& EPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-456/R-97-005 \S"
September 1997
http://www.epa.gov/ttn/uatw
Air
WOOD FURNITURE MANUFACTURING
OPERATIONS NESHAP
IMPLEMENTATION DOCUMENT
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WOOD FURNITURE MANUFACTURING OPERATIONS
NESHAP IMPLEMENTATION DOCUMENT
Prepared for:
Information Transfer and Program Integration Division (ITPID)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Prepared by:
Midwest Research Institute
Crossroads Corporate Park
5520 Dillard Road, Suite 100
Gary, NC 27511-9232
September 1997
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TABLE OF CONTENTS
Pa
CHAPTER 1
INTRODUCTION 1-1
1.1 BACKGROUND 1-1
1.2 PURPOSE OF GUIDEBOOK 1-1
1.3 ORGANIZATION 1-2
^ CHAPTER 2
SS OVERVIEW OF THE NESHAP 2-1
N 2.1 WOOD FURNITURE NESHAP - APPLICABILITY AND REQUIREMENTS .. 2-1
CHAPTER 3
-0
WORK PRACTICE STANDARDS 3-1
3.1 APPLICATION EQUIPMENT REQUIREMENTS 3.1
3.2 OPERATOR TRAINING PROGRAM 3.3
3.3 INSPECTION AND MAINTENANCE PLAN 3.3
3.4 CLEANING AND WASHOFF SOLVENT ACCOUNTING PROGRAM 3.4
3.5 ADDITIONAL WORK PRACTICE STANDARDS 3.4
3.6 WORK PRACTICE IMPLEMENTATION PLAN 3.5
3.7 FORMULATION ASSESMENT PLAN FOR FINISHING OPERATIONS 3.5
3.8 COMPOSITION OF CLEANING AND WASHOFF SOLVENTS 3.7
CHAPTER 4
NESHAP COMPLIANCE OPTIONS 4-1
4.1 NESHAP COMPLIANCE OPTIONS 4-1
4.2 COMPLIANCE OPTIONS FOR GLUING OPERATIONS 4-8
CHAPTER 5
RECORDKEEPING AND REPORTING REQUIREMENTS 5-1
5.1 RECORDKEEPING REQUIREMENTS 5-1
5.2 NESHAP REPORTING REQUIREMENTS 5.4
CHAPTER 6
EXAMPLE INSPECTION CHECKLISTS
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TABLE OF CONTENTS (continued)
CHAPTER 7
QUESTIONS ON THE WOOD FURNITURE NESHAP 7-1
7.1 APPLICABILITY 7-1
7.2 DETERMINING MAJOR SOURCE STATUS 7-3
7.3 DEFINITIONS 7-4
7.4 COATING EMISSION LIMITS AND COMPLIANCE OPTIONS 7-6
7.5 ADHESIVE EMISSION LIMITS AND COMPLIANCE OPTIONS 7-9
7.6 WORK PRACTICE STANDARDS 7-9
APPENDIX A.
APPENDIX B.
APPENDIX C.
APPENDIX D.
APPENDIX E.
APPENDIX F.
APPENDIX G.
ACRONYMS AND DEFINITIONS
LIST OF CONTACTS
DETAILED TABLE OF CONTENTS FOR THE NESHAP
FEDERAL REGISTER NOTICE-WOOD FURNITURE NESHAP
LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
POLLUTANTS EXCLUDED FROM USE IN CLEANING AND
WASHOFF SOLVENTS
SOURCES OF TECHNICAL AND REGULATORY INFORMATION
11
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LIST OF FIGURES
Figure 2-1. Determining the applicability of the NESHAP to a
facility 2-3
LIST OF TABLES
Page
TABLE 2-1. COMPLIANCE DATES FOR THE NESHAP 2-5
TABLE 2-2. SUMMARY OF NESHAP EMISSION LIMITS 2-6
TABLE 3-1. WORK PRACTICE STANDARDS FOR THE WOOD FURNITURE
NESHAP 3-2
TABLE 3-2. VHAP OF POTENTIAL CONCERN IDENTIFIED BY INDUSTRY .. 3-5
TABLE 4-1. COMPLIANCE METHODS FOR THE NESHAP 4-1
TABLE 4-2. COATING PARAMETERS FOR FACILITY USING AVERAGING
APPROACH TO MEET THE NESHAP EMISSION LIMITS FOR
FINISHING 4-6
TABLE 4-3. OPERATING PARAMETERS FOR ADD-ON CONTROL
DEVICES 4-7
TABLE 4-4. COMPLIANCE DEMONSTRATION FOR COMPLIANT
ADHESIVES 4-9
TABLE 5-1. RECORDKEEPING REQUIREMENTS FOR THE NESHAP 5-2
TABLE 5-2. RECORDKEEPING REQUIREMENTS NESHAP WORK PRACTICE
STANDARDS 5-3
TABLE 5-3. INFORMATION TO BE INCLUDED IN INITIAL COMPLIANCE
REPORT FOR THE NESHAP 5-5
TABLE 5-4. INFORMATION TO BE INCLUDED IN THE SEMIANNUAL
COMPLIANCE STATUS REPORT FOR THE NESHAP 5-6
in
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CHAPTER 1
INTRODUCTION
1.1 BACKGROUND
The Clean Air Act as amended in 1990 (CAA) directs the U. S. Environmental Protection
Agency (EPA) to regulate emissions of 189 toxic chemicals (hazardous air pollutants, or HAP)
from a wide range of industrial sources. In 1992, surface coating of wood furniture was listed as
a source category to be regulated under the CAA because many of the coatings, adhesives, and
solvents used in the wood furniture industry contain toxic chemicals such as toluene, xylene,
methanol, methyl ethyl ketone, glycol ethers, and formaldehyde. Therefore, the EPA is
regulating HAP emissions from wood furniture manufacturing facilities to meet the requirements
of the CAA. The EPA estimates that this regulation will reduce nationwide HAP emissions from
wood furniture manufacturing facilities by 32,000 tons per year.
In December of 1995, the EPA issued national emission standards for hazardous air
pollutants (NESHAP) to control emissions from wood furniture manufacturing operations. The
regulation appeared in the December 7, 1995 edition of the Federal Register [60 FR 62930,] and
was amended in June of 1997 [62 FR 30257; 62 FR 31361]. The level of emissions control
required by the NESHAP is based on the maximum achievable control technology (MACT).
Therefore, these standards are sometimes referred to as MACT standards.
The NESHAP was developed through a regulatory negotiation process. In a regulatory
negotiation. EPA works with members of industry, State representatives, and representatives
from environmental groups to try to reach an agreement regarding the level of control that should
be required, the format of the standards, compliance options, and recordkeeping and reporting
requirements. The wood furniture regulatory negotiation Committee reached consensus on all
issues.
1.2 PURPOSE OF GUIDEBOOK
The purpose of this guidebook is to provide assistance to Sate and local agencies who are
responsible for implementing the requirements of the wood furniture NESHAP. This guidebook
is not a complete and full statement of the legal and technical requirements of the regulation. See
1-1
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the Federal Register notice (Appendix D of this guidebook) for the complete text of the
regulation.
This manual also includes summary tables and example calculations that are designed to
assist in implementing the wood furniture NESHAP.
1.3 ORGANIZATION
Chapter 2 of this guidebook presents an overview of the NESHAP applicability and
requirements. Chapters 3, 4, and 5 discuss the work practice standards, compliance options, and
recordkeeping and reporting requirements, respectively. Chapter 6 presents example inspection
checklists that State and local agency inspection personnel can use in making compliance
inspections at wood furniture manufacturing facilities. Finally, Chapter 7 is a su .\mary of
commonly asked questions and answers on the wood furniture NESHAP. The u;pendices
contain acronyms and definitions, contacts, other guidance materials available on the wood
furniture NESHAP, a detailed table of contents for the NESHAP, and the text of the wood
furniture manufacturing NESHAP.
1-2
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CHAPTER 2
OVERVIEW OF THE NESHAP
2.1 WOOD FURNITURE NESHAP - APPLICABILITY AND REQUIREMENTS
The level of control required by the NESHAP is based on MACT. Unlike reasonably
available control technology (RACT), which addresses VOC emissions, MACT is aimed at
reducing emissions of hazardous air pollutants (HAP). While the majority of HAP are VOC, not
all VOC are HAP. Appendix E contains a list of volatile HAP (VHAP) that will be regulated
under this NESHAP.
In addition to regulating HAP emissions from finishing and cleaning operations, the
NESHAP will also regulate emissions from some gluing operations. The NESHAP includes
emission limitations for contact adhesives, and many of the work practice standards that are
discussed in Chapter 3 also apply to gluing operations
2.1.1 Applicability of NESHAP
Figure 2-1 can be used to assist State and local agencies in determining whether a facility
is subject to the NESHAP. The NESHAP is a national standard that applies to facilities that are
engaged in, either in part or in whole, in the manufacture of wood furniture or wood furniture
components and emit or have the potential to emit 10 tons or more of any HAP or 25 tons or
more of any combination of HAP. These sources are known as major sources.
Wood furniture component means any part that is used in the manufacture of wood
furniture. Examples include, but are not limited to, drawer sides, cabinet doors, and laminated
tops. However, foam seat cushions manufactured and fabricated at a facility that does not engage
in any other wood furniture or wood furniture component manufacturing operation are excluded
from this definition. The NESHAP includes a list of SIC codes that should be used as a guide in
determining the applicability of the NESHAP to a particular facility. However, if there is any
question as to whether the NESHAP is applicable to a facility, Mr. Bob Marshall of EPA's
Office of Enforcement and Compliance Assurance should be contacted.
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IS THE FACILITY AN INCIDENTAL FURNITURE MANUFACTURER USING LESS
THAN 100 GAL/MO OF WOOO FURNITURE COATINGS AND ADHESIVES BUT
A MAJOR SOURCE DUE TO OTHER OPERATIONS'
YES
FACILITY IS NOT SUBJECT TO NESHAP BUT
MUST MAINTAIN COATING AND ADHESIVE
PURCHASE OR USAGE RECORDS
NO
DOES THE FACILITY USE MORE THAN 250 GAL/MO (3.000 GAL PER ROLLING
12-MONTH PERIOD) OF FINISHING. GLUING. CLEANING. AND WASHOFF
MATERIALS (INCLUDING MATERIALS USED IN PROCESSES OTHER THAN
WOOO FURNITURE MANUFACTURING)'
OH
DOES THE FACILrTY EMIT MORE THAN
5 TONS OF ANY ONE HAP PER ROLLING 12 MONTH PERIOD
(AND AT LEAST 90% OF EMISSIONS ARE ASSOCIATED WITH THE
MANUFACTURE OF WOOO FURNITURE)'
FACILITY IS AN AREA SOURCE AND IS NOT
SUBJECT TO THE NESHAP IF 90 PERCENT OF
TOTAL EMISSIONS FROM THE SITE ARE
FROM MATERIALS USED FOR WOOO
FURNCTURE MANUFACTURING OPERATIONS
THE FACI.ITY MUST MAINTAIN RECORDS OF
THE AMOUNT OF MATERIALS USED AND
CPDS FOR THOSE MATERIALS
YES
DOES THE FACIUTY EMIT MORE THAN
12.5 TONS OF ANY COMBINATION OF HAP PER ROLLING 12 MONTH PERIOD
(AND AT LEAST 90% OF EMISSIONS ARE ASSOCIATED WITH THE
MANUFACTURE OF WOOO FURNITURE)'
NO
YES
FAOUTY IS AN AREA SOURCE AND IS NOT
SUBJECT TO THE NESHAP IF 90 PERCENT OF
TOTAL EMISSIONS FROM THE SITE ARE
FROM MATERIALS USED FOR WOOO
FURNITURE MANUFACTURING OPERATIONS.
THE FACILITY MUST MAINTAIN RECORDS OF
THE AMOUNT OF MATERIALS USED AND
CPDS FOR THOSE MATERIALS
DOES THE FACILrTY EMIT OR HAVE THE POTENTIAL TO EMIT 10 TONS
OF ANY ONE HAP OR 25 TONS OF A COMBINATION OF HAPj PER YEAR
(INCLUDING EMISSIONS FROM PROCESSES OTHER THAN WOOD
FURNITURE MANUFACTURING)''
NO
YES
FACILrTY IS NOT SUBJECT TO THE NESHAP.
BUT THEY MAY HAVE TO OBTAIN A
FEDERALLY ENFORCEABLE LIMIT ON THEIR
POTENTIAL TO EMIT BY LIMITING THEIR
OPERATING HOURS. COATING USAGE. ETC
FACILITY IS SUBJECT TO THE NESHAP
DID CONSTBUCnON OR RECONSTRUCTION OF THE FACILITY BEGIN AFTER
DECEMBER 8. 1994
FACILITY IS A NEW SOURCE AND IS SUBJECT
TO THE EMISSION LIMITS FOR NEW
SOURCES
NO
FACLITY IS AN EXISTING SOURCE AND IS SUBJECT TO THE EMISSION LIMITS
FOR EXISTING SOURCES
Figure 2-1. Determining the applicability of the NESHAP to a Wood Furniture facility.
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In determining whether or not a source is major, HAP emissions from all sources at the
facility must be accounted for. For example, a facility may manufacture metal and wood
furniture. Although the NESHAP will only apply to the wood furniture manufacturing
operations, emissions from the metal furniture manufacturing operations must be included when
determining whether or not the source is major.
However, if a facility only performs incidental wood furniture manufacturing but is a
major source due to other unrelated activities, the facility is not subject to the regulation if no
more than 100 gallons per month of wood furniture coatings and adhesives are used. This
exemption would include operations such as hobby shops on military bases or maintenance shops
at chemical plants that manufacture wood furniture items such as bookshelves for on site use.
These facilities must maintain records to demonstrate that their usage of wood furniture coatings
and adhesives is no more than 100 gallons per month.
