 2, which conforms with the
provisions specified in Subsection 35.6.2(a); or
(4) Using a combination of the methods presented in Paragraphs 35.3.1(a)(1),
35.3.1(a)(2), and 35.3.1(a)(3) which is approved by the Division.
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Table 2. Emissions Limitations for Finishing Materials
COATING CATEGORY
lbs VOC/
gal coating
minus water
and exempt
compounds
lbs VOC/
lb solids
clear topcoats containing HOC
4.6
1.2
clear topcoats not containing HOC
5.7
2.5
fillers
4.2
1.0
high-solids stains
5.8
2.7
low-solids stains, toners and
washcoats containing HOC
4.0
0.9
low-solids stains, toners and
washcoats not containing HOC
6.7
7.5
inks
4.2
1.0
multi-colored coatings
5.7
2.5
pigmented coatings
5.0
1.6
sealers containing HOC
4.6
1.2
sealers not containing HOC
5.7
2.5
(b) In addition to complying with the limitations in Table 2, on and after March 7, 1998,
the owner or operator of a facility subject to this regulation which has the potential to
emit greater than or equal to 25 tons per year of VOC shall:
(1) Use topcoats containing no more than 1.8 lbs VOC/lb solids, as applied, and
sealers containing no more than 1.9 lbs VOC/lb solids, as applied; or
(2) Use waterborne topcoats with a VOC content no greater than 0.8 lb VOC/lb
solids, as applied; or
(3) Use a control system that achieves equivalent reductions in VOC emissions
from topcoats and sealers.
(c) A facility subject to the emissions limits in Table 2 may be required, at the discretion
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of the Division, to undergo a review every two years to determine whether the limitations
in Paragraphs (a) and (b) of this subsection represent Reasonably Available Control
Technology (RACT) for the finishing operations at that facility at that time. Facilities
shall comply with emissions limitations determined to be RACT within one year of that
determination and shall thereafter operate in compliance with those limitations.
35.3.2 VHAP Emission Limitations for Finishing Operations at Existing Facilities
(a) On and after March 7, 1998, the owner or operator of a facility subject to this
regulation which is a major source of HAP and which began operations before December
6, 1994 shall limit VHAP emissions from wood products finishing operations by:
(1) Using stains, washcoats, sealers, topcoats, basecoats, and enamels with VHAP
contents no higher than 1.0 lb VHAP/lb solids, as applied; thinners for stains,
sealers, and topcoats that contain no more than 10% VHAP by weight; and
thinners for washcoats, basecoats and enamels that contain no more than 3%
VHAP by weight; or
(2) Using finishing materials with a weighted average VHAP content of no
greater than 1.0 lb VHAP/lb solids, as applied, calculated using the procedures in
Subsection 35.6.2(b), and thinners with VHAP contents as specified in Paragraph
35.3.2(a)(1); or
(3) Using a control system that achieves a reduction in emissions equivalent to
that which would be achieved by complying with the requirements of Paragraph
(1) or (2) of this subsection, calculated according to the procedures in Subsection
35.6.3(c) of this regulation; or
(4) Using a combination of the methods presented in Paragraphs (1) and (3) of
this subsection which is approved by the Division.
(b) The formaldehyde content of a finishing material shall be calculated as the amount of
free formaldehyde present in the finishing material when it is applied.
(c) The styrene content of a finishing material shall be based on an estimate of unreacted
styrene, which shall be calculated by multiplying the amount of styrene monomer in the
finishing material when it is applied by a factor of 0.16.
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35.3.3 VHAP Emission Limitations for Finishing Operations at New Facilities
(a) On and after March 7, 1996, the owner or operator of a facility subject to this
regulation which is a major source of HAP and began operation on or after December 6,
1994 shall limit VHAP emissions from wood products finishing operations by:
(1) Using stains with VHAP contents no greater than 1.0 lb VHAP/lb solids, as
applied; washcoats, sealers, topcoats, basecoats, and enamels with VHAP contents
no greater than 0.8 lb VHAP/lb solids, as applied; thinners for stains, sealers, and
topcoats that contain no more than 10% VHAP by weight; and thinners for
washcoats, basecoats and enamels that contain no more than 3% VHAP by
weight; or
(2) Using finishing materials with a weighted average VHAP content of no
greater than 0.8 lb VHAP/lb solids, as applied, calculated using the procedures in
Subsection 35.6.2(b), and thinners with VHAP contents as specified in Paragraph
35.3.3(a)(1); or
(3) Using a control system that achieves a reduction in emissions equivalent to
that which would be achieved by complying with the requirements of Paragraph
(1) or (2) of this subsection, calculated according to the procedures in provisions
in Subsection 35.6.3(c) of this regulation; or
(4) Using a combination of the methods presented in Paragraphs (1) and (3) of
this subsection which is approved by the Division.
(b) The formaldehyde content of a finishing material shall be calculated as the amount of
free formaldehyde present in the finishing material when it is applied.
(c) The styrene content of a finishing material shall be based on an estimate of unreacted
styrene, which shall be calculated by multiplying the amount of styrene monomer in the
finishing material when it is applied by a factor of 0.16.
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35.4
Emission Limitations for Cleaning and Gluing Operations
35.4.1 VOC Emission Limitations for Cleaning Operations
On and after March 7, 1996, any strippable booth coating used at a facility subject to this
regulation must contain no more than 0.8 lb VOC/lb solids, as applied.
35.4.2 VHAP Emission Limitations for Existing Gluing Operations
On and after March 7, 1996, the owner or operator of a facility subject to this regulation
which is a major source of HAP and which began operation before December 6, 1994
shall limit VHAP emissions from contact adhesives used in gluing operations as follows:
(a) For foam adhesives used in products that meet the upholstered seating flammability
requirements of California Technical Bulletin 116, 117, or 133, the Business and
Institutional Furniture Manufacturers Association's (BIFMA's) X5.7, UFAC flammability
testing, or any similar requirements from local, State, or Federal fire regulatory agencies,
the VHAP content of the adhesive shall not exceed 1.8 lb VHAP/lb solids, as applied;
(b) For all other contact adhesives, including foam adhesives used in products that do not
meet the standards presented in Paragraph (a) of this subsection, the VHAP content of the
adhesive shall not exceed 1.0 lb VHAP/lb solids, as applied; or
(c) By using a control system that will achieve a reduction in VHAP emissions
equivalent to that which would be achieved by complying with the requirements of
Paragraph (b) of this subsection, as calculated using the procedures in Subsection
35.6.3(d) of this regulation.
35.4.3 VHAP Emission Limitations for New Gluing Operations
On and after March 7, 1996, the owner or operator of a facility subject to this regulation
which is a major source of HAP and which began operation on or after December 6, 1994
shall not use contact adhesives which have VHAP contents higher than 0.2 lb VHAP/lb
solids, as applied or shall use a control system that achieves an equivalent reduction in
emissions of VHAP, as calculated using the procedures in Subsection 35.6.3(d).
