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 Amendment, 01/09/2017 to 01/13/2019)

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES AIR POLLUTION CONTROL REGULATION NO. 35 CONTROL OF VOLATILE ORGANIC COMPOUNDS AND VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCT MANUFACTURING OPERATIONS Effective 7 March 1996 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. RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES AIR POLLUTION CONTROL REGULATION NO. 35 CONTROL OF VOLATILE ORGANIC COMPOUNDS AND VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING OPERATIONS 35.1 Definitions .............................................................................................................................1 35.2 Applicability ..........................................................................................................................6 35.3 Emission Limitations for Finishing Operations .........................................................................8 Table 2. Emissions Limitations for Finishing Materials ........................................................9 35.4 Emission Limitations for Cleaning and Gluing Operations ......................................................11 35.5 Work Practice Standards .......................................................................................................12 35.6 Compliance Procedures and Monitoring Requirements ...........................................................19 35.7 Recordkeeping and Reporting ................................................................................................25 35.8 Performance Test Methods ....................................................................................................32 35.9 General Provisions ................................................................................................................35 TABLE 1. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS ............................................37 TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF SOLVENTS .................................................................................................................42 Page 1 of 44 RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR RESOURCES AIR POLLUTION CONTROL REGULATION NO. 35 CONTROL OF VOLATILE ORGANIC COMPOUNDS AND VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING OPERATIONS 35.1 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: 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 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. 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 Page 2 of 44 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. 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. Page 3 of 44 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 "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. 35.1.24 "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. 35.1.25 "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. 35.1.26 "Finishing application station" means the part of a finishing operation where the finishing material is applied, e.g., a spray booth. 35.1.27 "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. 35.1.28 "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. 35.1.29 "Foam adhesive" means a contact adhesive used for gluing foam to fabric, foam to foam, and fabric to wood. 35.1.30 "Gluing operation" means those operations in which adhesives are used Page 4 of 44 to join components, for example to apply a laminate to a wood substrate or foam to fabric. 35.1.31 "High-solids stains" means stains containing more than one pound of solids per gallon and includes wiping stains, glazes, and opaque stains. 35.1.32 "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. 35.1.33 "Ink" means a fluid that contains dyes and/or colorants and is used to make markings, but not to protect surfaces. 35.1.34 "Low-solids stains" means stains containing one pound of solids per gallon, or less. 35.1.35 "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. 35.1.36 "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. 35.1.37 "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. 35.1.38 "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. 35.1.39 "Operating day" means a day, or any part of a day, in which a facility is engaged in manufacturing. 35.1.40 "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. 35.1.41 "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 Page 5 of 44 solvent evaporates during drying and does not become a part of the dried film. 35.1.42 "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. 35.1.43 "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. 35.1.44 "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. 35.1.45 "Recycled onsite" means the reuse of an organic solvent at the facility in a process other than cleaning or washoff. 35.1.46 "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. 35.1.47 "Shutdown" means the cessation of operation of wood products manufacturing operations for any purpose. 35.1.48 "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. 35.1.49 "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. 35.1.50 "Startup" means the setting in operation of wood products manufacturing operations for any purpose. 35.1.51 "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. 35.1.52 "Substrate" means the surface onto which coatings are applied or into which coatings are impregnated. Page 6 of 44 35.1.53 "Thinner" means a volatile liquid that is used to dilute coatings to reduce viscosity, color strength, and solids, or to modify drying conditions. 35.1.54 "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. 35.1.55 "Topcoat" means the last film-building finishing material applied in a finishing system. 35.1.56 "Touch-up and repair" means the application of finishing materials to cover minor finishing imperfections. 35.1.57 "Volatile Hazardous Air Pollutant" and "VHAP" means any of the substances listed in Table 1. 35.1.58 "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. 35.1.59 "Washoff operations" means those operations in which organic solvent is used to remove coating from a substrate. 35.1.60 "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. 35.1.61 "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 a major source of Hazardous Air Pollutants (HAP) from wood products manufacturing operations. 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. Page 7 of 44 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, 35.1.23, and 35.1.41, this term should be read as Volatile Organic Compound and Halogenated Organic Compound or VOC and HOC. 35.2.4 The owner or operator of a facility which is a major source of Hazardous Air Pollutants (HAP) from wood products manufacturing operations but which has not emitted more than 10 tons of any one HAP or more than 25 tons of any combination of HAP from wood products manufacturing operations 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 Department 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. Page 8 of 44 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 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 Department. Page 9 of 44 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 of the Department, 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 Page 10 of 44 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 from wood products manufacturing operations 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 Department. (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. Page 11 of 44 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 from wood products manufacturing operations 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 Department. (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. 