Sources using less than 250 gallons per month, or 3,000 gallons per rolling 12-month
period, of coating, gluing, cleaning, and washoff materials, including materials used for
operations other than wood furniture manufacturing, are area sources and are not subject to the
NESHAP if the finishing materials, adhesives, cleaning solvents, and washoff solvents account
for at least 90 percent of annual emissions at the plant site. These sources must also maintain
records that demonstrate their material usage is below these levels. A rolling 12 month period
includes the previous 12 months of operation at the facility. Facilities should note that this
limitation includes all coating, gluing, cleaning, and washoff materials, whether those materials
contain HAP or not.
Sources that emit no more than 5 tons per rolling 12 month period of any one HAP and
no more than 12.5 tons per rolling 12 month period of any combination of HAP, and at least 90
percent of the plantwide emissions are associated with the manufacture of wood furniture or
wood furniture components, are also considered area sources under the NESHAP. These
facilities will be required to maintain records demonstrating that their actual emissions are less
than these cutoffs.
2.1.2 Compliance Dates
Table 2-1 presents the compliance dates for existing facilities subject to the NESHAP.
An existing facility's compliance date is determined by its actual emissions for the year 1996.
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New sources must comply with the provisions of the NESHAP upon promulgation of the
NESHAP or upon startup, or reconstruction, whichever is later. For this rule, facilities are
considered new sources if construction commenced on or after December 6, 1994.
TABLE 2-1. COMPLIANCE DATES FOR THE NESHAP
FOR EXISTING SOURCES
1996 Emissions
>50 tons of HAP/yr
<50 tons of HAP/yr
Compliance date
November 21, 1997
December?, 1998
2.1.3 NESHAP Emission Limitations
A summary of the NESHAP emission limitations is presented in Table 2-2. These
include limitations on the VHAP content of both finishing materials and contact adhesives and a
limit on the VOC content of strippable spray booth coating. Note that the NESHAP includes
emission limitations for both existing and new sources. Wood furniture manufacturing facilities
that begin construction or reconstruction after the proposal date, that is, after December 6, 1994,
are considered new sources. Reconstruction is the replacement of components of a source to the
extent that the fixed capital cost of the new components exceeds 50 percent of the fixed capital
cost that would be required to construct a comparable new source.
There are several options a facility may use to comply with the emission limits for
finishing operations. Chapter 4 provides additional detail on each of the compliance methods,
including examples of the calculations to be used to demonstrate compliance.
The standards for finishing operations limit the pounds of VHAP per pound of solids for
selected coatings or as an average across all coatings used at the facility. Because many facilities
formulate their washcoats, basecoats, and enamels onsite by thinning other types of finishing
materials (for example, many facilities thin their sealers to use as washcoats) the regulation
contains guidance that is aimed at reducing the recordkeeping burden on these facilities. If the
facility does formulate one of these coatings onsite, the coating will be deemed compliant if the
finishing material that is thinned is compliant and thinners with a HAP content of no more than
3.0 percent are used to thin the coating. For example, if a facility thins its sealer to make
washcoat, the facility does not have to maintain records of the VHAP content of the washcoat as
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TABLE 2-2. SUMMARY OF NESHAP EMISSION LIMITS
Emission point
Finishine ooerations
(a) Achieve a weighted average VHAP content across all coatings (Ib
VHAP/lb solids, as applied);
(b) Use compliant finishing materials (Ib VHAP/lb solids, as applied)
-stains
-washcoats
-sealers
-topcoats
-basecoats
-enamels
-thinners (maximum %HAP allowable); or
(c) Use a control device or
(d) Use a combination of (a), (b), and (c)
Cleaning operations
Strippable spray booth coating (Ib VOC/lb solids, as applied)
Gluing operations
(a) Use compliant contact adhesives (Ib VHAP/lb solids, as applied)
based on the following criteria:
I. For aerosol adhesives, and for contact adhesives applied to
nonporous substrates
ii. For foam adhesive used in products subject to flammability
testing;
iii. For all other contact adhesives (including foam adhesives
used in products not subject to flammability testing but
excluding aerosol adhesives and excluding contact adhesives
used on nonporous substrates); or
ib) Use a control device
Existing source3
1.0
1.0
1.0b
1.0
1.0
1.0b
1.0b
10.0
1.0C
1.0
0.8
NAd
1.8
1.0
1.0e
New
source3
O.a
1.0
0.8b
0.8
0.8
0.8b
0.8b
10.0
0.8*
0.8
0.8
NAd
0.2
0.2
0.2e
aThe limits refer to the maximum VHAP/VOC content, as applied.
''Washcoats, basecoats, and enamels must comply with the limits presented in this table if they are purchased
premade, that is, if they are not formulated onsite by thinning other finishing materials. If they are formulated
onsite, they must be formulated using compliant finishing matenals (i.e., those that meet the limits specified in
this table) and thinners containing no more than 3.0 percent VHAP by weight.
cThe control device must operate at an efficiency that is equivalent to no greater than 1.0 pound of VHAP (0.8
for new sources) being emitted per pound of solids used.
dThere is no limit on the VHAP content of these adhesives.
^e control device must operate at an efficiency that is equivalent to no greater than 1.0 pound of VHAP (0.2
for new sources) being emitted per pound of solids used.
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long as the sealer has a VHAP content of no more than 1.0 Ib VHAP/lb solids (0.8 for new
sources) and the thinner has a HAP content no greater than 3.0 percent by weight. If the facility
purchases washcoat, however, it must demonstrate that the washcoat is compliant.
Contact adhesives are the only type of adhesive regulated by the standard. In the
regulation, foam adhesives are considered a subset of contact adhesives, and they have a different
emission limitation depending upon whether the product in which they are used is subject to
flammability testing. Foam adhesives used in products subject to flammability testing, which is
often required for office and institutional furniture, have a less stringent emission limit because
testing has shown that products made with waterborne adhesives may not pass the flammability
tests. However, foam adhesives used by new sources must meet the same emission limit as all
other contact adhesives, regardless of any flammability testing that may be required. Note that
aerosol adhesives and contact adhesives used on nonporous substrates (rubber, metal, rigid
plastic, and flexible vinyl) are not subject to emission limits under this rule.
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CHAPTER 3
WORK PRACTICE STANDARDS
Work practice standards are an integral part the NESHAP. In general, the work practice
standards are aimed at reducing coating, cleaning solvent, and washoff solvent usage. Many
facilities will have already implemented a number of these work practices because, in addition to
reducing emissions, they also reduce worker exposure to solvents and, in many cases, operating
costs.
A summary of the work practice standards that are required by the NESHAP is presented
in Table 3-1. The work practice standards are discussed in detail in the following sections.
Chapter 5 includes a discussion of recordkeeping and reporting requirements associated with the
work practice standards.
3.1 APPLICATION EQUIPMENT REQUIREMENTS
The NESHAP limits the use of conventional air spray guns. Facilities are allowed to use
these guns only under any of the following conditions:
1. If they are using the guns to apply coatings that have a VOC content no greater than
1.0 lb VOC/lb solids, as applied;
2. If they are using the gun for touchup and repair that occurs either after the completion
of the finishing operation or after the application of stain and before the application of other types
of finishing materials. In addition, any materials used for touchup and repair after the stain
application must be applied from a container with a volume of no more than 2.0 gallons.
3. If the guns are automatic;
4. If the guns are used in a spray booth or other application station where emissions are
directed to a control device;
5. If the guns are only used for applying small quantities of finishing material. The total
amount of finishing material applied with the conventional air spray gun must be no more than
5.0 percent of the total amount of finishing material used in that semiannual period; or
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TABLE 3-1. WORK PRACTICE STANDARDS FOR THE WOOD
FURNITURE NESHAP3
Emission source
Work practice
Finishing operations
Equipment leaks
Storage containers, including
mixing equipment
Application equipment
Develop a written inspection and maintenance plan to address
and prevent leaks. Inspections must be made once per month.
Keep containers used for storing or mixing HAP, or materials
containing HAP, covered when not in use.
Discontinue use of conventional air spray guns.b
Cleaning and washoff operations
Gun/line cleaning
Spray booth cleaning
Washoff/general cleaning
Collect solvent into a closed container.
- Cover all containers associated with cleaning when not in
use.
Use solvents for cleaning spray booths only under certain
conditions.0
Keep washoff tank covered when not in use.
- Minimize dripping by tilting and/or rotating the part to
drain as much solvent as possible. Allow sufficient dry
time for the part.
- Maintain a log of the number of parts washed off and the
reason for the washoff.
- Maintain a log of the quantity and type of solvent used for
washoff and cleaning, as well as the quantity of solvent
reused for other operations at the facility and the quantity
of solvent sent offsite for disposal.
Miscellaneous
Operator training
Implementation plan
All operators shall be given annual training on proper
application methods, cleaning procedures, and equipment use.
Develop a plan to implement these work practice standards
and maintain onsite.
aThe work practice standards apply to both existing and new major sources.
bConventional air spray guns will be allowed only in any of the following instances:
- when they are used to apply finishing materials that emit less than 1.0 Ib VOC/lb solids;
- touchup and repair under limited conditions;
- when spray is automated;
- when add-on controls are employed;
- if the cumulative application is no more than 5.0 percent of the total gallons of finishing material applied; or
- if the permitting agency determines that it is economically or technologically infeasible to use other
application technologies.
cSolvents can be used for cleaning conveyors and their enclosures and metal filters. Limited quantities, no more
than 1.0 gallon, can also be used for spot cleaning when the spray booth coating is being replaced.
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6. If the gun is used to apply stain and the facility can demonstrate that it is technically or
economically infeasible to use another spray application technology.
To qualify for exemption (6), the facility must submit a videotape, a technical report, or
. some other type of documentation to the permitting agency that supports the facility's claim of
technical or economic infeasibility. There are two factors that the facility can use either singly or
in combination to support their claim. These are:
*. 1. The production speed is too high or the part shape is too complex for one operator to
5 finish the part and the spray booth is not large enough for an additional operator; or
2. The part has an excessively large vertical spray area, making it difficult to avoid
sagging or runs in the stain.
A final determination of whether the facility may use the conventional air spray gun under
exemption (6) will be made by the permitting authority.
3.2 OPERATOR TRAINING PROGRAM
Each facility subject to the NESHAP must conduct annual training of all employees who
are involved in finishing, gluing, cleaning, or washoff operations. All personnel hired before the
effective date of the standard, which will vary according to the size of the facility, must be
trained within 6 months of the effective date. Personnel who are hired after the effective date of
the standard must be trained upon hiring. All personnel must be retrained annually.
Operator training should include instruction in application techniques, cleaning and
washoff procedures, equipment setup and adjustment, and management of waste solvent from
cleaning and washoff operations. The facility must develop a training program that includes a
list of current personnel that must be trained, an outline of the subjects covered in the initial and
refresher training, and a description of how the facility will document that personnel have
successfully completed the training program.
3.3 INSPECTION AND MAINTENANCE PLAN
Each facility must also develop an inspection and maintenance plan that addresses
equipment leaks. Facilities are required to visually check all equipment used to transfer or apply
finishing materials or organic solvents at least once a month to ensure there are no equipment
leaks. The inspection and maintenance plan should include a schedule for inspections and a way
to document the date of each inspection as well as any repairs that were made. After identifying
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the leak, the facility must attempt to repair the leak within 5 days and make final repairs within
15 days, unless the leaking equipment has to be replaced, in which case the facility is allowed
3 months to complete repairs.
3.4 CLEANING AND WASHOFF SOLVENT ACCOUNTING PROGRAM
Facilities are required to develop a program for tracking the amount and type of organic
solvent used for cleaning and washoff each month. They must also track the amount of spent
solvent that is generated from each cleaning operation each month, the amount of spent solvent
that is reused in-house for operations other than cleaning or washoff, and the amount that is sent
offsite for disposal. Finally, the program should provide a mechanism for tracking the number of
pieces that are washed off and the reason for the washoff.
3.5 ADDITIONAL WORK PRACTICE STANDARDS
3.5.1 Spray Booth Cleaning
The NESHAP limits the types of cleaners that can be used for spray booth cleaning.
Unless operators are cleaning conveyors, continuous coalers and their enclosures, or metal filters,
they may not use cleaning compounds containing more than 8.0 percent of VOC by weight. The
8.0 percent limit should still allow facilities to use many commercial cleaners, but it precludes
the use of organic solvent. Facilities may, however, use organic solvents in small quantities, no
more than 1.0 gallon per booth, if they are replacing the strippable spray booth coating or other
protective material used to cover the booth.
3.5.2 Storage Containers
All containers that are used to store finishing, cleaning, gluing, or washoff materials
must be closed unless an operator is emptying or filling the container. This includes drums that
are used to hold wiping rags.
3.5.3 Gun and Line Cleaning
Organic solvent used to clean spray guns and lines must be collected in a container that is
kept closed except when an operator is emptying or filling the container.
3.5.4 Washoff Operations
Tanks used for washoff must be kept closed when they are not being used. Operators
should also try to minimize dripping from the part that has been washed off by tilting or rotating
the part so that the solvent can drain back into the tank.
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3.6 WORK PRACTICE IMPLEMENTATION PLAN
Each facility must develop a work practice implementation plan that documents how they
will ensure that all of the work practice standards are being followed. The operator training
program, the inspection and maintenance plan, and the solvent accounting program should be
included in the work practice implementation plan along with examples of record forms or
checklists developed by the facility as a part of these plans.
3.7 FORMULATION ASSESSMENT PLAN FOR FINISHING OPERATIONS
Table 3-2 presents a partial list of VHAP of potential concern. These VHAP of potential
concern were identified by several coating suppliers as being present in some coating formula-
tions used by the wood furniture industry. The first step for the facility in developing their
formulation assessment plan is to identify any chemicals from this list that are used in their
finishing materials or thinners. The facility must then determine how much of the chemical they
used in 1994, 1995, and 1996. The highest value from those 3 years is considered the baseline
level of usage for that chemical. Note that VHAP of potential concern used in adhesives should
not be included in the baseline level. The formulation assessment plan only applies to VHAP of
potential concern used in finishing materials.
TABLE 3-2. VHAP OF POTENTIAL CONCERN IDENTIFIED BY INDUSTRY
Chemical
Dimethyl formamide
Formaldehyde
Methylene chloride
2-Nitropropane
Isophorone
Styrene monomer
Phenol
Diethanolamine
2-Methoxyethanol
2-Ethoxyethyl acetate
CAS No.