35.5
Work Practice Standards
The owner or operator of a facility subject to this regulation shall implement the
following work practice standards by March 7, 1996, except where another date is
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specified.
35.5.1 Work Practice Implementation Plan
(a) The owner or operator of a facility subject to this regulation shall prepare and
maintain a written work practice implementation plan that defines work practices for each
wood products manufacturing operation and addresses each of the topics specified in
Subsections 35.5.2 through 35.5.10.
(b) The work practice implementation plan shall be developed by May 6, 1996 and shall
be subject to the approval of the Division.
(c) The owner or operator of the facility shall comply with each provision of the work
practice implementation plan.
(d) The work practice implementation plan shall be available for inspection by the EPA
or the Division upon request and shall be modified by the facility if found to be
inadequate.
35.5.2 Operator Training Course
(a) Each owner or operator of a facility subject to this regulation shall train all new and
existing personnel, including contract personnel, who are involved in finishing, gluing,
cleaning, or washoff operations, use of manufacturing equipment, or implementation of
the requirements of this regulation.
(b) All personnel shall be trained by November 6, 1996, or upon hiring, whichever is
later. All personnel shall be given refresher training annually.
(c) Initial and refresher trainings shall include, at a minimum, the following topics:
(1) Appropriate application techniques;
(2) Appropriate cleaning and washoff procedures;
(3) Appropriate equipment setup and adjustment to minimize finishing material
usage and overspray; and
(4) Appropriate management of cleanup wastes.
(d) The facility shall maintain records of the training program. Records shall include, at
a minimum, the following:
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(1) A list of all current personnel by name and job description who are required to
be trained and a record of the date that each employee was trained;
(2) An outline of the subjects covered in the initial and refresher training for each
position, or group of personnel;
(3) Lesson plans for courses to be given at the initial and the annual refresher
training that include, at a minimum, the topics specified in Paragraph (c) of this
subsection; and
(4) A description of the methods to be used to demonstrate successful completion
of initial and refresher training.
35.5.3 Equipment Operation, Maintenance, Inspection and Repair
(a) Equipment Leak Inspection and Repair
(1) After March 6, 1996, all equipment used to transfer or apply finishing
materials, adhesives, or organic solvents shall be visually inspected for leaks at
least once per month.
(2) A first attempt at repair shall be made no later than 3 calendar days after a
leak is detected and final repairs shall be made within 10 calendar days, unless the
leaking equipment is to be replaced by a new purchase, in which case repairs shall
be completed within 3 months.
(3) Each owner or operator of a source subject to this regulation shall prepare and
maintain a written leak inspection and maintenance plan that includes:
(i) A schedule for conducting visual inspections required in Paragraph (a)
of this subsection; and
(ii) A log documenting the date and results of each inspection and any
repairs that are made.
(b) Operation and Maintenance Requirements
(1) At all times, including periods of startup, shutdown, and malfunction, owners
or operators shall operate and maintain any equipment associated with wood
products manufacturing operations, including associated air pollution control
equipment, in a manner consistent with good air pollution control practices for
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minimizing emissions.
(2) Malfunctions shall be corrected as soon as practicable after their occurrence in
accordance with the startup, shutdown, and malfunction plan required in
Paragraph (b)(4) of this subsection.
(3) The Division will determine whether acceptable operation and maintenance
procedures are being used, based on information which may include, but is not
limited to, monitoring results, review of operation and maintenance procedures
(including the startup, shutdown, and malfunction plan required in
Paragraph (b)(4) of this subsection), review of operation and maintenance records,
and inspection of the facility.
(4) The owner or operator of a facility subject to this regulation shall develop and
implement a written startup, shutdown, and malfunction plan that describes, in
detail, procedures for operating and maintaining equipment associated with wood
products manufacturing operations during periods of startup, shutdown, and
malfunction and a program of corrective action for malfunctioning process and air
pollution control equipment used to comply with this regulation. The facility's
standard operating procedures (SOP) manual, an Occupational Safety and Health
Administration (OSHA) or another plan can be used to fulfill this requirement,
provided the plan meets all the requirements of this paragraph. Startup,
shutdown, and malfunction plans shall be maintained at the facility and made
available to the Division or the EPA for review upon request and shall be revised
if determined to be unacceptable.
(5) During periods of startup, shutdown, and malfunction, the owner or operator
of a facility subject to this regulation shall operate and maintain equipment
associated with wood products manufacturing operations (including associated air
pollution control equipment) in accordance with the procedures specified in the
startup, shutdown, and malfunction plan developed according to the provisions of
Paragraph (b)(4) of this subsection.
(6) The owner or operator of a facility subject to this regulation shall keep records
of action taken during startups, shutdowns, and malfunctions, including actions
taken to correct malfunctions and shall certify, in the semi-annual reports required
in Subsection 35.7.7, that all such actions were consistent with the procedures
specified in the facility's startup, shutdown and malfunction plan developed under
Paragraph (b)(4) of this subsection
.
(7) If actions taken by the owner or operator during a startup, shutdown, or
malfunction (including an action taken to correct a malfunction) are not consistent
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with the procedures specified in the facility's startup, shutdown, and malfunction
plan, the owner or operator shall record the actions taken and report such actions
to the Division within 2 working days after beginning actions inconsistent with
the plan, followed by a letter within 7 working days after the end of the event.
(8) If a malfunction occurs that was not adequately addressed in the startup,
shutdown, and malfunction plan, the owner or operator shall revise the plan
within 45 days after the event to include detailed procedures for operating and
maintaining the source during similar malfunction events and a program of
corrective action for similar malfunctions of process or air pollution control
equipment.
35.5.4 Cleaning and Washoff Solvent Requirements
(a) The owner or operator of a facility subject to this regulation shall account for organic
solvent use in cleaning and washoff operations by recording the following information:
(1) The quantity and types of organic solvent used in washoff and cleaning
operations each month;
(2) The number of pieces washed off, and the reason for the washoff; and
(3) The quantity of spent organic solvent generated from each washoff and
cleaning activity each month, and whether it is recycled onsite or disposed offsite.
(b) Facilities subject to this regulation shall not use cleaning or washoff solvents that
contain any of the pollutants listed in Table 3 in concentrations greater than 0.1%.
35.5.5 Spray Booth Cleaning
Facilities subject to this regulation shall not use compounds containing more than
8.0 percent by weight of VOC for cleaning spray booth components other than conveyors,
continuous coaters and their enclosures, or metal filters, unless the spray booth is being
refurbished. If the spray booth is being refurbished, that is, the spray booth coating or
other material used to cover the booth is being replaced, the facility shall use no more
than 1.0 gallon of organic solvent per booth to prepare the booth prior to applying the
booth coating.