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. Page 12 of 44 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 from wood products manufacturing operations 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 from wood products manufacturing operations 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 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 Page 13 of 44 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 Department. (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 Department 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: (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 Page 14 of 44 (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 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 Department 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 Page 15 of 44 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 Department 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 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 Office of Air Resources 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. Page 16 of 44 (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. 35.5.7 Application Equipment Requirements Conventional air spray guns shall not be used to apply finishing materials, except in the following situations: Page 17 of 44 (a) When applying finishing materials before March 6, 1998 at a facility which is not a major source of HAP from wood products manufacturing operations 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 Department 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. 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. Page 18 of 44 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 from wood products manufacturing operations 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 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. Page 19 of 44 (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 Department 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 Department 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 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 Page 20 of 44 material and the VOC and VHAP content, as applicable, of the finishing material; and (d) The Department 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: ܧ௩௢௖ ൌ ∑ ௏೔஼೔ ೙ ೔సభ ∑ ௏೔ ೙ ೔సభ Equation 1 Where: EVOC = the weighted average VOC content of coatings in a particular coating category, in lb VOC/gal coating, as applied, excluding water and exempt compounds; C = the VOC content of a coating in the particular coating category, in lb VOC/gal coating excluding 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, excluding water and exempt compounds; (2) Demonstrate that the value calculated for EVOC is no greater than 0.9 times the 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 Page 21 of 44 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: ܧ௏ு஺௉ൌ ∑ ெ೔ ೙ ೔సభ ஼೔ା ∑ ௌ೔ ೙ ೔సభ ௐ೔ ∑ ெ೔ ೙ ೔సభ Equation 2 Where: EVHAP = the weighted average VHAP content of finishing materials, in lb VHAP/lb solids; C = the VHAP content of a finishing material, in lb VHAP/lb solids, as supplied; 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. 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 Page 22 of 44 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: ܴ ௡ൌሾ ஼ିா௅ ஼ሿሺ100ሻ 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. ܴ ௔ൌሺܨൈܰ ሻሺ100ሻ 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 the value of Eac in Equation 5 is no greater than 0.8 if complying with Subsection 35.3.3; ܴ ௡ൌሺ100ሻሺܧ௕௖െܧ௔௖ሻ/ܧ௕௖ Equation 5 Where: Page 23 of 44 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; ܴ ௡ൌሺ100ሻሺܩ௕௖െܩ௔௖ሻ/ܩ௕௖ 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. (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 Page 24 of 44 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 Department and the EPA to establish other operating parameters. One of the following devices is required to monitor these parameters: (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 Page 25 of 44 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 Department and the EPA. (g) A facility using a control device not listed in this section to comply with this regulation shall submit to the Office of Air Resources 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 Department 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 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. Page 26 of 44 (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: (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; Page 27 of 44 (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 from wood products manufacturing operations shall submit a Initial Notification to the Division by September 2, 1996 or within 30 days of becoming a major source of HAP from wood products manufacturing operations, 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; (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 Page 28 of 44 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 from wood products manufacturing operations 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 from wood products manufacturing operations 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: Page 29 of 44 (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 Page 30 of 44 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 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 Office of Air Resources 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. Page 31 of 44 (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. (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 Page 32 of 44 with the recordkeeping and monitoring requirements specified in this regulation. 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 Department. 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 Department, 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 Department Page 33 of 44 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 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: ܨൌ ∑ ொ್೔஼್೔ ೙ ೔సభି ∑ ொೌೕ ೛ ೕసభ ஼ೌೕ ∑ ொ್೔஼್೔ ೙ ೔సభ Equation 7 Page 34 of 44 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: ܰ ൌ ∑ ொ೏೔஼೏೔ ೙ ೔సభ ∑ ொ೏೔஼೏೔ ೙ ೔సభ ା∑ ொ೑ೖ஼೑ೖ ೛ ೖసభ 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 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 Department and the EPA, the control device capture efficiency, N, is equal to 1. Page 35 of 44 35.9 General Provisions 35.9.1 Purpose The purpose of this regulation is to limit emissions of volatile organic compounds and hazardous air pollutants from wood products manufacturing operations. 35.9.2 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 35.9.3 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. 35.9.4 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 36 of 44 35.9.5 Effective Date The foregoing regulation, "Control of Volatile Organic Compounds and Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations”, as amended, after due notice, 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 37 of 44 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 Table 1 (continued) Page 38 of 44 Chemical name CAS No. 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 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 Table 1 (continued) Page 39 of 44 Chemical name CAS No. 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 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 Table 1 (continued) Page 40 of 44 Chemical name CAS No. 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 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 Table 1 (continued) Page 41 of 44 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. Page 42 of 44 TABLE 3. POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF SOLVENTS1 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 1Solvents containing these pollutants in concentrations less than or equal to 0.1% may be used. Page 43 of 44 Chemical Name CAS No. 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 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 Page 44 of 44 Chemical Name CAS No. 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