68122
50000
75092
79469
78591
100425
108952
11422
109864
111159
EPA de minimis, tons/yr
1.0
0.2
4.0
1.0
0.7
1.0
0.1
5.0
10.0
5.0
Sources using a control device to reduce emissions should adjust their usage based on the
overall control efficiency of the control system. Because some portion of the formaldehyde and
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styrene in a coating becomes part of the cured resin, the regulation provides guidance on how to
calculate usage of these chemicals. For formaldehyde, usage is based on the amount of free
formaldehyde present in the finishing material when it is applied. For styrene monomer, usage is
calculated by multiplying the amount of styrene monomer in the finishing material when it is
applied by a factor of 0.16.
Facilities must continue to track their usage of each VHAP of potential concern.
However, they only have to track usage of those VHAP that are present in a finishing material in
a large enough quantity that it must be reported on the material safety data sheet (MSDS). If,
after November 1998, a facility's usage of the VHAP exceeds the baseline usage level for that
VHAP, the facility must notify the permitting authority in writing that they have exceeded their
baseline level, the amount by which they have exceeded the baseline, and the reasons why. If the
facility has exceeded the baseline for any of the reasons cited below, and they are in compliance
with any State regulations or requirements for that VHAP, the facility does not have to take any
further action. They may also exceed the baseline level for any of the following reasons:
1. The exceedance is no more than 15.0 percent above the baseline level;
2. The facility's usage of the VHAP is less than the de minimis value for that VHAP as
presented in Table 3-2;
3. The facility is in compliance with its State's air toxics regulations or guidelines for that
VHAP; or
4. The VHAP is being used in a finishing material with a VOC content of no more than
1.0 Ib VOC/lb solids, as applied.
If the increase above the baseline level is due to some reason other than those listed
above, the facility must then refer to their permitting authority to discuss the reason for the
increase and whether or not there are practical and reasonable technology-based solutions for
reducing the usage. Cost, quality, and marketability of the product, as well as successful usage of
the technology by other wood furniture manufacturers, may all be considered in determining
whether a solution exists. The facility and the permitting authority may also agree upon other
factors that should be used for such an evaluation. If there are no practical and reasonable
solutions, the facility would not have to take any further action. If there are solutions, the facility
must develop a plan to reduce usage of the VHAP to the extent feasible. The plan should address
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the approach the facility will use to reduce usage, a timetable for reducing usage, and a schedule
for reporting progress to the permitting authority.
There may be cases in which a facility begins using a VHAP of potential concern for
which a baseline level has not been previously established. In those cases, the baseline level is
equal to the de minimis level, based on 70 year exposure levels and data provided in the
proposed rulemaking pursuant to section 112(g) of the Clean Air Act, for that VHAP. A
complete listing of all VHAP of potential concern is presented in Appendix A, Table A-1. If
usage of the VHAP is greater than the de minimis level, then the facility must follow the same
procedures as those in the previous paragraphs for exceeding an established baseline level. Any
of the reasons listed in (1) through (4) will excuse the facility from further action.
3.8 COMPOSITION OF CLEANING AND WASHOFF SOLVENTS
The NESHAP also prohibits the use of solvents containing any of the chemicals listed in
Appendix F for cleaning and washoff operations. However, the restriction is only limited to
chemicals that are present in the solvent at a level high enough that they have to be reported on
the MSDS.
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CHAPTER 4
NESHAP COMPLIANCE OPTIONS
The NESHAP includes four options that a facility can use to comply with the regulations.
Table 4-1 summarizes these options. Each of these options has advantages and disadvantages.
In general, the more flexibility the option provides the facility, the greater the recordkeeping
requirements associated with the option.
TABLE 4-1. COMPLIANCE METHODS FOR THE NESHAP
Compliance method
Compliant coatings
Averaging
Add-on control device
Combination
NESHAP
Yes
Yes, finishing only
Yes
Yes
In this chapter, we will discuss each of these options in more detail for the NESHAP and
present example calculations that a facility can use to demonstrate they are complying with each
option. A detailed discussion of the recordkeeping and reporting requirements associated with
each option is presented in Chapter 5.
4.1 COMPLIANCE OPTIONS FOR FINISHING OPERATIONS
4.1.1 Compliant Coatings
Table 2-2 presents the NESHAP emission limits for coatings for both existing and new
sources. As shown in the table, the standard limits the VHAP content of all stains, washcoats,
sealers, topcoats, basecoats, enamels, and thinners used by a facility. There is no limit on the
VHAP content of coatings typically used in smaller amounts, such as fillers and glazes. With the
exception of the emission limit for stains, the emission limits for coatings used by new sources
are more stringent than those used by existing sources.
To demonstrate compliance with the NESHAP emission limits for coatings, facilities
have to maintain copies of certified product data sheets for each coating, and thinners added to
those coatings, subject to an emission limit. If a facility thins the coatings before application, the
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NESHAP does not require the facility to maintain data sheets showing the amount of thinner
added to each batch and the VHAP content of that batch after thinning. However, the emission
limits are on an as applied basis so facilities do need to make sure that they are not thinning the
coating to the point that the emission limit is exceeded. If an inspector comes in and takes a
sample of the coating and it exceeds the limit, the facility will be in violation of the standard
even though the CPDS shows the VHAP content of the coating is no greater than the emission
limit established for that coating and the thinner the facility used had a HAP content less than
10.0 percent by weight. Therefore, it is in the best interest of the facility to maintain data sheets
for calculating the as-applied VHAP content even though it is not required by the NESHAP.
Setting up a system to determine the VHAP content of coatings as they are applied can be
straightforward. Example 1 demonstrates how to calculate the VHAP content of a coating after
thinning.
In summary, facilities using a compliant coatings approach to comply with the NESHAP
limits for finishing operations are required to maintain certified product data sheets for each
coating subject to an emission limit and any thinners that are added to those coatings.
4.1.1.1 Compliant coatings and continuous coaters. The NESHAP contains special
compliance provisions for facilities that are using a compliant coatings approach to comply with
the coating emission limits and are applying those coatings with a continuous coater. Facilities
may choose between the following two options.
1. Option 1 for demonstrating compliance is basically the same as it is for coatings that
are not applied with continuous coaters. Facilities must maintain copies of the CPDS for each
coating subject to an emission limit, and, if the coating is subsequently thinned, they must
maintain records that demonstrate the VHAP content of the as applied coating does not exceed
the emission limit for that coating. If an inspector takes a sample of the coating in the reservoir
and performs a Method 311 (40 CFR Part 60, Appendix A) analysis of the sample, the coating
must have a VHAP content no greater than the emission limit for the coating.
2. Under option 2, the facility must monitor the viscosity of the coating in the reservoir.
The viscosity of the initial coating in the reservoir must be measured. The facility may then
either monitor the viscosity of the coating in the reservoir continuously with a viscosity meter, or
they may measure the viscosity each time solvent is added. If, at any time, the viscosity of the
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Example 1 • Calculating the As-Applied VHAP Content of a Coating
VHAP content of topcoat - 0.8 Ib VHAP/lb solids, as supplied
Emission limit - 1.0 Ib VHAP/lb solids, as applied
Coating density - 8.0 Ib/gal
Coating solids content - 0.4 (40 percent)
Coating usage -1,000 gal
Solids used = Density x Gals used x percent solids
= 8.0x1,000x0.4
= 3,200 Ib solids
VHAP from as-supplied coating
= 0.8 Ib VHAP/lb solids x 3,200 Ib solids
= 2,560 Ib VHAP
Thinner VHAP content - 0.6 Ib/gal
Thinner usage - 100 gal
VHAP from thinner
0.6 x 100 = 60 Ib VHAP
VHAP from thinner and as supplied coating 2,560 + 60 = 2,620 Ib
Solids from as-supplied coating (also equal to solids of as-applied coating because
thinner contains no solids) = 3,200 Ib
VHAP content of as applied coating = 2,620 lbVHAP/3,200 Ib solids = 0.82 Ib
VHAP/lb solids, as applied.
In this case, the as-applied coating is still compliant, that is, it has a VHAP content
no greater than 1.0 Ib VHAP/lb solids, as applied. However, if this facility were a new
source, it would not be in compliance.
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coating in the reservoir is less than the viscosity of the initial coating, the facility is out of
compliance. The facility must also maintain a record of all solvent and coating additions to the
reservoir. As with option 1, if an inspector takes a sample of the coating in the reservoir, the
VHAP content must not exceed the emission limit for that coating. However, the VHAP content
as calculated from the facility's records may exceed the emission limit.
4.1.2 Averaging
The NESHAP also provides facilities the option of averaging their coatings to meet the
standard. The NESHAP gives facilities the flexibility of meeting a monthly average. For
existing sources, the average VHAP content for all finishing materials used at the facility during
the month must be no greater than 1 .0 Ib VHAP/lb solids, as applied. For new sources, the limit
is ' Ib VHAP/lb solids, as applied. Note that although the compliant coatings approach only
requires specific coatings to meet the emission limits, all coatings used at the facility during the
month must be included in the averaging equation for the NESHAP.
Both existing and new sources must use the following equation to demonstrate
compliance when using an averaging approach:
E = (MclCcl + Mc2Cc2 + ... + McnCcn + S^, + S2W2 + ...
Equation (3)
where:
E = average VHAP content of finishing materials (Ib VHAP/lb solids);
Mcn = the mass of solids in finishing material (c) used monthly (Ib solids/month);
Ccn = the VHAP content of finishing material (c) in Ib VHAP/lb solids;
Sn = the VHAP content, expressed as a weight fraction, of any thinners added to the
finishing materials participating in the averaging equation; and
Wn = the amount of Sn, in pounds, added to the finishing materials during the monthly
averaging period.
For existing sources, E must be no greater than 1.0 Ib VHAP/lb solids. For new sources, E must
be no greater than 0.8.
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To demonstrate compliance using an averaging approach, a facility must:
1. Maintain certified product data sheets for each finishing material;
2. Maintain records of the amount of each finishing material used each month and
the percent solids of that finishing material in order to determine the pounds of solids of each
finishing material used;
3. Maintain certified product data sheets for all thinners added to the finishing materials
used each month; and
4. Maintain records of the amount of thinners, in pounds, added to the finishing materials
during the month.
Example 2 illustrates a facility that has chosen to use an averaging approach to meet the
NESHAP emission limits for finishing operations.
4.1.3 Add-On Controls
Facilities may also use an add-on control device to meet the NESHAP emission limits for
finishing operations. It is anticipated that only a few facilities will choose this option, but it is
available. Currently, add-on control devices are being used by only a few facilities, and those are
primarily large kitchen cabinet and business furniture manufacturers with automated flatline
finishing systems. Controlling traditional wood furniture manufacturing exhaust streams, which
are typically high volume, low concentration streams, with add-on control devices is technically
feasible but generally not cost effective.
The NESHAP also recognizes that the overall control efficiency of a control system is a
product of the destruction/removal efficiency of the control device and the capture efficiency.
The capture efficiency is the ratio of the quantity of pollutants entering the control device to the
quantity of pollutants emitted from the emission source. The NESHAP identifies the methods to
be used to determine the capture efficiency initially. Because these methods are somewhat
complicated and apply to only a few facilities, they will not be discussed in detail here.
Facilities using add-on control devices must conduct a performance test to demonstrate
the overall control efficiency of the system. During the performance test, they need to establish
operating parameter(s) they can monitor that will demonstrate that the control device is
continually achieving the required control efficiency. If they cannot establish an operating
parameter, they may have to continually monitor HAP emissions at the inlet and outlet of the
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Example 2 • Calculations to Demonstrate Compliance for a Facility Using an
Averaging Approach to Meet the NESHAP Emission Limits
Facility Description - The facility is a medium sized kitchen cabinet plant using
about 60,000 gallons of coating per year, with a basic finishing sequence of stain, sealer,
and topcoat. The facility is an existing source, so they must achieve an average emission
limit of no more than 1.0 Ib VHAP/lb solids, as applied. In order to meet the NESHAP
emission limits, they have decided to use sealers and topcoats with slightly higher solids
contents, that is, about 35 percent. They have also worked with their coating supplier to
try and lower the HAP content of these coatings by using non-HAP solvents. The facility
has had little success reformulating their stains, however, so they must use an averaging
approach to meet the standard. The facility also uses small amounts of thinner, typically
lacquer thinner, for their sealers and topcoats. Table 4-2 presents the coating usage and
parameters for the facility.
TABLE 4-2. COATING PARAMETERS FOR FACILITY USING AVERAGING
APPROACH TO MEET THE NESHAP EMISSION LIMITS FOR FINISHING
Parameters
Usage (gal/month)
Density (Ib/gal)
% Solids (by weight)
Usage (Ib solids/month)
VHAP content (Ib/gal)
VHAP content (Ib VHAP/lb
solids)
Stain
925
6.7
1.5
93
0.1
45
Sealer
2,000
7.8
35
5,460
2.0
0.7
Topcoat
2.075
7.9
35
5,737
1.5
0.5
Thinner
60
6.8
0
0
3.4
N/A
Using Table 4-2:
E = ((93)(45) + (5,460)(0.7) + (5,737)(0.5) + (60)(6.8)(0.5))/(93 + 5,460 + 5,737) =
0.98 Ib VHAP/lb solids
Because E is less than 1.0 the facility is in compliance.
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control device. Table 4-3 presents operating parameters to be monitored for facilities using
thermal oxidizers, catalytic oxidizers, and carbon adsorbers. To demonstrate continuous
compliance with the standard using a control device, the facility must continuously monitor the
operating parameter(s) to demonstrate that the operating parameter(s) are in the range established
during the initial performance test.
TABLE 4-3. OPERATING PARAMETERS FOR ADD-ON CONTROL DEVICES
Control device
Thermal oxidizer
Catalytic oxidizer with fixed
catalyst bed
Catalytic oxidizer with fluidized
catalyst bed
Carbon adsorber
Operating parameter(s)
Minimum combustion temperature
Minimum gas temperature upstream and
downstream of the catalyst bed
1 . Minimum gas temperature upstream of the catalyst
bed; and
2. Pressure drop across the catalyst bed.
1 . Total regeneration mass stream for each
regeneration cycle; and
2. Carbon bed temperature after each regeneration.
4.1.4 Combination of Compliance Options
The NESHAP allows facilities to use any combination of the three options to meet the
emission limits for finishing operations. If using a combination of options, the facility must meet
the compliance demonstration requirements associated with each option.