35.5.6 Storage Requirements
All finishing, gluing, cleaning, and washoff materials shall be stored in containers that are
closed at all times except when material is being added or removed.
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35.5.7 Application Equipment Requirements
Conventional air spray guns shall not be used to apply finishing materials, except in the
following situations:
(a) When applying finishing materials before March 6, 1998 at a facility which is not a
major source of HAP or which began operation prior to December 6, 1994;
(b) When applying finishing materials that have a VOC content no greater than 1.0 lb
VOC/lb solids, as applied;
(c) Touch-up or repair that occurs after the completion of a finishing operation;
(d) Touch-up or repair that occurs after the stain and before any other type of finishing
material is applied, provided that the touch-up finishing materials are applied from a
container that has a volume of no more than 2.0 gallons;
(e) If the spray gun is aimed and triggered automatically, not manually;
(f) If emissions from the finishing application station are directed to a control device;
(g) For application of a finishing material if the total usage of that finishing material is no
more than 5.0 percent of the total gallons of all finishing materials used at that facility
during that semi-annual reporting period, as specified in Subsection 35.7.7(a).; or
(h) The application of stain on a part for which it is technically or economically
infeasible to use any other spray application technology. The facility must demonstrate
technical or economic infeasibility by submitting documentation to the Division that the
following criteria, either independently or in combination, are met:
(1) The production speed is too high or the part shape is too complex for one
operator to coat the part and the application station is not large enough to
accommodate an additional operator; or
(2) The excessively large vertical spray area of the part makes it difficult to avoid
sagging or runs in the stain.
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35.5.8 Line Cleaning
All organic solvent used for line cleaning shall be pumped or drained into a container that
is closed at all times except when material is being added or removed.
35.5.9 Gun Cleaning
All organic solvent used to clean spray guns shall be collected in a container that is closed
at all times except when material is being added or removed.
35.5.10 Washoff operations
Emissions from washoff operations shall be controlled by:
(a) Using tanks for washoff that are closed at all times except when material is being
added or removed; and
(b) Minimizing dripping by tilting or rotating the part to drain as much organic solvent as
possible.
35.5.11 Formulation Assessment Plan
Each owner or operator of a facility that is subject to this regulation and that is a major
source of Hazardous Air Pollutants shall prepare and maintain a formulation assessment
plan that:
(a) Lists all VHAP from Table 1 that are being used in finishing operations at the facility.
(b) Establishes a baseline level of usage by the facility for each VHAP as follows:
(1) The baseline usage level shall be the annual usage from the calendar year
1994 for each VHAP;
(2) For formaldehyde, the baseline level of usage shall be based on the amount of
free formaldehyde present in the finishing material when it is applied;
(3) For styrene, the baseline level of usage shall be an estimate of unreacted
styrene, which shall be calculated by multiplying the amount of styrene monomer
in the finishing material when it is applied by a factor of 0.16; and
(4) Facilities using a control device to reduce emissions may adjust their baseline
usage based on the overall control efficiency of the control system, calculated
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using Equation 5 in Paragraph 35.6.3(c).
(5) The baseline levels for a VHAP that was not used in 1994 shall be established
as 20% of the Reportable Quantity for that substance specified in Table III of
Regulation No. 22.
(c) Tracks the annual usage of each VHAP used by the facility.
(d) If, beginning with the calendar year 1998, the usage of a VHAP in any year exceeds
its baseline level, then the owner or operator of the facility shall provide a written
notification to the Division by 31 January of the following year that specifies the amount
of the increase and explains the reasons for the increase. The Division will determine
whether the increase would cause an exceedance of the Acceptable Ambient Levels
specified in Air Pollution Control Regulation No. 22. If Regulation No. 22 limits are
exceeded, the Division will develop a timetable for the facility to achieve compliance and
a schedule for submitting notification of progress.
35.6 Compliance Procedures and Monitoring Requirements
35.6.1 Compliance Using Compliant Coatings
Compliance with the emissions limitations in Sections 35.3 and 35.4 of this regulation
through the use of compliant coatings shall be demonstrated by the following methods:
(a) Maintaining Certified Product Data Sheets (CPDS) documenting that the VOC and/or
VHAP content of each topcoat, filler, stain, toner, ink, multi-colored coating, pigmented
coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth
coating meets the applicable emissions limitations in Sections 35.3 and 35.4 in lb
VOC/gallon of coating or lb VHAP/lb of solids; and
(b) Maintaining formulation data and related calculations showing that the VOC and
VHAP content of each topcoat, filler, stain, toner, ink, multi-colored coating, sealer,
washcoat, enamel, basecoat, adhesive and strippable booth coating diluted onsite, as
applied, meets the applicable emissions limitations in Sections 35.3 and 35.4 in lb
VOC/gallon of coating or lb VHAP/lb of solids; and
(c) For facilities with continuous coaters, using one of the following procedures:
(1) Calculating the VOC and VHAP content, as applicable, of the finishing
material in the reservoir from information on the CPDS and records of materials
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added to the reservoir; or
(2) Monitoring the viscosity of the finishing material in the reservoir with a
viscosity meter or testing the viscosity of the initial finishing material and
retesting the material in the reservoir each time solvent is added. If this option is
chosen, the facility shall maintain data that demonstrates the correlation between
the viscosity of the finishing material and the VOC and VHAP content, as
applicable, of the finishing material; and
(d) The Division or EPA will determine compliance either by reviewing the records
specified in Paragraphs (a), (b) and (c) of this subsection or by conducting a performance
test according to the specifications in Subsections 35.8.1 and 35.8.2. If the VOC or
VHAP content of a coating determined by a performance test using the procedures
specified in Subsections 35.8.1 and 35.8.2 is greater than that indicated on a CPDS or by
the facility's formulation or viscosity data, the performance test results shall govern.
35.6.2 Compliance Using Averaging
(a) To demonstrate compliance with the VOC emission limitations in Subsection 35.3.1
for a particular coating category through the use of averaging, the owner or operator of a
facility shall, each week:
(1) Calculate the average VOC content for all coatings in that category used at the
facility using Equation 1:
n
n
Evoc= (∑ ViCi ) / ∑ Vi
Equation 1
i=I
i=I
Where:EVOC = the average VOC content of coatings in a particular coating
category, in lb VOC/gal coating, as applied;
C = the VOC content of a coating in the coating category, in lb
VOC/gal coating minus water and exempt compounds, as applied;
i = subscript denoting an individual coating;
V = the volume of coating, in gallons, as applied, of a particular
coating in the coating category used during the weekly averaging
period;
(2) Demonstrate that the value calculated for EVOC is no greater than 0.9 times the
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emission limitation, in lbs VOC/gallon coating minus water and exempt
compounds, as applied, for that coating category, as listed in Table 2.