4.2 COMPLIANCE OPTIONS FOR GLUING OPERATIONS
As discussed in Chapter 2, the NESHAP also establishes emission limits for contact
adhesives. Facilities using contact adhesives have two options for demonstrating
compliance-using compliant contact adhesives, that is, those that meet the emission limits
presented in Table 2-2, or using an add-on control device.
4.2.1 Compliant Contact Adhesives
Table 2-4 presents the emission limits for contact adhesives for both existing and new
sources. There are two categories of contact adhesives for the purposes of this rule: foam
t
adhesives and all other contact adhesives (excluding aerosol adhesives and excluding contact
adhesives used on nonporous substrates such as metal, rubber, rigid plastic, or flexible vinyl).
For existing sources, the limit is less stringent for foam adhesives due to problems encountered in
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formulating foam adhesives that pass flammability tests. The compliance demonstration
requirements for facilities using compliant contact adhesives are the same as those for facilities
using compliant coatings to meet the finishing limits.
If a facility does not thin their contact adhesives onsite, the only requirement for
demonstrating compliance is to maintain a certified product data sheet for each contact adhesive.
However, if the facility thins their adhesives onsite, they must also maintain data sheets that
demonstrate the as-applied VHAP content of the contact adhesive does not exceed the allowable
level. Because the limit for contact adhesives varies according to the use of the adhesive, the
facility should also maintain a record of how the contact adhesive was used. Table 4-4
summarizes the compliance demonstration requirements for facilities using contact adhesives.
TABLE 4-4. COMPLIANCE DEMONSTRATION FOR COMPLIANT
CONTACT ADHESIVES
Adhesive usage scenario
Compliance demonstration requirements
Contact adhesives are used as supplied,
that is, no additives or thinners are added
to the contact adhesive.
1. Maintain copies of certified product data
sheets; and
2. Maintain record of operation for which contact
adhesive was used.
Contact adhesives are thinned before
application
1. Maintain copies of certified product data
sheets;
2. Maintain data sheets showing contact adhesive
and thinner usage and calculation of as-applied
VHAP content; and
3. Maintain record of operation for which
adhesive was used.
4.2.2 Add-On Control Devices
The compliance demonstration requirements for facilities using an add-on control device
to reduce emissions from the use of contact adhesives are the same as those discussed in 4.1.3.
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CHAPTER 5
RECORDKEEPING AND REPORTING REQUIREMENTS
This section presents the recordkeeping and reporting requirements for facilities subject
to the NESHAP. In general, these requirements will vary according to the method the facility
chooses to use to demonstrate compliance.
5.1 RECORDKEEPING REQUIREMENTS
Because many facilities are expected to use a compliant coatings and/or contact adhesives
approach to meet the requirements of the NESHAP, maintaining complete records is particularly
important because they allow these facilities to demonstrate compliance. Therefore, many of the
recordkeeping requirements discussed in this chapter were also discussed in Chapter 4.
However, in addition to the recordkeeping requirements associated with the emission limits and
compliance options presented in Chapters 2 and 4, this chapter will also discuss recordkeeping
requirements associated with the work practice standards.
5.1.1 NESHAP Recordkeeping Requirements
The recordkeeping requirements for the NESHAP are dependent upon the option the
facility is using to demonstrate compliance. Table 5-1 summarizes the recordkeeping
requirements by compliance option for both finishing and gluing operations.
5.1.2 Recordkeeping Requirements for the NESHAP Work Practice Standards
EPA has included recordkeeping requirements to ensure facilities are implementing these
standards, because the work practice standards are considered a critical element of the NESHAP.
A summary of the recordkeeping requirements associated with the work practice standards is
included in Table 5-2.
Facilities are also required to maintain a copy of the work practice implementation plan
onsite. The work practice implementation plan should include a copy of the operator training
program, the inspection and maintenance plan, the cleaning and washoff solvent accounting
system, and the formulation assessment plan for finishing operations.
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5.2 NESHAP REPORTING REQUIREMENTS
Each wood furniture manufacturing facility should have already submitted an initial
notification report. Each facility must also submit an initial compliance status report and
semiannual continuous compliance status reports. Table 5-3 summarizes the information that
should be included in the initial compliance status report. The initial compliance status report
must be submitted no later than 60 days after the compliance date.
The first semiannual compliance status report must be submitted no later than 30 calendar
days after the end of the first 6-month period following the facility's compliance date.
Subsequent reports must be submitted no later than 30 calendar days after the end of each
6-month period. Table 5-4 summarizes the information to be included in the semiannual
compliance status reports for the NESHAP.
The semiannual continuous compliance status report must be signed by a responsible
official of the company that owns or operates the facility.
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TABLE 5-1. RECORDKEEPING REQUIREMENTS FOR THE NESHAP
Compliance option
Recordkeeping requirements
Finishing operations
Compliant coatings
Compliant coatings with continuous
coalers
Averaging
Add-on control device
Compliant coatings and control device
or averaging and control device
Certified product data sheets for each coating and thinner subject to
the emission limits presented in Chapter 2; and
The VHAP content, in Ib VHAP/lb solids, as applied, for each coating
subject to the emission limits presented in Chapter 2.
Option 1
• Same as requirements for compliant coatings. Records must
demonstrate that the VHAP content does not exceed the applicable
emission limit.
Option 2
1 . Certified product data sheet for each coating and thinner;
2. Record of all solvent and coating additions to the reservoir; and
3. All viscosity measurements.
1 . Certified product data sheets for each coating participating in
averaging;
2. Records of the amount of coating and thinner used each month;
3. Copies of the averaging calculation.
1 . Certified product data sheets for each coating;
2. Copies of calculations demonstrating equivalency of using a
control system;
3. Records of the daily average value of each continuously monitored
parameter; and
4. For facilities using a fluidized bed catalytic incinerator, records of
the pressure drop across the catalyst bed.
Maintain all records required by each individual option.
Gluing Operations
Compliant contact adhesives
Add-on control device
1 . Certified product data sheet for each contact adhesive subject to
the emission limits presented in Chapter 2;
2. If adhesives are thinned, data sheets showing contact adhesive and
thinner usage and calculation of the as applied VHAP content; and
3. Records documenting the process in which the contact adhesive
was used.
1 . Certified product data sheet for each contact adhesive subject to
the emission limits presented in Chapter 2;
2. Copies of calculations demonstrating the equivalency of using a
control system;
3. Records of the daily average value of each continuously monitored
parameter; and
4. For facilities using a fluidized bed catalytic incinerator, records of
the pressure drop across the catalyst bed.
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TABLE 5-2 RECORDKEEPING REQUIREMENTS FOR THE NESHAP WORK
PRACTICE STANDARDS
Work practice standard
Operator training program
Inspection and maintenance plan
Cleaning and washoff solvent accounting
system
Spray booth cleaning
Application equipment requirements
Formulation assessment plan for finishing
operations
Limitation on chemical composition of
cleaning/washoff solvents
Recordkeeping requirements
1 . Copy of program, including:
- a list of personnel required to be trained;
- an outline of the subjects to be covered;
- lesson plans for training courses;
2. Records documenting successful completion of the
training program for each individual; and
3. Date each individual was trained.
1 . Copies of checklists documenting visual monthly
inspection of equipment; and
2. Records demonstrating timeframe for making repairs.
1 . Record of the quantity and type of organic solvent
used each month for washoff and cleaning;
2. Record of the number of pieces washed off and the
reason why; and
3. Record of the quantity of spent solvent generated
each month by operation and whether it is recycled
onsite or disposed offsite.
VOC content of material used for cleaning spray booths.
Documentation that conventional air spray guns are only
being used as allowed, including:
• if used for applying low VOC coatings, records
showing that the VOC content is no greater than
l.OlbVOC/lb solids;
• if used for applying small quantities of finishing
materials, other than for touchup and repair, records
of total finishing materials usage and quantity applied
with air spray gun.
1 . Maintain MSDS for coatings containing VHAP of
potential concern; and
2. Maintain usage records for coatings containing
VHAP of potential concern.
Maintain MSDS for all solvents used for cleaning and/or
washoff.
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TABLE 5-3. INFORMATION TO BE INCLUDED EN ENITIAL COMPLIANCE
REPORT FOR THE NESHAP
Compliance method
Information to be included in report
Compliant coatings/contact
adhesives
Statement that the facility is using compliant coatings,
thinners, and/or contact adhesives.
Compliant coatings with
continuous coaters
1. Statement that the facility is using compliant coatings,
as determined by the VHAP content of the coating in
the reservoir and the VHAP content as calculated
from records, and compliant thinners; or
2. Statement that the facility is using compliant coatings,
as determined by the VHAP content of the coating in
the reservoir, and compliant thinners and that they are
monitoring the viscosity of the coating in the
reservoir; and
3. Data demonstrating relationship between the viscosity
of the coating in the reservoir and the VHAP content
of the coating.
Averaging (coatings only)
Results of averaging calculation for the first month,
starting the first day of the month following the
compliance date.
Add-on control device
1. Monitoring plan that identifies each operating
parameter to be monitored for the capture device; and
2. Results from initial performance test.
Compliance with work practice
standards
Statement that the facility has developed a work practice
implementation plan and has established procedures for
implementing the provisions of the plan.
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TABLE 5-4. INFORMATION TO BE INCLUDED IN THE SEMIANNUAL
COMPLIANCE STATUS REPORT FOR THE NESHAP
Compliance with emission limits
for coatings/contact adhesives
Information to be included in report
Compliant coatings and/or contact
adhesives
Statement that the facility has used compliant coatings,
thinners, and/or contact adhesives each day during the
reporting period. If noncompliant coatings, thinners, or
contact adhesives have been used during the reporting
period, the facility should identify when the
coatings/thinners/adhesives were used and the reasons
why.
Compliant coatings with
continuous coaters
1. Statement that the facility has used compliant coatings,
as determined by the VHAP content of the coating in
the reservoir and the VHAP content of the coating as
calculated from records, and compliant thinners each
day during the reporting period; or
2. Statement that the facility has used compliant coatings,
as determined by the VHAP content of the coating in
the reservoir, and compliant thinners each day in the
reporting period and that the viscosity of the coating in
the reservoir has not been less than the viscosity of the
initial coating.
Averaging (coatings only)
Results of the averaging equation for each month within
that semiannual period.
Add-on control device
Statement that the facility has not operated the capture or
control device at a daily average value greater than or less
than (as appropriate) each operating parameter value.
Compliance with work practice
standards
Statement that the work practice implementation plan is
being followed, or, if any provisions of the plan have not
been followed during the reporting period, a description
of the violation and the time period during which it
occurred.
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CHAPTER 6
EXAMPLE INSPECTION CHECKLISTS
This chapter contains example checklists that the state or local agency inspectors may use in
determining a facility's compliance status. The checklists include a summary form for recording
background information on the facility and its compliance status, a checklist for the work practice
standards, and a checklist for recording the facility's recordkeeping practices.
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NESHAP INSPECTION CHECKLIST
Applicable Rule: 40 CFR Part 63, Subpart JJ—National Emission Standards for Wood
Furniture Manufacturing Operations
Plant Name
Plant Address
City State Zip Code.
Plant Contact/Title
Plant Phone number
Owner/Operator/Title
Street Address (if different than plant's)
City Sate Zip Code
Inspection Date: / / Time:.
Indicate whether a facility is a new or existing source:
Q New source
G Existing source
Indicate the facility's compliance date: __/__/
Process Description:
INCOMPLIANCE: Y N
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NOTICE TO CORRECT:
Source signature/Title: Date:
Investigator/Title: Date:
Indicate the facility's compliance approach:
Q Compliant Coatings/ Adhesives
Compliant Coatings with continuous coalers
Averaging
Control Device
Q Combination of methods
Facility is in compliance with:
Q Emission limitations (Emission Limitation Checklist and appropriate records are enclosed)
G Work Practice Standards (Work Practice Standards and appropriate records are enclosed)
Q Recordkeeping (Recordkeeping Requirements Checklist and appropriate records are enclosed)
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WORK PRACTICE STANDARDS CHECKLIST
Application Equipment Requirement
Q The facility does not use conventional air spray guns.
Q The facility operates conventional air spray guns, but are only used:
1. If they are using the guns to apply coatings that have a VOC content no greater than 1.0 Ib
VOC/lb solids, as applied;
2. If they are using the gun for touchup and repair that occurs either after the completion of the
finishing operation or after the application of stain and before the application of other types of
finishing materials. In addition, any materials used for touchup and repair after the stain
application must be applied from a container with a volume of no more than 2.0 gallons.
3. If the guns are automatic;
4. If the guns are used in a spray booth or other application station where emission are directed to
a control device;
5. If the guns are only used for applying small quantities of finishing materials. The total amount
of finishing material applied with the conventional air spray gun must be no more than 5.0
percent of the total amount of finishing material used in that semiannual period; or
6. If the gun is used to apply stain and the facility has demonstrated that it is technically or
economically infeasible to use another spray application technology.
Operator Training Program
Q The facility has developed an operator training program that contains:
• A list of job descriptions and current personnel that must be trained;
• An outline of the subjects to be covered for each job description;
• An initial and refresher training program; and
• A description how the facility will document personnel's successful completion of the
program.
Inspection and Maintenance Plan
Q The facility has developed an inspection and maintenance plan that:
• Addresses equipment leaks;
• Includes a monthly visual inspection to ensure there are no equipment leaks of all equipment
used to transfer or apply finishing materials or organic solvents;
• Specifies how a facility will document date, result, and repairs of an inspection; and
• Assures first attempt at leak repair within 5 days and final repair within 15 days, unless repair
requires replacement of the equipment in which case the facility is allowed 3 months to
complete repairs.
Cleaning and Washoff Solvent Accounting Program
Q The facility has developed a program that tracks:
• the amount of organic solvent used for cleaning and washoff each month;
• the quantity of spent solvent generated from each cleaning or washoff operation each month;
• the amount of spent solvent that is reused or disposed; and
• the number of pieces washed off and the reason for the washoff.
Cleaning and Washoff Solvent Composition
Q The facility has discontinued the use of solvents that contains known or probable human
carcinogens. (See Appendix F for list of solvents)
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Spray Booth Cleaning
Q The facility does not use cleaning compounds that contain more than 8.0 percent VOC by weight,
unless operators are cleaning conveyors, continuous coalers and there enclosures, or metal filters.
Q The facility's solvent use is limited to 1.0 gallon per booth for preparation of booth surface for
coating/protection.
Storage Containers
Q Containers that are used for storing finishing, cleaning, adhesive, or washoff materials are closed
when not in use.
Gun and Line Cleaning
Q Gun and line cleaning solvent is collected into a closed container.
L) Containers associated with cleaning are covered when not in use.
Washoff Operations
Q Washoff tank is covered when not in use.
Q The facility minimizes dripping by tilting and/or rotating the part to drain as much solvent as
possible.
Q The facility is allowing sufficient dry time for the part.
Work Practice and Implementation Plan
G The facility has developed a plan to implement these work practice standards and maintain onsite.
Formulation Assessment Plan for Finishing Operations
Q The facility has:
• Establish a baseline level for each VHAP of potential concern
• Track annual usage VHAP of potential of concern ; and
• Reported all exceedences of baseline level, if any.
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RECORDKEEPING REQUIREMENTS CHECKLIST
Finishing operations (Check one compliance method and attach all relevant records)
Q Compliant coatings
• Certified product data sheets for each coating and thinner subject to the emission limits
presented in Chapter 2; and
• The VHAP content, in Ib VHAP/lb solids, as applied, for each coating subject to the emission
limits presented in Chapter 2.
Q Compliant coatings with continuous coalers
Option 1
• Same as requirements for compliant coatings. Records must demonstrate that the VHAP
content does not exceed the applicable emission limit.
Option 2
1. Certified product data sheets for each coating and thinner;
2. Record of all solvent and coating additions to the reservoir; and
3. All viscosity measurements.
Q Averaging
1. Certified product data sheets for each coating participating in averaging;
2. Records of the amount of coating and thinner used each month;
3. Copies of the averaging calculation.
G Add-on control device
1. Certified product data sheets for each coating;
2. Copies of the calculations demonstrating equivalency of using a control system;
3. Records of the daily average value of each continuously monitored parameter; and
4. For facilities using a fluidized bed catalytic incinerator, records of the pressure drop across the
catalyst bed.
Q Compliant coatings and control device or averaging and control device
Maintain all records required by each individual option.
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Gluing Operations
Q Compliant contact adhesives
1. Certified product data sheets for each contact adhesive subject to the emission limits presented
in Chapter 2;
2. If adhesives are thinned, data sheets showing contact adhesive and thinner usage and
calculation of the as applied VHAP content; and
3. Records documenting the process in which the contact adhesive was used.
Q Add-on control devices
1. Certified product data sheet for each contact adhesive subject to the emission limits presented
in Chapter 2;
2. Copies of calculations demonstrating the equivalency of using a control system;
3. Records of the daily average value of each continuously monitored parameter; and
4. For facilities using a fluidized bed catalytic incinerator, records of the pressure drop across the
catalyst bed.
Work Practice Recordkeeping Requirements
Q Operator training program
1. Copy of program, including:
• a list of personnel required to be trained;
• an outline of the subjects to be covered;
• lesson plans for training courses;
2. Records documenting successful completion of the training program for each individual; and
3. Records of date each individual was trained.
Q Inspection and maintenance plan
1. Copies of checklists documenting visual monthly inspection of equipment; and
2. Records demonstrating timeframe for making repairs.
3 Cleaning and washoff solvent accounting system
1. Record of the quantity and type of organic solvent used each month for washoff and cleaning;
2. Record of the number of pieces washed off and the reason why; and
3. Record of the quantity of spent solvent generated each month by operation and whether it is
recycled onsite or disposed offsite.
Q Spray booth cleaning
Records of VOC content of material used for cleaning spray booths
G Application equipment requirements
Records documenting that conventional air spray guns are only being used as allowed,
including:
if used for applying low VOC coatings, records showing that the VOC content is no
greater than 1.0 Ib VOC/lb solids;
if used for applying small quantities of finishing materials, other than for touchup and
repair, records of total finishing materials usage and quantity applied with air spray gun.
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Formulation assessment plan for finishing operations
1. The facility has maintained MSDS for coatings containing VHAP of potential concern; and
2. The facility has maintained usage records for coatings containing VHAP of potential concern.
Limitation on chemical composition of cleaning/washoff solvents
The facility has maintained MSDS for all solvents used for cleaning and/or washoff.
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CHAPTER 7
QUESTIONS ON THE WOOD FURNITURE NESHAP
Since the NESHAP was promulgated in December of 1995, both the EPA and State and
local agencies have received numerous questions concerning the applicability and requirements
' of the NESHAP. Following is a summary of those questions, and their answers, by topic area.
7.1 APPLICABILITY
To date, this topic has elicited the most questions. In general, the wood furniture
NESHAP covers facilities manufacturing residential furniture, office furniture, kitchen and
bathroom cabinets, store fixtures, contract furniture (furniture for hotels and motels), and
£ furniture for schools, churches, restaurants, and other public facilities. The NESHAP is also
applicable to facilities manufacturing component parts for these products. For example, a facility
may only manufacture drawers that they sell to residential furniture manufacturers. If the source
„ is a major source, it is subject to the requirements of the wood furniture NESHAP.
Following is a list of questions received concerning the applicability of the NESHAP and
the responses to those questions. If you have a question on applicability that is not covered here,
you should contact Bob Marshall of the Office of Enforcement and Compliance Assurance.
1. The Federal Register notice for the wood furniture NESHAP includes a list of SIC
codes that represent wood furniture manufacturers. My facility is not included under one of
those SIC codes. Are we subject to the NESHAP requirements?
The list of SIC codes in the wood furniture rule is intended only for guidance. A facility
that only manufactures component parts that are then used by a wood furniture manufacturing
facility may not operate under one of the listed SIC codes. However, they are still subject to the
wood furniture NESHAP if they are a major source. Applicability determinations are based on
the products manufactured at the facility and the facility's total HAP emissions, not on the
-facility's SIC code.
Conversely, a facility may operate under one of the SIC codes and still not be subject to
the NESHAP. For example, SIC code 2531 includes facilities manufacturing seating for planes,
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cars, and buses. Even though facilities manufacturing these products are operating under one of
the listed SIC codes, they are not subject to the requirements of the wood furniture NESHAP
because they are not manufacturing wood furniture.
2. Are facilities manufacturing hardwood flooring covered under the wood furniture
NESHAP?
No. These facilities are not subject to the wood furniture NESHAP. However, they may
be covered under the NESHAP for flatwood paneling that is currently being developed by the
EPA.
3. Are facilities manufacturing ping pong and pool tables subject to the wood furniture
NESHAP?
No. These facilities are not subject to the wood furniture NESHAP.
4. Are facilities manufacturing dowels and wood toys subject to the wood furniture
NESHAP?
No. These facilities are not subject to the wood furniture NESHAP.
5. Are facilities manufacturing caskets subject to the wood furniture NESHAP?
No. These facilities are not subject to the wood furniture NESHAP.
6. Are area sources subject to the wood furniture NESHAP?
No. Only major sources, that is, sources that emit or have the potential to emit more than
10 tons of any one HAP or 25 tons of a combination of HAP are subject to the NESHAP.
1. Are facilities that refmish furniture subject to the wood furniture NESHAP?
No. Only furniture manufacturers are subject to the wood furniture NESHAP. Facilities
that only refinish furniture are not subject to the NESHAP.
8. Are facilities that manufacture musical instruments subject to the wood furniture
NESHAP?
No. However, a few facilities manufacture pianos and residential furniture at the same
facility. If these facilities are major sources, including emissions from the piano manufacturing
process, they are subject to the NESHAP.
9. Are facilities that manufacture shutters and doors subject to the wood furniture
NESHAP?
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No. These facilities are not subject to the wood furniture NESHAP, but they may be
subject to the NESHAP for flatwood paneling manufacturers that the EPA is currently working
on.
10. Are facilities that manufacture seat cushions subject to the wood furniture NESHAP?
The EPA recently amended the wood furniture NESHAP to address this issue
(62 FR 31405). Facilities that only manufacture seat cushions are not subject to the wood
furniture NESHAP. The EPA has developed a foam fabrication NESHAP that will regulate
emissions from these facilities. However, wood furniture manufacturing facilities that
manufacture their own seat cushions, including laminating fabric to the foam base, are subject to
the NESHAP. The contact adhesives used to assemble the seat cushions are subject to an
emission limit.
11. Are facilities that manufacture kitchen cabinets subject to the wood furniture
NESHAP?
Yes. Kitchen cabinet manufacturers are subject to the wood furniture NESHAP if they
are major sources.
7.2 DETERMINING MAJOR SOURCE STATUS
The wood furniture NESHAP only applies to major sources. It does not apply to area
sources. However, because the definition of a major source is based on potential to emit it is
often difficult to determine the major source status of a facilities. According to the Census of
Manufactures, there are more than 11,000 facilities manufacturing wood furniture. The EPA
estimates there are only 750 major sources based on actual emission estimates. This means that
there are a significant number of area sources and major sources that are only major based on
their potential to emit. Taken literally, the definition of potential to emit could mean that a five
person kitchen cabinet shop could be a major source. Any facility with a spray gun has the
potential to emit 10 tons of any one HAP or 25 tons of a combination of HAP. In order to lessen
the burden on these small sources that would otherwise have to go through at least some minimal
permitting process to limit their potential to emit, the EPA included material usage and emission
limits in the NESHAP. Facilities below those limits are designated by rule as area sources and
are therefore not subject to the NESHAP. These cutoff levels are presented in Chapter 1.
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Even with the cutoff levels in the NESHAP, the EPA and State and local regulatory
agencies have received numerous questions on how a facility can determine its major source
status. These questions, and the responses, are summarized below.
1. If a facility uses materials at a rate above the cutoff level established in the NESHAP
are they automatically a major source and subject to the NESHAP?
No. A facility may use more material than the cutoff levels established in the NESHAP
and still not be subject to the NESHAP. The material usage cutoff level includes all materials,
not just those containing HAP. Some or all of the materials used by a facility may not contain
HAP so the facility's actual emissions may be significantly less than 10/25 tons/year. The
material cutoff limit is a conservative limit to reduce the burden on very small facilities.
However, many facilities may use more than this and still not be subject to the NESHAP. In
some cases, the facility may have to obtain a federally enforceable limit on their potential to emit
to avoid major source status.
2. If a facility emits more than 5 tons of any one HAP or 12.5 tons of a combination of
HAP, that is, if they emit HAP at a greater rate than the cutoff level included in the NESHAP, are
they automatically a major source and subject to the NESHAP.
No. Again, the cutoff levels are included in the NESHAP to automatically exempt the
very small facilities. Other facilities may also be exempted from the requirements of the
NESHAP, but they may nave to obtain a federally enforceable limit on their potential to emit to
avoid major source status and be exempted from the NESHAP.
3. If a facility is a major source as defined under Part 70, that is, Title V, are they subject
to the wood furniture NESHAP?
Most wood furniture facilities that are required to obtain a Title V permit will also be
major sources of HAP and will therefore be subject to the NESHAP. However, some sources are
major sources under Title V because of their VOC emissions, not their HAP emissions. If a
facility only used non-HAP VOC's, they would not be a major source of HAP emissions and
therefore would not be subject to the NESHAP. This is more likely for facilities located in severe
and extreme ozone nonattainment areas where the major source cutoff for VOC's is as low or
lower than the major source cutoff for HAP.
7.3 DEFINITIONS
It is important that both wood furniture manufacturing facilities and State and local
enforcement agencies familiarize themselves with the definitions included in the rule. For
facilities using a compliant coatings approach to comply with the rule, the definitions are
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particularly important. All coatings are not subject to an emission limit under the compliant
coatings compliance option, so the definitions are key to determining what coatings are subject to
a limit. A facility or a facility's coating supplier may have always referred to a particular coating
as a stain, but if the coating does not fit the definition of stain included in the rule it may not be
subject to an emission limit. Following is a clarification of definitions that the EPA and State
and local enforcement agencies have reported receiving questions on.
1. Are wiping stains regulated as stains under the NESHAP?
One of the major problems in determining if a particular coating is a stain as defined in
the wood furniture NESHAP is that there is inconsistency among wood furniture manufacturers
and wood furniture coating suppliers in how they have identified coatings in the past. In the
traditional long finishing sequence, used primarily by residential furniture manufacturers, the
wiping stain is applied after the washcoat and before the sealer. Typically the wiping stain is a
higher solids stain that is used in relatively small quantities. These stains are not subject to an
emission limit under the NESHAP because (1) they typically have a higher solids content than
the 8.0 percent limit specified in the NESHAP for stains, and (2) they are not applied directly to
the substrate. However, some facilities and some coating suppliers refer to the initial stain that
is applied to the substrate as a wiping stain or a wipe stain. This seems to be particularly
common in the kitchen cabinet industry. In these cases, the wiping or wipe stain is subject to an
emission limit if the solids content of the coating is no more than 8.0 percent by weight. In
general, any stain not covered by the definition of stain in the NESHAP should not be a major
source of emissions, particularly when compared to the emissions from the major coatings, that
is, stain, washcoat, sealer, topcoat, primer, and enamel.
2. Are highlight stains regulated as stains under the NESHAP?
No. Highlight stains are typically applied after the washcoat. They do meet part of the
definition of stain because they usually have a fairly low solids content, but they are not applied
directly to the substrate. Again, usage of highlight stains and emissions from these stains should
be minimal in comparison to the primary coatings used by the facility.