(b) To demonstrate compliance with the VHAP emission limitations in Subsections
35.3.2 and 35.3.3 through the use of averaging, the owner or operator of a facility shall,
each month:
(1) Calculate the average VHAP content for all finishing materials used at the
facility using Equation 2:
n
n n
EVHAP = ( ∑ MiC1 + ∑ SiWi ) / ∑ Mi
Equation 2
i=1
i=1 i=1
Where:EVHAP = the average VHAP content of finishing materials, in lb VHAP/lb
solids;
C = the VHAP content of a coating, in lb VHAP/lb solids, as
applied;
i = subscript denoting an individual coating;
M = the mass of solids, in pounds, in a particular finishing
material used during the monthly averaging period;
S = the VHAP content of a solvent, expressed as a weight
fraction, added to finishing materials; and
W = the amount of solvent, in pounds, added to finishing
materials during the monthly averaging period.
(2) Demonstrate that the value calculated for EVHAP is no greater than 1.0 if the
facility is complying with Subsection 35.3.2 and is no greater than 0.8 if the
facility is complying with Subsection 35.3.3.
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35.6.3 Initial Compliance Using Control Equipment
(a) The owner or operator of a facility which uses control equipment to comply with the
VOC emission limitations in Table 2 or the VHAP limitations in Subsections 35.3.3
and/or 35.4.3 shall conduct an initial performance test to measure the capture and control
efficiency of the control system using the procedures specified in Subsection 35.8.3 by
June 4, 1996. Initial performance tests for control equipment which is being used to
comply with the VHAP emission limitations in Subsections 35.3.2 and/or 35.4.2 or the
VOC emissions limitations for sealers and clear topcoats in Paragraph 35.3.1(b) shall be
conducted by September 8, 1998.
(b) Initial compliance with VOC emission limitations for finishing materials through the
use of a control system shall be determined as follows:
(1) Calculate the overall control efficiency needed (Rn) for each finishing material
which will be controlled by the control equipment using the following equation:
Rn = [(C - EL)/C](100)
Equation 3
Where:Rn = the overall efficiency of the control system needed, expressed as a
percentage.
C = the VOC content of a coating, in lb VOC/lb solids, as applied;
EL = the emission limitation required for the coating, from Table
2, in lb VOC/lb solids.
(2) Document that the value of C used in Equation 3 was calculated from the
VOC and solids content of the as-applied finishing material.
(3) Demonstrate, for all applicable coatings, that the value of Rn calculated using
Equation 3 is less than or equal to the actual overall control efficiency (Ra)
calculated by substituting the capture efficiency (N) and control efficiency (F) of
the control system measured in the initial performance test into Equation 4.
Ra = (F x N)(100)
Equation 4
(c) Initial compliance with VHAP emission limitations for finishing materials through
the use of a control system shall be determined as follows:
(1) Calculate the overall control efficiency needed, Rn, so that the value of Eac in
Equation 5 is no greater than 1.0 if complying with Subsection 35.3.2 and so that
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the value of Eac in Equation 5 is no greater than 0.8 if complying with Subsection
35.3.3;
Rn = (100)(Ebc - Eac)/Ebc
Equation 5
Where:Rn = the overall efficiency of the control system needed, expressed as
a percentage;
Eac = emissions from an emission point or a set of emission points
after control equipment is in operation, in lb VHAP/lb solids; and
Ebc = emissions from an emission point or set of emission points
before controls, calculated as EVHAP in Equation 2.
(2) Demonstrate that the value of Rn calculated using Equation 5 is less than or
equal to the actual overall control efficiency (Ra) calculated using the capture
efficiency (N) and control efficiency (F) of the control system measured in the
initial performance test and Equation 4.
(d) Initial compliance with VHAP emission limitations for gluing materials through the
use of a control system shall be determined as follows:
(1) Calculate the overall control efficiency of the control system needed (Rn) so
that the value of Gac in Equation 6 is no greater than 1.0 if complying with
Subsection 35.4.2 and 0.2 if complying with Subsection 35.4.3;
Rn = (100)(Gbc - Gac)/Gbc)
Equation 6
Where:Rn = the overall efficiency of the control system needed, expressed as
a percentage;
Gac = emissions from the gluing operation after control equipment,
in lb VHAP/lb solids; and
Gbc = emissions from the gluing operation before controls, in lb
VHAP/lb solids.
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(2) Demonstrate that the value of Rn calculated using Equation 6 is less than or
equal to the actual overall control efficiency (Ra) calculated using the capture
efficiency (N) and control efficiency (F) of the control system measured in the
initial performance test and Equation 4.
35.6.4 Continuous Compliance Using Control Equipment
(a) The owners or operator of a facility that is complying with the emission limitations in
this regulation through the use of a control system shall demonstrate continuous
compliance by installing, calibrating, maintaining, and operating appropriate monitoring
equipment according to manufacturers' specifications.
(b) The monitoring equipment installed pursuant to Paragraph (a) of this subsection shall
measure operating parameters which indicate ongoing compliance with the control
efficiency requirements in this regulation.
(c) Where a thermal incinerator is used, the operating parameter to be monitored shall be
minimum combustion temperature, and a temperature monitoring device equipped with a
continuous recorder shall be installed in the firebox or in the ductwork immediately
downstream of the firebox in a position before any substantial heat exchange occurs.
(d) Where a catalytic incinerator equipped with a fixed catalyst bed is used, the operating
parameter to be monitored shall be the minimum gas temperature upstream and
downstream of the catalyst bed and temperature monitoring devices equipped with
continuous recorders shall be installed in the gas stream immediately before and after the
catalyst bed.
(e) Where a catalytic incinerator equipped with a fluidized catalyst bed is used, the
operating parameters to be monitored shall be the minimum gas temperature upstream of
the catalyst bed and the pressure drop across the catalyst bed, and temperature monitoring
devices equipped with continuous recorders shall be installed in the gas stream
immediately before the bed. In addition, a pressure monitoring device shall be installed
to determine the pressure drop across the catalyst bed. A constant pressure drop, as
measured monthly at a constant flow rate, shall be maintained.
(f) Where a carbon adsorber is used, the operating parameters to be monitored shall be
either the total regeneration mass stream flow for each regeneration cycle and the carbon
bed temperature after each regeneration, or the concentration level of organic compounds
exiting the adsorber, unless the owner or operator requests and receives approval from the
Division and the EPA to establish other operating parameters. One of the following
devices is required to monitor these parameters:
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(1) An integrating regeneration stream flow monitoring device having an
accuracy of +10 percent, capable of recording the total regeneration stream mass
flow for each regeneration cycle; and a carbon bed temperature monitoring device
having an accuracy of +1 percent of the temperature being monitored expressed in
degrees Celsius or +0.5o C, whichever is greater, capable of recording the carbon
bed temperature after each regeneration and within 15 minutes of completing any
cooling cycle;
(2) An organic monitoring device, equipped with a continuous recorder, to
indicate the concentration level of organic compounds exiting the carbon
adsorber; or
(3) Another monitoring device that has been approved by the Division and the
EPA.
(g) A facility using a control device not listed in this section to comply with this
regulation shall submit to the Division a description of the device, test data verifying the
performance of the device, and appropriate operating parameter values that will be
monitored to demonstrate continuous compliance with the standard. Compliance using
this device is subject to the approval of the Division and the EPA.
(h) Operating parameter values indicating compliance shall be calculated as the
arithmetic average of the maximum or minimum value of those parameters, as
appropriate, measured during the three test runs of the initial performance test, provided
that the initial performance test demonstrated compliance.
(i) The capture or control device shall be operated so that the average of all values for a
monitored parameter recorded during each operating day is in compliance with the
operating parameter value calculated according to the procedures in Paragraph (h) of this
subsection.
35.7 Recordkeeping and Reporting
35.7.1 The owner or operator of a facility subject to this regulation shall maintain the
following records for a period of five years:
(a) A certified product data sheet (CPDS) for each finishing material, thinner, adhesive,
and strippable booth coating subject to the emission limitations in this regulation;
(b) As applicable, the VOC content in lb VOC/gallon of coating, as applied and the
VHAP content, in lb VHAP/lb of solids, as applied, of each coating subject to the
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emission limitations in this regulation, and copies of calculations documenting how the
as-applied values were determined. The VOC content of strippable booth coatings shall
be expressed in units of lb VOC/lb solids, as applied.
(c) The amount and type of each coating and thinner used at the facility each month.
(d) If viscosity measurements are used to track VOC and/or VHAP concentrations:
(1) Records of dates and amounts of solvent and finishing material added to the
continuous coater reservoir;
(2) Records of dates and results of viscosity measurements; and
(3) Data demonstrating that viscosity is an appropriate parameter for
demonstrating compliance.
35.7.2 The owner or operator of a facility using weekly averaging to comply with the
VOC emissions limitations in Subsection 35.3.1 or monthly averaging to comply with the
VHAP emissions limitations in Subsection 35.3.2 or 35.2.3 shall maintain the
calculations of EVOC and EVHAP required in Subsection 35.6.2 for a period of 5 years.
35.7.3 The owner or operator of a source using control equipment to comply with the
emissions limitations in this regulation shall maintain the following records for a period
of five years:
(a) Copies of calculations of EVHAP from Equation 2 and Rn from Equation 3, 5 and 6, as
applicable;
(b) Records of the daily average value of each continuously monitored operating
parameter for each operating day. If all recorded values for a monitored parameter during
an operating day are within the range established during the initial performance test, the
owner or operator may record that all values were within the range rather than calculating
and recording an average for that day; and
(c) Records of the pressure drop across the catalyst bed for facilities complying with the
emission limitations using a catalytic incinerator with a fluidized catalyst bed.
35.7.4 The owner or operator of a facility subject to this regulation shall maintain onsite
the work practice implementation plan and for five years shall maintain onsite all records
associated with fulfilling the requirements of that plan, as specified in Section 35.5,
including, but not limited to:
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(a) Records demonstrating that the operator training program is in place;
(b) Records maintained in accordance with the equipment leak inspection and
maintenance plan and startup, shutdown, and malfunction plan;
(c) Records associated with the cleaning solvent accounting system;
(d) Records associated with the limitation on the use of conventional air spray guns
showing total finishing material usage and the percentage of finishing materials applied
with conventional air spray guns for each reporting period;
(e) Records associated with the formulation assessment plan;
(f) Records showing the VOC content of compounds used for cleaning booth
components, except for solvent used to clean conveyors, continuous coaters and their
enclosures, and/or metal filters;
(g) A copy of logs and other documentation developed to demonstrate that the provisions
of the work practice implementation plan are followed; and
(h) A copy of the compliance certifications, and periodic reports submitted in accordance
with the requirements of this regulation.
35.7.5 Initial Notifications
(a) The owner or operator of a facility subject to this regulation which was constructed
before December 7, 1995 and which is a major source of HAP shall submit a Initial
Notification to the Division by September 2, 1996 or within 30 days of becoming a major
source of HAP, whichever is later. Initial Notifications for facilities constructed before
December 7, 1995 shall include the following information:
(1) The name and address of the owner or operator;
(2) The address (i.e., physical location) of the facility;
(3) An identification of the relevant standard, or other requirement, that is the
basis of the notification and the facility's compliance date;
(4) A brief description of the nature, size, design, and method of operation of the
facility, including its operating design capacity and an identification of each point
of emission for each HAP, or, if a definitive identification is not yet possible, a
preliminary identification of each point of emission for each HAP;
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(5) An estimate of the amount of each HAP used and emitted annually from the
facility; and
(6) The number of hours per day and days per week that the facility operates.
(b) The owner or operator of a facility subject to this regulation which was constructed or
reconstructed on or after December 7, 1995 and which is a major source of HAP shall
submit an Initial Notification in conjunction with its construction permit application. A
facility constructed or reconstructed on or after December 7, 1995 which subsequently
becomes a major source of HAP shall submit an Initial Notification within 30 days of
becoming a major source of HAP. Initial Notifications for facilities constructed on or
after December 7, 1995 shall include the following information:
(1) The date when construction or reconstruction began or is scheduled to begin;
(2) The anticipated date of startup of the source; and
(3) The information listed in paragraphs (a)(1) through (a)(6) of this subsection.
(c) A facility subject to this regulation which was constructed or reconstructed after
December 7, 1995 shall notify the Division of the actual date of startup of the facility by
April 6, 1996 or within 15 calendar days after the startup date, whichever is later.
35.7.6 Initial Compliance Certification
(a) The owner or operator of a facility subject to the VHAP emission limitations in this
regulation shall submit an Initial Compliance Certification for VHAP to the Division.
Initial Compliance Certifications for VHAP for facilities which began operation on or
after December 6, 1994 shall be submitted by May 6, 1996 or 60 days after beginning
operation, whichever is later. Initial Compliance Certifications for VHAP for facilities
which began operation before December 6, 1994 shall be submitted by May 6, 1998. The
owner or operator of a facility that, due to an increase in emissions, becomes a major
source of HAP after the effective date of the regulation, shall submit an Initial
Compliance Certification to the Division no more than 60 days after becoming a major
source of HAP.
(b) The owner or operator of a facility subject to the VOC emission limitations in this
regulation shall submit an Initial Compliance Certification for VOC to the Division.
Initial Compliance Certifications for VOC shall be submitted by May 6, 1998.
(c) Initial Compliance Certifications shall include the following information:
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(1) For a facility that is complying with emission limitations through the use of
compliant materials, Initial Compliance Certifications shall state that each
topcoat, filler, stain, toner, ink, multi-colored coating, pigmented coating, sealer,
washcoat, enamel, basecoat, thinner, adhesive and strippable booth coating is in
compliance with applicable emissions limitations in this regulation and identify
the method used to determine compliance.