3. What is a certified product data sheet? Is it the same as a material safety data sheet?
The certified product data sheet (CPDS) is the primary method of demonstrating
compliance with the coating and adhesive emission limits included in the rule. For facilities
using a compliant coatings approach to comply with the rule, the CPDS are the .only
recordkeeping requirement. The CPDS will typically be supplied by your coating or adhesive
supplier. The CPDS must include the total VHAP content of the material, by percent weight, the
solids content, by percent weight, and the density of the coating. The material safety data sheet
(MSDS) is required by OSHA, so that facility employees will know what compounds they are
being exposed to and the quantities of those compounds. Unlike a material safety data sheet
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(MSDS), the CPDS does not have to list the components in the coating. The CPDS only has to
provide the total VHAP content. Facilities cannot use a MSDS to demonstrate compliance with
the emission limits. They must have a CPDS for each coating.
4. What is the difference between a conventional air spray gun and a high volume low
pressure spray (HVLP) spray gun?
A conventional air spray gun uses high pressure air to deliver the coating to the
substrate. An HVLP gun also uses pressure to deliver the coating to the substrate, but the
pressure is regulated to Wpsi or less. If a facility is operating an HVLP gun at greater than 10
psi, they are effectively using an HVLP gun as a conventional air spray gun and are likely in
violation of the work practice standards limiting the use of HVLP guns.
7.4 COATING EMISSION LIMITS AND COMPLIANCE OPTIONS
Most facilities are expected to meet the coating emission limits using either compliant
coatings or an averaging approach. The emission limits are based on the pounds of volatile HAP
emitted/pound of solids used (Ib VHAP/lb solids), as applied. Example calculations for
determining the Ib VHAP/lb solids of a coating are included in an earlier chapter. As discussed
earlier, the NESHAP only limits the VHAP content of the primary coatings for facilities using a
compliant coatings approach. Low usage coatings such as fillers and highlight stains are not
subject to an emission limit. Facilities using an averaging approach must include all of the
coatings they use in the averaging equation.
1. How does a facility demonstrate compliance if they are using the compliant coatings
compliance option?
The facility must maintain a certified product data sheet for each coating subject to an
emission limit. The facility should also maintain a CPDS for each thinner that is added to any of
these coatings. The thinners cannot contain more than 10.0 percent HAP by weight. The facility
does not have to maintain records of thinner usage, however. Any coating sample taken by State
or local agency enforcement personnel should have a VHAP content of no more than 1.0 Ib
VHAP/lb solids (0.8 for new sources) and any thinner sample should have a VHAP content of no
more than 10.0percent by weight.
2. What does "as applied" mean?
The NESHAP limits the VHAP content of the coating as applied. For facilities using a
compliant coatings approach, this means that the VHAP content of the coating should not exceed
1.0 Ib/lb solids (0.8 for new sources) after thinners, catalysts, drying agents, etc. have been
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added. The coating that is leaving the spray gun and being applied to the substrate should not
exceed 1.0 (0.8). For facilities using an averaging approach, this means that the VHAP
contribution from all thinners, catalysts, etc. should be included in the averaging equation.
3. How does a facility demonstrate compliance if they are using an averaging approach?
The facility must maintain certified product data sheets for every coating and thinner
they use. They must also maintain usage records for each coating and thinner. Using the Ib
VHAP/lb solids value for each coating, the VHAP content for each thinner, and the usage values,
the facility should use the averaging equation presented in the rule to calculate the average Ib
VHAP/lb solids each month. This should be no more than 1.0 for existing sources or 0.8 for new
sources.
4. Is there a limit on the VHAP content of the thinners if the facility is using an averaging
approach to comply with the rule?
No. The facility can use any thinners they wish if they are using an averaging approach
to comply with the rule. There is no limit on the VHAP content of the thinners.
5. What about washcoats?
The NESHAP includes two compliance options for facilities that use washcoats and a
compliant coatings approach to comply with the rule. These options were included to minimize
the recordkeeping burden on the industry. The first compliance option is the same as that for the
other coatings in a compliant coatings approach. The facility must use a washcoat that emits no
more than 1.0 Ib VHAP/lb solids (0.8 for new sources), as applied, and any thinners used to thin
the washcoat must have a VHAP content of no more than 10.0 percent by weight. If enforcement
personnel take a sample of the washcoat for analysis, the VHAP content of the washcoat should
be no more than 1.0 Ib VHAP/lb solids (0.8 for new sources). If the analysis indicates the VHAP
content is greater than 1.0 (0.8), the facility is out of compliance.
The first compliance option applies to facilities that purchase their washcoats from a
supplier. However, many wood furniture manufacturing facilities formulate their washcoat
onsite by diluting their sealer. These facilities can demonstrate compliance with the washcoat
emission limit by using a sealer that emits no more than 1.0 Ib VHAP/lb solids, maintaining a
CPDSfor the sealer, using a thinner to dilute the sealer than contains no more than 3.0 percent
VHAP by weight, and maintaining a CPDSfor the thinner. The washcoat is automatically
deemed compliant if the sealer has a VHAP content of no more than 1.0 (0.8) and the thinner
used to dilute the sealer has a VHAP content of no more than 3.0 percent by weight. Even if an
analysis of the sample reveals that the actual VHAP content of the washcoat is greater than 1.0
(0.8), the washcoat is still considered compliant because it was formulated with a compliant
sealer and a compliant (less than 3.0 percent VHAP by weight) thinner.
6. Are aerosol spray paints used for touchup and repair subject to an emission limit?
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No. There is no emission limit for aerosol spray paints that are used for touchup and
repair.
1. Are inks subject to an emission limit under the wood furniture NESHAP?
Inks are considered coatings under the wood furniture NESHAP. However, they are not
one of the primary coatings used by the industry, so they are not subject to an emission limit for
facilities using a compliant coatings approach. However, facilities using an averaging approach
to comply with the rule must include the inks in the averaging equation.
8. If inks are applied to the wood furniture over the topcoat (that is, after completion of
the coating operation) do they fall under the VHAP restrictions for coatings?
As discussed in the previous question, inks are considered coatings. However, there is no
limit on the VHAP content of the inks for facilities using a compliant coatings approach no
matter where the ink is applied in the finishing process. If the facility is using an averaging
approach to comply with the rule, the inks must be included in the averaging equation even if
they are applied over the topcoat.
9. According to 40 CFR 63.804(g)(i), a facility using a continuous coater can comply
with the regulations by using compliant coatings, as determined by the VHAP content of the
coating in the reservoir and the VHAP content determined from records. Can this method be
used to comply if additional solvent is added to the coating in the reservoir to replace the solvent
lost due to evaporation, or must the facility use viscosity measurements to comply as outlined in
63.804(g)(ii)? Would this also pertain to coatings not used in continuous coaters, that is, dip
tanks or pressure pots?
If a facility adds solvent to the continuous coater to replace that lost by evaporation, the
facility can use one of two methods to determine compliance. For both compliance options, the
VHAP content of the coating in the reservoir should never exceed 1.0 Ib VHAP/lb solids, even
after solvent additions. In addition, the facility must demonstrate one of two things. The facility
must always maintain records, including the records showing solvent additions, that demonstrate
that the coating has a VHAP content of no more than 1.0 Ib VHAP/lb solids, as applied; or the
facility must measure the viscosity of the initial coating in the reservoir and each time solvent is
added to the reservoir. The facility must maintain records of the viscosity measurements. If the
viscosity of the coating falls below the viscosity of the initial viscosity of the coating, the facility
is out of compliance.
These two compliance options do not apply to coatings used in dip tanks or pressure pots.
The VHAP content of these coatings, as determined by a sample of the coating, should not
exceed 1.0 Ib VHAP/lb solids, and the records, including records of solvent additions, should
demonstrate that the VHAP content of the coating never exceeded 1.0 Ib VHAP/lb solids. There
is no option in this case of monitoring the viscosity of the coating in lieu of having the records
demonstrate compliance with the emission limit.
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7.5 ADHESIVE EMISSION LIMITS AND COMPLIANCE OPTIONS
1. Is there an emission limit on adhesives other than contact adhesives?
No. The only adhesives subject to an emission limit are contact adhesives. The industry
also uses urea-formaldehyde, polyvinyl acetate, and hot melt adhesives, but none of these
adhesive types are subject to an emission limit. Hot melt adhesives are 100 percent solids
adhesives so they do not emit VHAP. Polyvinyl acetate adhesives do emit small quantities of the
HAP vinyl acetate, but they are lower emitting than the other types of adhesives so the EPA did
not want to discourage their usage by placing an emission limit on them. Urea-formaldehyde
emissions do emit formaldehyde, but they are primarily used for veneering and plywood
manufacturing. These operations will be covered under the particleboard/plywood
manufacturing NESHAP.
2. Can a facility average among their contact adhesives to meet the emission limit?
No. All contact adhesives must be compliant. A facility cannot average among their
contact adhesives to meet the limit.
7.6 WORK PRACTICE STANDARDS
The wood furniture NESHAP includes work practice standards for reducing emissions
from cleaning, washoff, finishing, and gluing operations. These work practice standards are an
important part of the rule. For the most part, the work practice standards are straightforward, but
the EPA has received a few questions concerning the requirements. Following is a summary of
these questions and their responses.
1. Does the limitation on conventional air spray guns also apply to spray guns used to
apply adhesives?
No. The limitation only applies to spray guns used to apply finishing materials. Any type
of spray gun may be used to apply adhesives.
2. What is a normally closed container?
The NESHAP requires all containers used to store solvent or solvent containing
materials to be closed when not in use. These containers are referred to as normally closed
containers. They are containers that should be closed during most periods, but they may be open
if an operator is filling or emptying the container.
3. How do I determine the de minimis levels for the VHAP of potential concern included
in Table 6?
In developing the formulation assessment plan, the EPA worked with the coating
suppliers to identify VHAP of potential concern that are currently used by industry. The EPA
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then developed de minimis values for these VHAP based on 70-year exposure levels. These
VHAP and their de minimis values are included in Table 5. However, industry may use VHAP of
potential concern that are identified in Table 6 but are not listed in Table 5. If a facility uses any
of these pollutant after November of 1998, the baseline level is equivalent to the de minimis level.
The rule states that the de minimis level should be based on 70 year exposure levels and data
provided in the rulemaking pursuant to Section 112(g). However, the final Section 112(g)
rulemaking did not include these de minimis values. The EPA is currently addressing litigation
issues related to the formulation assessment plan. A Federal Register notice addressing any
changes in the formulation assessment plan resulting from the litigation is expected in late fall of
1997. The EPA will include de minimis levels for the pollutants in Table 6 in that notice.
4. Do the VHAP of potential concern found in inks fall under the formulation assessment
plan requirements?
Yes. The inks are considered coatings so any VHAP of potential concern that are in the
inks must be tracked under the formulation assessment plan.
5. Section 63.803(b)(4) dictates that a facility maintain a description of the methods used
to demonstrate successful completion of the operator training course. What will be the definition
of successful completion?
Whether or not an operator has successfully completed the training course will be up to
the facility for the most part. If an operator is still not applying coatings correctly after training,
the facility is the one that will pay in extra coating costs. However^ the facility should maintain
records documenting that the operator has completed the training. For example, the facility may
present each operator with a certificate that is signed by both the facility and the operator upon
the completion of training. An inspector may ask to see the records and may also observe the
operator to ensure he or she is following the work practice standards and is using proper
application techniques.
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APPENDIX A
ACRONYMS AND DEFINITIONS
A.I LIST OF ACRONYMS
Following is a list of acronyms that are used throughout the manual. Many of these terms
are included in the definitions in A.2, but the list presented here is intended to serve as a handy
reference if you come across an acronym you are not familiar with. Some of these acronyms are
not used in this manual, but you may come across them when studying other material related to
the control of VOC and/or HAP emissions.
Acronym Meaning
BACT Best available control technology
CFR Code of Federal Regulations
CPDS Certified product data sheet
CTG Control Techniques Guideline
EPA Environmental Protection Agency
FAP Formulation assessment plan
HAP Hazardous air pollutant
HVLP High volume low pressure
LAER Lowest achievable emission rate
MACT Maximum Achievable Control Technology
MSDS Material safety data sheet
NESHAP National Emission Standards for Hazardous Air Pollutants
NSPS New Source Performance Standards
NSR New Source Review
RACT Reasonably Available Control Technology
SIP State implementation plan
VHAP Volatile hazardous air pollutant
VOC Volatile organic compound
A.2 DEFINITIONS
These definitions are from commonly used terms in this document. However, it is not an
exhaustive list. The list is limited to terms that are used in this implementation manual. Note
that these definitions are based on EPA's definitions, which may not always be consistent with
the industry's definitions. Because the standards are based on EPA's definitions, however, those
are the definitions included here.
Adhesive means any chemical substance that is applied for the purpose of bonding two
surfaces together other than by mechanical means. For the purposes of the wood furniture
NESHAP, adhesives are not considered coatings or finishing materials. Products used on
numans and animals, adhesive tape, contact paper, or any other product with an adhesive
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incorporated onto or in an inert substance are not considered adhesives under the wood furniture
NESHAP.
Aerosol adhesive means a contact adhesive that is dispensed from a pressurized container
as a suspension of fine solid or liquid particles in gas.
As applied means the VOC, VHAP, and solids content of the coating or contact adhesive
that is actually used for coating or gluing the substrate. It includes the contribution of materials
used for in-house dilution of the coating or contact adhesive.
Basecoat means a coat of colored material, usually opaque, that is applied before graining
inks, glazing coats, or other opaque finishing materials, and is usually topcoated for protection.
Capture device means a hood, enclosed room, floor sweep, or other means of collecting
solvent emissions or other pollutants into a duct so that the pollutant can be directed to a
pollution control device such as an oxidizer or carbon adsorber.
Capture efficiency means the fraction of all organic vapors generated by a process that are
directed to a control device.
Certified product data sheet (CPDS) means documentation furnished by coating or
adhesive suppliers or an outside laboratory that provides the VHAP content, VOC content, solids
content, and density of a finishing material, contact adhesive, or solvent. The VHAP content
should be measured by EPA Method 311, an equivalent or alternative method, or formulation
data if all HAP present in the coating or contact adhesive is solvent. The reportable HAP content
should represent the maximum aggregate emissions potential of the finishing material, contact
adhesive or solvent in concentrations greater than or equal to 1.0 percent by weight or 0.1 percent
for HAP that are carcinogens, as defined by the Occupational Safety and Health Administration
Hazard Communication Standard (29 CFR 1910), as formulated. The VOC content, solids
content, and density of the coating or contact adhesive should be measured by EPA Method 24,
an alternative or equivalent method, or formulation data if all of the VOC present in the coating
or contact adhesive is solvent. The purpose of the CPDS is to assist the facility in demonstrating
compliance with the NESHAP emission limits.