(2) For a facility monitoring viscosity to demonstrate compliance with emission
limitations, the initial compliance report shall state that viscosity is an appropriate
parameter for demonstrating compliance, that viscosity is being measured in
accordance with the specifications in Paragraph 35.6.1(b)(2) and that viscosity
measurements demonstrate that the VHAP and VOC content of the material in the
coaters is in compliance with applicable emission limitations.
(3) For a facility using weekly averaging to comply with the VOC emission
limitations in Subsection 35.3.1 or monthly averaging to comply with the VHAP
emission limitations in Subsection 35.3.2 or 35.2.3, the Initial Compliance
Certification shall state that EVOC and EVHAP, as calculated using Equation 1 and
Equation 2, respectively, are no greater than the applicable emission limitations
specified in Subsection 35.6.2.
(4) For a facility using a control system to comply with the emission limitations
in this regulation, the Initial Compliance Certification shall identify each control
device installed, including the identification number, permit number, installation
date and equipment controlled. In addition, the following information must be
submitted no more than 60 days after completing the initial performance test of
the control system:
(i) The results of the initial performance test of the control system;
(ii) The overall control efficiency needed (Rn), calculated using Equation
3 for VOC emissions from finishing operations, Equation 5 for VHAP
emissions from finishing operations, and Equation 6 for VHAP emissions
from gluing operations, as applicable;
(iii) The actual overall control efficiency (Ra) calculated using the results
of the initial performance test and Equation 4; and
(iv) A plan for monitoring operating parameters which identifies the
operating parameter values which indicate ongoing compliance, calculated
as specified in Paragraph 35.6.4(h), discusses why those parameters are
35-33
appropriate indicators of compliance, and specifies the frequency that
those parameters will be monitored.
(5) Initial Compliance Certifications shall state that a work practice
implementation plan has been developed and procedures have been established for
implementing the provisions of that plan.
(6) Initial Compliance Certifications shall be signed by a responsible official of
the company that owns or operates the facility.
35.7.7 Periodic Reports
The owner or operator of a facility subject to this regulation shall submit periodic reports
to the Division according to the following specifications:
(a) Periodic reports shall be submitted semi-annually by 1 February of each year for the
reporting period of 1 July through 31 December of the previous year and by 1 September
for the reporting period of January 1 through June 30, which include the following:
(1) The amount and type of VOC and VHAP in each coating used at the facility
during the reporting period,
(2) A compliance certification, as specified in Paragraphs (b) through (g) of this
subsection, and
(3) Documentation of progress made during the reporting period toward reducing
the VOC and VHAP content of coatings used at the facility.
(b) If the facility is using compliant coatings to comply with the emission limitations in
Sections 35.3 and 35.4 of this regulation, periodic reports shall state that the VOC and
VHAP content of each topcoat, filler, stain, toner, ink, multi-colored coating, pigmented
coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth
coating used each day at the facility was in compliance with applicable limitations in
those sections throughout the reporting period, or should identify periods of
noncompliance and the reasons for noncompliance.
(c) If the facility uses viscosity to monitor compliance, the periodic report shall state that
the viscosity of the finishing material in the reservoir was monitored according to the
specifications in Paragraph 35.6.1(b)(2) and that those measurements demonstrated
compliance with applicable emission limitations throughout the reporting period, or
should identify the days of noncompliance and the reasons for noncompliance.
35-34
(d) If the facility is complying with the VOC emissions limitations in Section 35.3 using
averaging, the periodic report shall include the results of the VOC averaging calculation
(Equation 1) for each week in the reporting period and shall certify that the facility was in
compliance with the applicable emission limitations in all weeks during that period, or
identify the weeks that these limitations were exceeded and give reasons for those
exceedances.
(e) If the facility is complying with the VHAP emissions limitations in Section 35.3
using averaging, the periodic report shall include the results of the VHAP averaging
calculation (Equation 2) for each month in the reporting period and shall certify that the
facility was in compliance with the applicable emission limitations in all months during
that period, or identify the months that these limitations were exceeded and give reasons
for those exceedances.
(f) If the facility is complying with the emission limitations in this regulation using a
control system, the periodic report shall state that the daily average value of each
continuously monitored operating parameter was within the acceptable range on each
operating day, or identify the days of noncompliance and the reasons for the
noncompliance.
(g) Periodic reports shall include a statement certifying that the work practice
implementation plan and startup, shutdown, and malfunction plan were followed
throughout the reporting period, or otherwise identify the periods of noncompliance with
the work practice standards.
(h) The periodic report shall be signed by a responsible official of the company that owns
or operates the facility.
(i) If an exceedance occurs, periodic reports must be submitted quarterly until a request
to reduce the reporting frequency has been approved. Submittal frequencies may be
reduced to semi-annual provided that the following conditions have been satisfied:
(1) The facility has demonstrated a full year of compliance without an
exceedance; and
(2) The owner or operator of the facility continues to comply with the
recordkeeping and monitoring requirements specified in this regulation.
35-35
35.8 Performance Test Methods
35.8.1 VOC and Solids Content
(a) VOC and solids content, by weight, of coatings shall be demonstrated with
EPA Method 24 or an alternative procedure approved by EPA and the Division.
Sampling procedures shall follow the guidelines presented in "Standard Procedures for
Collection of Coating and Ink Samples for VOC Content Analysis by Reference Method
24 and Reference Method 24A," EPA-340/1-91-010.
(b) The owner or operator of a facility that uses a finishing material that does not release
VOC reaction byproducts during the cure; for example, if all VOC is solvent; may request
permission to use batch formulation information to demonstrate compliance. If the VOC
content of a coating determined by an EPA Method 24 test is greater than that indicated
by the facility's formulation data, the EPA Method 24 test shall govern.
35.8.2 VHAP and Solids Content
(a) EPA Method 311 of Part 63, Appendix A, or an alternative method, if approved by
EPA and the Division, shall be used in conjunction with formulation data to determine
the VHAP content of the liquid coating. Formulation data shall be used to identify
VHAP present in the coating, and Method 311 or an approved alternative method shall be
used to quantify the VHAP identified through the formulation data. EPA method 311
shall not be used to quantify VHAP such as styrene and formaldehyde that are emitted
during the cure.
(b) EPA Method 24 (40 CFR part 60) shall be used to determine the solids content by
weight and the density of coatings for the purpose of showing compliance with VHAP
emission limitations.
(c) The owner or operator of a facility that uses a finishing material that does not release
VOC or VHAP byproducts during the cure; for example, if all VOC and VHAP present in
the coating is solvent; may request permission to use batch formulation information to
demonstrate compliance.
(d) If the VOC content of a coating as determined by EPA Method 24/311 test is higher
than that indicated by a facility's formulation data, the EPA Method 24/311 test shall
govern, unless the facility can demonstrate to the satisfaction of the Division that
formulation data are correct.
(e) Sampling procedures shall follow the guidelines presented in "Standard Procedures
for Collection of Coating and Ink Samples for VOC Content Analysis by Reference
35-36
Method 24 and Reference Method 24A," EPA-340/1-91-010.
35.8.3 Control Equipment Efficiency
(a) EPA Method 18, 25, or 25A shall be used to determine the VOC concentration of
gaseous air streams. EPA Method 18 shall be used to determine the VHAP concentration
of gaseous air streams. The test shall consist of three separate runs, each lasting a
minimum of 30 minutes.
(b) EPA Method 1 or 1A shall be used for sample and velocity traverses.
(c) EPA Method 2, 2A, 2C, or 2D shall be used to measure velocity and volumetric flow
rates.
(d) EPA Method 3 shall be used to analyze exhaust gases.
(e) EPA Method 4 shall be used to measure the moisture content of stack gas when
required.
(f) EPA Methods 2, 2A, 2C, 2D, 3, and 4 shall be performed, as applicable, at least
twice during each test run.
(g) VOC and VHAP control systems must be constructed so that volumetric flow rates
and VOC and/or total VHAP concentrations, as applicable, can be determined by the test
methods specified in Paragraphs (a) through (f) of this subsection, as applicable.
(h) Capture efficiency shall be measured using measures approved by the EPA.
(i) Testing shall be performed while all affected emission points are connected and
operating at maximum production rate.
(j) The efficiency (F) of the control device shall be determined using Equation 7:
n p
Σ Qbi Cbi - Σ Qaj Caj
i=I j=I
F = ___________________________________ Equation 7
N
Σ Qbi Cbi
35-37
where:
F = control device efficiency, expressed as a fraction.
Cbi = the concentration of VOC or VHAP, as applicable, in gas stream (i)
entering the emission control device, in parts per million by volume.
Caj = the concentration of VOC or VHAP, as applicable, in gas stream (j)
exiting the emission control device, in parts per million by volume.
Qaj = the volumetric flow rate of gas stream (j) exiting the emission
control device, in dry standard cubic meters per hour.
Qbi = the volumetric flow rate of gas stream (i) entering the emission
control device, in dry standard cubic meters per hour.
(k) Determine the efficiency (N) of the capture system using Equation 8:
where: N = the capture system efficiency, expressed as a fraction.
Cdi = the concentration of VOC or VHAP, as applicable, in gas stream (i)
entering the emission control device from the affected emission point(s),
in parts per million by volume.
Cfk = the concentration of VOC or VHAP, as applicable, in each
uncontrolled gas stream (k) emitted directly to the atmosphere from the
affected emission point(s), in parts per million by volume.
Qdi = the volumetric flow rate of gas stream (i) entering the emission
n
Σ Qdi Cdi
N = _______________________________ Equation 8
n P
Σ Qdi Cdi + Σ Qfk Cfk
35-38
control device from the affected emission point(s), in dry standard cubic
meters per hour.
Qfk = the volumetric flow rate of each uncontrolled gas stream (k) emitted
directly to the atmosphere from the affected emission point(s), in dry
standard cubic meters per hour.
(l) If all effected emissions points are surrounded by a permanent enclosure that is
demonstrated to be total by procedures acceptable to the Division and the EPA, the
control device capture efficiency, N, is equal to 1.
35-39
TABLE 1. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
Chemical name
CAS No.
Acetaldehyde
75070
Acetamide
60355
Acetonitrile
75058
Acetophenone
98862
2-Acetylaminofluorine
53963
Acrolein
107028
Acrylamide
79061
Acrylic acid
79107
Acrylonitrile
107131
Allyl chloride
107051
4-Aminobiphenyl
92671
Aniline
62533
o-Anisidine
90040
Benzene
71432
Benzidine
92875
Benzotrichloride
98077
Benzyl chloride
100447
Biphenyl
92524
Bis(2-ethylhexyl)phthalate (DEHP)
117817
Bis(chloromethyl)ether
542881
Bromoform
75252
1,3-Butadiene
106990
Caprolactam
105602
Carbon disulfide
75150
Carbon tetrachloride
56235
Carbonyl sulfide
463581
Catechol
120809
Chloroacetic acid
79118
2-Chloroacetophenone
532274
Chlorobenzene
108907
Chloroform
67663
Chloromethyl methyl ether
107302
Chloroprene
126998
Cresols (isomers and mixture)
1319773
o-Cresol
95487
m-Cresol
108394
p-Cresol
106445
Cumene
98828
2,4-D (2,4-Dichlorophenoxyacetic acid, including
salts and esters)
94757
DDE (1,1-Dichloro-2,2-bis(p-chlorophenyl)ethylene)
72559
Diazomethane
334883
Dibenzofuran
132649
1,2-Dibromo-3-chloropropane
96128
Dibutylphthalate
84742
1,4-Dichlorobenzene
106467
3,3'-Dichlorobenzidine
91941
Dichloroethyl ether (Bis(2-chloroethyl)ether)
111444
Table 1 (continued)
35-40
Chemical name
CAS No.
1,3-Dichloropropene
542756
Diethanolamine
111422
N,N-Dimethylaniline
Diethyl sulfate
121697
64675
3,3'-Dimethoxybenzidine
119904
4-Dimethylaminoazobenzene
60117
3,3'-Dimethylbenzidine
119937
Dimethylcarbamoyl chloride
79447
N,N-Dimethylformamide
68122
1,1-Dimethylhydrazine
57147
Dimethyl phthalate
131113
Dimethyl sulfate
77781
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
51285
2,4-Dinitrotoluene
121142
1,4-Dioxane (1,4-Diethyleneoxide)
123911
1,2-Diphenylhydrazine
122667
Epichlorohydrin (1-Chloro-2,3-epoxypropane)
106898
1,2-Epoxybutane
106887
Ethyl acrylate
140885
Ethylbenzene
100414
Ethyl carbamate (Urethane)
51796
Ethyl chloride (Chloroethane)
75003
Ethylene dibromide (Dibromoethane)
106934
Ethylene dichloride (1,2-Dichloroethane)
107062
Ethylene glycol
107211
Ethylene oxide
75218
Ethylenethiourea
96457
Ethylidene dichloride (1,1-Dichloroethane)
75343
Formaldehyde
50000
Glycol ethers
0
Hexachlorobenzene
118741
Hexachloro-1,3-butadiene
87683
Hexachloroethane
67721
Hexamethylene-1,6-diisocyanate
822060
Hexamethylphosphoramide
680319
Hexane
110543
Hydrazine
302012
Hydroquinone
123319
Isophorone
78591
Maleic anhydride
108316
Methanol
67561
Methyl bromide (Bromomethane)
74839
Methyl chloride (Chloromethane)
74873
Methyl chloroform (1,1,1-Trichloroethane)
71556
Methyl ethyl ketone (2-Butanone)
78933
Methylhydrazine
60344
Methyl iodide (Iodomethane)
74884
Table 1 (continued)
35-41
Chemical name
CAS No.