(Note: Because the optimum analytical conditions under EPA Method 311 vary by
coating, the coating or adhesive supplier may also choose to include on the CPDS the optimum
analytical conditions for analysis of the coating, adhesive, or solvent using EPA Method 311.
Such information may include, but not be limited to, separation column, oven temperature,
carrier gas, injection port temperature, extraction solvent, and internal standard.)
Cleaning operations means operations in which organic solvent is used to remove coating
materials or adhesives from equipment used in wood furniture manufacturing operations.
Coating means a protective, decorative, or functional film applied in a thin layer to a
surface. Such materials include, but are not limited to, paints, topcoats, varnishes, sealers, stains,
A-2
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washcoats. basecoats, enamels, inks, and temporary protective coatings. Aerosol spray paints
used for touch-up and repair are not considered coatings under the NESHAP.
Coating solids (or solids) means the part of the coating which remains after the coating is
dried or cured; solids content is determined using data from EPA Method 24.
Compliant coating/contact adhesive means a finishing material, contact adhesive, or
strippable booth coating that meets the CTG and/or NESHAP emission limits specified in Tables
2-2 and 2-4 of this manual.
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 is sufficiently
strong to hold pieces together without further clamping, pressure, or airing.
Continuous coater means a finishing system that continuously applies finishing materials
onto furniture parts moving along a conveyor. Finishing materials that are not transferred to the
part are recycled to a reservoir. Several types of application methods can be used with a
continuous coater including spraying, curtain coating, roll coating, dip coating, and flow coating.
Control device (also referred to as an add-on control device in this manual) 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. Includes, but is not limited to, oxidizers,
carbon adsorbers, and condensers.
Control device efficiency means the ratio of the pollution released by a control device to
the pollution introduced to the control device.
Control system means the combination of capture and control devices used to reduce
emissions to the atmosphere.
Conventional air spray means a spray coating method in which the coating is atomized by
mixing it with compressed air and applied at an air pressure greater than 10 pounds per square
inch (gauge) at the point of atomization. Airless and air assisted airless spray technologies are
not conventional air spray because the coating is not atomized by mixing it with compressed air.
Electrostatic spray technology is also not considered conventional air spray because an
electrostatic charge is employed to attract the coating to the workpiece.
Emission means the release or discharge, whether directly or indirectly, of HAP into the
ambient air.
Enamel means a coat of colored material, usually opaque, that is applied as a protective
topcoat over a basecoat, primer, or previously applied enamel coats. In some cases, another
finishing material may be applied as a topcoat over the enamel.
A-3
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Equipment leak means emissions of VHAP from pumps, valves, flanges, or other
equipment used to transfer or apply coatings, adhesives, or organic solvents.
Finishing material means a coating used in the wood furniture industry. Such materials
include, but are not limited to, stains, basecoats, washcoats, enamels, sealers, and topcoats.
Finishing operation means those operations in which finishing material is applied to a
substrate and is subsequently air-dried, cured in an oven, or cured by radiation.
Foam adhesive means a contact adhesive used for gluing foam to fabric, foam to foam,
and fabric to wood.
Gluing operation means those operations in which contact adhesives are used to join
components, for example, to apply a laminate to a wood substrate or foam to fabric.
Incidental wood furniture manufacturer means a major source that is primarily engaged in
the manufacture of products other than wood furniture or wood furniture components and uses no
more than 100 gallons per month of finishing material or adhesives in the manufacture of wood
furniture or wood furniture components.
Material Safety Data Sheet (MSDS) means the documentation required for hazardous
chemicals by the Occupational Safety and Health Adminstration (OS HA) Hazard
Communication Standard (29 CFR 1910) for a solvent, cleaning material, contact adhesive,
coating, or other material that identifies select reportable hazardous ingredients of the material,
safety and health considerations, and handling procedures.
Nonporous substrate means a surface that is impermeable to liquids. Examples include
metal, rigid plastic, flexible vinyl, and rubber.
Organic solvent means a volatile organic liquid that is used for dissolving or dispersing
constituents in a coating, adjusting the viscosity of a coating or adhesive, or cleaning equipment.
When used in a coating or adhesive, the organic solvent evaporates during drying and does not
become a part of the dried film.
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.
Potential to emit means the maximum capacity of a stationary source to emit a pollutant
under its physical and operational design.
Research or laboratory facility means any stationary source whose primary purpose is to
conduct research and development to develop new processes and products where such source is
operated under the chose supervision of technically trained personnel and is not engaged in the
manufacture of products for commercial sale in commerce, except in a de minimis manner.
A-4
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Sealer means a finishing material used to seal the pores of a wood substrate before
additional coats of finishing material are applied. Special purpose finishing materials that are
used in some finishing systems to optimize aesthetics are not sealers.
Solvent means a liquid used in a coating or contact adhesive to dissolve or disperse
constituents and/or to adjust viscosity. It evaporates during drying and does not become a part of
the dried film.
Stain means any color coat having a solids content by weight of no more than 8.0 percent
that is applied in single or multiple coats directly to the substrate. Includes, but is not limited to,
nongrain raising stains, equalizer stains, prestains, sap stains, body stains, no-wipe stains,
penetrating stains, and toners.
Strippable spray booth coating means a coating that (1) is applied to a spray booth wall to
provide a protective film to receive overspray during the finishing operations; (2) that is
subsequently peeled off and disposed; and (3) by achieving (1) and (2) reduces or eliminates the
need to use organic solvents to clean spray booth walls.
Substrate means the surface onto which a coating or contact adhesive is applied (or into
which a coating or contact adhesive is impregnated).
Thinner means a volatile liquid that is used to dilute coatings or contact adhesives (to
reduce viscosity, color strength, and solids, or to modify drying conditions).
Topcoat means the last film-building finishing material that is applied in a finishing
system.
Touch-up and repair means the application of finishing materials to cover minor finishing
imperfections.
VHAP means any hazardous air pollutant listed in Table E-1.
VHAP of potential concern means any VHAP from the list presented in Table A-1.
Volatile organic compound (VOC) means any organic compound that participates in
atmospheric photochemical reactions, that is, any organic compound other than those that the
Administrator designates as having negligible photochemical reactivity. A VOC may be
measured by a reference method, an equivalent method, an alternative method, or by procedures
specified in any rule. However, these methods may also measure nonreactive organic
compounds. In such cases, the owner or operator may exclude the nonreactive organic
compounds when determining compliance with a standard. For a list of compounds that the
-Administrator has designated as having negligible photochemical reactivity, refer to 40 CFR
51.00.
A-5
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Washcoat means a transparent special purpose finishing material having a solids content
by weight of 12.0 percent or less. Washcoats are applied over initial stains to protect, to control
color, and to stiffen the wood fibers in order to aid sanding.
Washoff operations means those operations in which organic solvent is used to remove
coating from wood furniture or a wood furniture component.
Wood furniture means any product made of wood, a wood product such as rattan or
wicker, or an engineered wood product such as particleboard that is manufactured under any of
the following standard industrial classification codes: 2434, 2511, 2512, 2517, 2519, 2521
2531, 2541, 2599, or 5712.
Wood furniture component means any part that is used in the manufacture of wood
furniture. Examples include, but are not limited to, drawer sides, cabinet doors, seat cushions,
and laminated tops. However, foam seat cushions manufactured and fabricated at a facility that
does not engage in any other wood furniture or wood furniture component manufacturing
operation are excluded from this definition.
Wood furniture manufacturing operations means the finishing, gluing, cleaning, and
washoff operations associated with the production of wood furniture or wood furniture
components.
A-6
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TABLE A-1. VHAP OF POTENTIAL CONCERN
CAS No.
Chemical name
"NONTHRESHOLD" POLLUTANTS
92671
96093
64675
59892
68122
80319
60355
101779
90040
1746016
92875
684935
542881
79447
75558
57147
96128
62759
50328
1336363
76448
119937
79061
118741
57749
1120714
106990
53963
53963
58899
95807
111444
122667
8001352
121142
119904
50000
4-Aminobiphenyl
Styrene oxide
Diethyl sulfate
N-Nitrosomorpholine
Dimethyl formamide
Hexamethy Iphosphoramide
Acetamide
4,4'- Methylenediani line
o-Anisidine
2,3,7. 8-Tetrachlorodibenzo-p-dioxm
Benzidine
N-Nitroso-N-methylurea
Bis(chloromethyl)ether
Dimethyl carbamoyl chloride
1 ,2-Propylenimine (2-Methyl aziridine)
1 , 1 -Dimethyl hydrazine
1 ,2-Dibromo-3-chloropropane
N-Nitrosodimethylamine
Benzo (a) pyrene
Polychlorinated biphenyls (Aroclors)
Heptachlor
3.3'-Dimethyl benzidine
Acrylamide
Hexachlorobenzene
Chlordane
1 ,3-Propane sultone
1 ,3-Butadiene
2-Acetylaminoflourine
3,3'-Dichlorobenzidine
Lindane (hexachlorcyclohexane, gamma)
2,4-Toluene diamine
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1 ,2 - Diphenylhydrazine
Toxaphene (chlorinated camphene)
2,4-Dinitrotoluene
3,3'-Dimethoxybenzidine
Formaldehyde
A-7
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TABLE A-1. (continued)
CAS No.
101144
107131
106934
72559
510156
62737
75014
75218
96457
593602
67663
87865
51796
107062
78875
56235
71432
140885
75569
62533
106467
88062
117817
95534
114261
79016
123911
75070
75252
133062
106898
75092
127184
53703
218019
60117
56553
205992
Chemical name
4,4'-Methylene bis(2-chloroaniline)
Acrylonitrile
Ethylene dibromide( 1 ,2-Dibromoethane)
DDE (1,1-p-chlorophenyl 1-2 dichloroethylene)
Chlorobenzilate
Dichlorvos
Vinyl chloride
Ethylene oxide
Ethylene thiourea
Vinyl bromide (bromoethene)
Chloroform
Pentachlorophenol
Ethyl carbamate (Urethane)
Ethylene dichloride (1,2-Dichloroethane)
Propylene dichloride ( 1 ,2-Dichloropropane)
Carbon tetrachloride
Benzene
Ethyl acrylate
Propylene oxide
Aniline
l,4-Dichlorobenzene(p)
2,4.6-Trichlorophenol
Bis(2-ethylhexyl)phthalate (DEHP)
o-Toluidine
Propoxur
Trichloroethylene
1,4-Dioxane (1,4-Diethyleneoxide)
Acetaldehyde
Bromoform
Captan
Epichlorohydrin
Methylene chloride (Dichloromethane)
Tetrachloroethylene(Perchloroethylene)
Dibenz (ah) anthracene
Chrysene
Dimethyl aminoazobenzene
Benzo (a) anthracene
Benzo (b) fluoranthene
A-8
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TABLE A-1. (continued)
CAS No.
79469
542756
57976
225514
193395
189559
79345
91225
75354
87683
82688
78591
79005
74873
67721
1582098
1319773
108394
75343
95487
106445
74884
100425
107051
334883
95954
133904
106887
108054
126998
123319
92933
Chemical name
2-Nitropropane
1 ,3-Dichloropropene
7, 12-Dimethylbenz(a)anthracene
Benz(c)acridine
Indeno( 1 ,2.3-cd)pyrene
l,2:7,8-Dibenzopyrene
1 , 1 ,2,2-Tetrachloroethane
Quinoline
Vinylidene chloride (1,1-Dichloroethylene)
Hexachlorobutadiene
Pentachloronitrobenzene (Quintobenzene)
Isophorone
1 , 1 ,2-Trichloroethane
Methyl chloride (Chloromethane)
Hexachloroethane
Trifluralin
Cresols/Cresylic acid (isomers and mixture)
m-Cresol
Ethylidene dichloride (1,1-Dichloroethane)
o-Cresol
p-Cresol
Methyl iodide (lodomethane)
Styrenea
Allyl chloride
Diazomethane
2,4,5 - Trichlorophenol
Chloramben
1,2 - Epoxybutane
Vinyl acetate
Chloroprene
Hydroqumone
4-Nitrobiphenyl
A-9
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TABLEA-1. (continued)
CAS No.
Chemical name
"HIGH-CONCERN" POLLUTANTS
56382
13463393
60344
75218
151564
77781
107302
57578
100447
98077
107028
584849
75741
78002
12108133
624839
77474
62207765
10210681
79118
534521
101688
108952
62384
98862
108316
532274
51285
108864
98953
74839
75150
121697
Parathion
Nickel Carbonyl
Methyl hydrazine
Ethylene oxide
Ethylene imine
Dimethyl sulfate
Chloromethyl methyl ether
beta-Propiolactone
Benzyl chloride
Benzotrichloride
Acrolein
2,4 - Toluene diisocyanate
Tetramethyl lead
Tetraethyl lead
Methylcyclopentadienyl manganese
Methyl isocyanate
Hexachlorocyclopentadiene
Fluomine
Cobalt carbonyl
Chloroacetic acid
4.6-Dinitro-o-cresol, and salts
Methylene diphenyl diisocyanate
Phenol
Mercury, (acetato-o) phenyl
Acetophenone
Maleic anhvdnde
2-Chloroacetophenone
2,4-Dinitrophenol
2-Methyoxy ethanol
Nitrobenzene
Methyl bromide (Bromomethane)
Carbon disulfide
N.N-Dimethylaniline
A-10
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TABLE A-1. (continued)
CAS No.