Methyl isobutyl ketone (Hexone)
108101
Methyl isocyanate
624839
Methyl methacrylate
80626
Methyl tert-butyl ether
1634044
4,4'-Methylenebis(2-chloroaniline)
101144
Methylene chloride (Dichloromethane)
75092
4,4'-Methylenediphenyl diisocyanate (MDI)
101688
4,4'-Methylenedianiline
101779
Naphthalene
91203
Nitrobenzene
98953
4-Nitrobiphenyl
92933
4-Nitrophenol
100027
2-Nitropropane
79469
N-Nitroso-N-methylurea
684935
N-Nitrosodimethylamine
62759
N-Nitrosomorpholine
59892
Phenol
108952
p-Phenylenediamine
106503
Phosgene
75445
Phthalic anhydride
85449
Polychlorinated biphenyls (Aroclors)
1336363
Polycyclic Organic Matterb
0
1,3-Propane sultone
1120714
beta-Propiolactone
57578
Propionaldehyde
123386
Propoxur (Baygon)
114261
Propylene dichloride (1,2-Dichloropropane)
78875
Propylene oxide
75569
1,2-Propylenimine (2-Methyl aziridine)
75558
Quinone
106514
Styrene
100425
Styrene oxide
96093
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1746016
1,1,2,2-Tetrachloroethane
79345
Tetrachloroethylene (Perchloroethylene)
127184
Toluene
108883
2,4-Toluenediamine
95807
Toluene-2,4-diisocyanate
584849
o-Toluidine
95534
1,2,4-Trichlorobenzene
120821
1,1,2-Trichloroethane
79005
Trichloroethylene
79016
2,4,5-Trichlorophenol
95954
2,4,6-Trichlorophenol
88062
Triethylamine
121448
Trifluralin
1582098
2,2,4-Trimethylpentane
540841
Vinyl acetate
108054
Vinyl bromide
593602
Table 1 (continued)
35-42
Chemical name
CAS No.
Vinyl chloride
75014
Vinylidene chloride (1,1-Dichloroethylene)
75354
Xylenes (isomers and mixture)
1330207
o-Xylene
m-Xylene
95476
108383
p-Xylene
106423
aIncludes mono- and di-ethers of ethylene glycol, diethylene glycols and
triethylene glycol; R-(OCH2CH2)RR-OR where:
n = 1, 2, or 3,
R = alkyl or aryl groups
R'= R, H, or groups which, when removed, yield glycol ethers with
the structure: R-(OCH2CH2)n - OH. Polymers are excluded from
the glycol category.
bIncludes organic compounds with more than one benzene ring, and which
have a boiling point greater than or equal to 100°C.
35-43
TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF SOLVENTS1
1Solvents containing these pollutants in concentrations less than or equal to 0.1% may be used.
Chemical Name
CAS No.
4-Aminobiphenyl
92671
Styrene oxide
96093
Diethyl sulfate
64675
N-Nitrosomorpholine
59892
Dimethyl formamide
68122
Hexamethylphosphoramide
680319
Acetamide
60355
4,4'-Methylenedianiline
101779
o-Anisidine
90040
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1746016
Beryllium salts
-
Benzidine
92875
N-Nitroso-N-methylurea
684935
Bis(chloromethyl)ether
542881
Dimethyl carbamoyl chloride
79447
Chromium compounds (hexavalent)
-
1,2-Propylenimine (2-Methyl aziridine)
75558
Arsenic and inorganic arsenic compounds
99999904
Hydrazine
302012
1,1-Dimethyl hydrazine
57147
Beryllium compounds
7440417
1,2-Dibromo-3-chloropropane
96128
N-Nitrosodimethylamine
62759
Cadmium compounds
-
Benzo (a) pyrene
50328
Polychlorinated biphenyls (Aroclors)
1336363
Heptachlor
76448
3,3'-Dimethyl benzidine
119937
Nickel subsulfide
12035722
Acrylamide
79061
Hexachlorobenzene
118741
Chlordane
57749
1,3-Propane sultone
1120714
1,3-Butadiene
106990
Nickel refinery dust
-
2-Acetylaminoflourine
53963
3,3'-Dichlorobenzidine
53963
Lindane (hexachlorcyclohexane, gamma)
58899
2,4-Toluene diamine
95807
Dichloroethyl ether (Bis(2-chloroethyl)ether)
111444
1,2 - Diphenylhydrazine
122667
Toxaphene (chlorinated camphene)
8001352
2,4-Dinitrotoluene
121142
3,3'-Dimethoxybenzidine
119904
Formaldehyde
50000
35-44
Chemical Name
CAS No.
4,4'-Methylene bis(2-chloroaniline)
Acrylonitrile
101144
107131
Ethylene dibromide(1,2-Dibromoethane)
106934
DDE (1,1-p-chlorophenyl 1-2 dichloroethylene)
72559
Chlorobenzilate
510156
Dichlorvos
62737
Vinyl chloride
75014
Coke Oven Emissions
99999908
Ethylene oxide
75218
Ethylene thiourea
96457
Vinyl bromide (bromoethene)
593602
Selenium sulfide (mono and di)
7488564
Chloroform
67663
Pentachlorophenol
87865
Ethyl carbamate (Urethane)
51796
Ethylene dichloride (1,2-Dichloroethane)
107062
Propylene dichloride (1,2-Dichloropropane)
78875
Carbon tetrachloride
56235
Benzene
71432
Methyl hydrazine
60344
Ethyl acrylate
140885
Propylene oxide
75569
Aniline
62533
1,4-Dichlorobenzene(p)
106467
2,4,6-Trichlorophenol
88062
Bis(2-ethylhexyl)phthalate (DEHP)
117817
o-Toluidine
95534
Propoxur
114261
Trichloroethylene
79016
1,4-Dioxane (1,4-Diethyleneoxide)
123911
Acetaldehyde
75070
Bromoform
75252
Captan
133062
Epichlorohydrin
106898
Methylene chloride (Dichloromethane)
75092
Tetrachloroethylene (Perchloroethylene)
127184
Dibenz (ah) anthracene
53703
Chrysene
218019
Dimethyl aminoazobenzene
60117
Benzo (a) anthracene
56553
Benzo (b) fluoranthene
205992
Antimony trioxide
1309644
2-Nitropropane
79469
1,3-Dichloropropene
542756
7, 12-Dimethylbenz(a)anthracene
57976
Benz(c)acridine
225514
Indeno(1,2,3-cd)pyrene
193395
1,2:7,8-Dibenzopyrene
189559