Chemical name
"UNRANKABLE" POLLUTANTS
106514
123386
120809
85449
463581
132649
100027
540841
11422
822060
-
-
Quinone
Propionaldehyde
Catechol
Phthalic anhydride
Carbonyl sulfide
Dibenzofurans
4-Nitrophenol
2,2,4-Trimethylpentane
Diethanolamine
Hexamethylene- 1 ,6-diisocyanate
Glycol ethersb
Polycyclic organic matter0
* = Currently an EPA weight of evidence classification is under review
aThe EPA does not currently have an official weight-of-evidence classification for
styrene. For purposes of this rule, styrene is treated as a "nonthreshold"
pollutant. (See data report form in appendix A of the hazard ranking technical
background document.)
^Except for 2-ethoxy ethanol, ethylene glycol monobutyl ether, and 2-methoxy
ethanol.
°Except for benzo(b)fluoranthene, benzo(a)anthracene, benzo(a)pyrene,
7,12-dimethylbenz(a)anthracene, benz(c)acridine, chrysene, dibenz(ah)
anthracene, l,2:7,8-dibenzopyrene, indeno(l,2,3-cd)pyrene, but including dioxins
and furans.
A-ll
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APPENDIX B.
LIST OF CONTACTS
This appendix includes a listing of State, EPA, and industry contacts.
B.I STATE CONTACTS
Table B-1 is a list of State agencies. In some cases, you may need to work with a local
agency, but the State agency will be able to refer you to the local agency if necessary. If you are
a small business, they can also refer you to the State's Small Business Ombudsman and/or the
State Small Business Assistance Program.
TABLE B-l. LISTING OF STATE AGENCIES
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Name of Agency
Alabama Department of Environmental Management, Air Division
Department of Environmental Conservation
Office of Air Quality
Department of Pollution Control and Ecology
Air Resources Board
Department of Health, Air Pollution Control Division
Air Management Bureau
Department of Natural Resources and Environmental Control,
Division of Air and Waste Management
Department of Environmental Protection
Air Protection Branch
Clean Air Branch
Department of Health and Welfare, Division of Environmental
Quality
Environmental Protection Agency, Division of Air Pollution Control
Department of Environmental Management
Department of Natural Resources
Bureau of Air and Radiation
Division for Air Quality
Department of Environmental Quality, Office of Air Quality and
Radiation Protection
Bureau of Air Quality Control, Department of Environmental
Protection
Air & Radiation Management Administration
Division of Air Quality Control
Air Quality Division, Department of Natural Resources
Phone No.
(205)271-7861
(907)465-5100
(602) 207-2308
(501)562-7444
(916)322-2990
(303)692-3100
(203) 566-2690
(302) 739-4764
(904)488-0114
(404) 363-7000
(808) 586-4200
(208) 334-0502
(217)782-7326
(317)232-8222
(515)281-5145
(913)296-1593
(502) 564-3382
(504)765-0219
(207) 289-2437
(410)631-3255
(617)292-5593
(517)373-7023
B-l
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State
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Name of Agency
Air Pollution Control. Pollution Control Agency
Department of Environmental Quality
Department of Natural Resources/Air Pollution Control Program
State Department of Health and Environmental Sciences
Air Quality Program, Department of Environmental Quality
Bureau of Air Quality/Division of Environmental Protection
Department of Environmental Services, Air Resources Division
Department of Environmental Protection and Energy, Air Pollution
Control Program
Environmental Department/ Air Quality Bureau
Department of Environmental Conservation, Division of Air
Resources
Division of Environmental Management
State Department of Health
Ohio Environmental Protection Agency
Department Environmental Quality/ Air Quality Division
Air Quality Division, Department of Environmental Quality
Department of Environmental Resources, Bureau of Air Quality
Division of Air Resources
Department of Health and Environmental Control, Bureau of Air
Quality
Department of Environment and Natural Resources, Division of
Environmental Regulation
Tennessee Division of Air Pollution Control
Texas Natural Resources Conservation Commission
Division of Air Quality, Department of Environmental Quality
Air Pollution Control Division, Agency of Natural Resources
Department of Air Pollution Control
State Department of Ecology
Air Pollution Control Commission
Department of Natural Resources, Bureau of Air Management
Air Quality Division, Department of Environmental Quality
Phone No.
(612)296-7331
(601)961-5171
(314)751-4817
(406) 444-3454
(402)471-2189
(702) 687-4670
(603)271-1370
(609) 292-6704
(505) 827-2850
(518)457-7230
(919)733-3340
(701)221-5188
(614) 644-2270
(405)271-5220
(503) 229-5359
(717)787-9702
(401)277-2808
(803) 734-4750
(605)773-3351
(615)532-0554
(512)451-5711
(801)536-4000
(802)244-8731
(804) 786-2378
(206) 459-6256
(304) 348-4022
(608)266-7718
(307)777-7391
B.2 EPA CONTACTS
If you have questions for EPA, the best place to start is the EPA regional office for your
State. They will either be able to answer your questions or refer you to someone who can. Table
B-2
-------
B-2 includes a list of the EPA regions, the States they cover, and their telephone number and
location.
TABLE B-2. EPA REGIONS
Region
1
2
3
4
5
6
7
8
Phone No.
(617) 565-3595
(212)637-4023
(215)566-2114
(404)562-9131
(312)886-6793
(214)665-2156
(913)551-7566
(303)312-6971
States covered
CT, ME, MA, NH, RI,
VT
NJ,NY
DE, MD, PA, VA, WV
& District of Columbia
AL, FL, GA, KY, MS,
NC, SC, TN
IL, IN, MI, WI, MN &
OH
AR, LA, NM, OK, &
TX
IA, KS, MO, NE
CO, MT, ND, SD, UT,
WY
Address
Janet Bowen
Air Toxics Coordinator
J.F.K. Federal Bldg.
One Congress Street
Boston, MA 02203
Umesh Dholakia
Air Toxics Coordinator
290 Broadway Street
New York, NY 10007-1866
Dianne Walker
Air Toxics Coordinator
841 Chestnut Bldg.
Philadelphia, PA 19107
Lee Page
Air Toxics Coordinator
Atlanta Federal Center
61 Forsyth Street SW
Atlanta, GA 30303-3 104
Bruce Varner
Air Toxics Coordinator
77 West Jackson Blvd.
Chicago, IL 60604-3507
Robert Todd
Air Toxics Coordinator
1445 Ross Avenue
12th Floor, Suite 1200
Dallas, TX 75202-2733
Richard Tripp
Air Toxics Coordinator
726 Minnesota Avenue
Kansas City, KS 66 101
Heather Rooney
Air Toxics Coordinator
999 18th Street
Suite 500
Denver, CO 80202-2466
B-3
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Region
9
10
Phone No.
(415)744-1200
(206) 553-8760
States covered
AZ, CA, HI, NV
AK, ID, WA, OR
Address
Air Division
75 Hawthorne Street
San Francisco, CA 94105
Andrea Longhouse
Air Toxics Coordinator
Atlanta Federal Center
1200 Sixth Avenue
Seattle, W A 98 101
B-4
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B.3 TRADE ASSOCIATIONS
Following is a list of contacts from the major trade associations representing the wood
furniture industry and wood furniture coating suppliers.
American Furniture Manufacturers Association
P.O. Box HP-7
High Point, NC 27261
Phone:(910)884-5000
Business and Institutional Furniture Manufacturers Association
2680 Horizon Drive S.E.
Grand Rapids, MI 49546
Phone:(616)285-3963
Grand Rapids Area Furniture Manufacturers Association
4362 Cascade Road, S.E., Suite 113
Grand Rapids, MI 49506
Phone: (616) 942-6225 Fax: (616) 942-1730
Kitchen Cabinet Manufacturers Association
1899 Preston White Drive
Reston, VA 22091-4326
Phone: (703) 264-1690
National Paint and Coatings Association
1500 Rhode Island Avenue, NW
Washington, DC 20005
Phone: (202) 462-6272
B-5
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APPENDIX C.
DETAILED TABLE OF CONTENTS FOR THE NESHAP
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Although we hope that this manual will answer most of the your questions concerning the
NESHAP, there may still be times when you will have to go directly to the regulation for the
answer to specific questions. Hopefully, the table of contents presented in Table C-1 will make
the search easier.
TABLE C-1. NESHAP TABLE OF CONTENTS
Requirement
Location in Regulation
Applicability
Applicability of the regulation
Sources specifically exempted from the regulation
Exemption for research and laboratory facilities
List of sections of EPA's General Provisions regulation (subpart N)
that apply to sources covered under this regulation
Compliance dates for existing sources
Compliance date for new sources
Guidance for determining if source is reconstructed
63.800(a)
63.800(b)
63.800(c)
63.800(d)
63.800(e)
63.800(f)
63.800(g)
Definitions and Nomenclature
Definitions used in the regulation
Definitions of terms used in equations in the regulation
63.801(a)
63.801(b)
Emission Limits
Emission limits for existing sources
Emission limits for new sources
63.802(a)
63.802(b)
Work Practice Standards
Work practice implementation plan
Operator training requirements
Inspection and maintenance plan
Cleaning and washoff solvent accounting system
Chemical composition of cleaning and washoff solvents
Spray booth cleaning restrictions
Storage requirements
Application equipment requirements
Gun and line cleaning
Washoff operations
Formulation assessment plan
63.803(a)
63.803(b)
63.803(c)
63.803(d)
63.803(e)
63.803(f)
63.803(g)
63.803(h)
63.803(I)&Q
63.803(k)
63.803(1)
Compliance Provisions
C-1
-------
TABLEC-1. (continued)
Requirement
Compliance options for finishing operations
Compliance options for gluing operations
Methods to demonstrate initial compliance
Methods to demonstrate continuous compliance
Location in Regulation
63.804(a)&(d)
63.804(b),(c) & (e)
63.804(f)
63.804(g)
Performance Test Methods
Test methods for determining the HAP content of coatings and
adhesives (cited here, but actual methods will be in 40 CFR part 60,
Appendix A)
Test methods for sources using control device to comply with the
regulation
63.805(a)
63.805(b),(c),
(d),&(e)
Recordkeeping Requirements
Recordkeeping requirements for sources using compliant coatings
and/or averaging to comply with the regulation
Recordkeeping requirements associated with work practice standards
Recordkeeping requirements for sources using control system to
comply with the regulation
Miscellaneous recordkeeping requirements
63.806(b),(c) & (d)
63.806(e)
63.806(f)&(g)
63.806(h),(D
&(i)
Reporting Requirements
Initial notification requirements
Ongoing compliance status reports
Reporting requirements for sources using a control system
Reporting requirements associated with the formulation assessment
plan
63.807(b)
63.807(c)
63.807(d)
63.807(e)
C-2
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APPENDIX D.
FEDERAL REGISTER NOTICE-WOOD FURNITURE NESHAP
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G293G Federal Register ' Vol. 60, No. 235 / Thursday. Doccmbcr 7, 1005 ' R-lcs ar.d Reg-la'..or.s
Taoics to Subpart II
Subpart JJ—National Emission
Standards for Wood Furniture
Manufacturing Operations
§ 63.800 Applicability.
,ai The affected source to which this
s-bo art applies is each facility that is
- engaged, either in part or in whole, in
the manufacture of wood furniture or
wood furniture components and that is
located at a plant sue that is a major
source as denned in 40 CFR part 63 2.
The owner or operator of a source that
meets the criteria for an incidental
furniture manufacturer shall maintain
purchase or usage records
demonstrating the source meets the
criteria specified in § 63.801 of this
subpart. but the source shall not be
subject to any other provisions of this
subpart.
fb) A source that complies with the
limits and criteria specified in
paragraphs (b)(l). (b)(2). or fb)(3) of this
section is an area source for the
purposes of this subpart and is not
subject to any other provision of this
rule, provided that: In the case of
* parargraphs (b)(l) and fb)(2). Finishing
materials, adhesives, cleaning solvents
and washoff solvents account for at ieast
9C percent of annual HAP emissions at
the plant site, and if the plant site has
HAP emissions that do not originate
frcrn trie listed materials, the owner or
operator keeps any records necessary to
demonstrate that the 30 percent
cr.ter.on is met. A source mat initially
relies on the limits and criteria specified
:.-. paragraphs fold, (bi(2). and (bi(3) to
Decome an area source, but
subsequently exceeds the relevant limit
Iw.tnout first obtaining and complying
w.tn otner units that keep its potential
:c err..t hazardous air pollutants below
T.a:cr source levels), becomes a major
source ar.d must comply thereafter with
all ;:p.icaoi9 provisions of tins subpart
starting or. the applicable compliance
aate in §63 800. Nothing in this
sa.-csraph fb) is intended to preclude a
scurce from limiting its potential to emit
'..-.rough other appropriate mechanisms
tr.at may be available through the
permitting authority
(1) The owner or operator of the
source uses no more than 250 gallons
per month, for every month, of coating,
jluir.g. cleaning, ar.c washoff materials
at the source, including materials used
for source categories other than wood
furniture (surface coating), but
cxr./ding materials used in routine
D.'v'cTiai or facihly grounds
maintenance, personal uses by
umslovccs or other persons, the use of
products for the purpose of maintain::!).;
motor vehicles operntnd by the facility,
or the use of toxic chemicals contained
in intake water (used for processing or
noncontact cooling) or intake air (used
either as compressed air or for
combustion) The owner or operator
shall maintain records of the total
gallons of coating, gluing, cleaning, ar.d
washoff materials used each month, and
upon request submit such records to the
Administrator. These records shall be
maintained for five years.
12} The owner or operator of the
source uses no more than 3,000 gallons
per rolling 12-month period, for every
12-month period, of coating, gluing,
cleaning, and washoff materials at the
source, including materials used for
source categories other than wood
furniture (surface coating), but
excluding materials used in routine
janitorial or facility grounds
maintenance, personal uses by
employees or other persons, the use of
products for the purpose of maintaining
motor vehicles operated by the facility.
or the use of toxic chemicals contained
in .ntake water (used for processing or
noncontact cooling) or intake air (used
either as compressed air or for
combustion). A rolling 12-month period
includes the previous 12 months of
operation. The owner or operator of the
source shall maintain records of the
total gallons of coating, gluing, cleaning.
and washoff materials used each month
and the total gallons used each previous
month, and upon request submit such
records to the Administrator. Because
records are needed over the previous set
of 12 months, the owner or operator
shall keep monthly records beginning
no less than one year before the
compliance date specified in
§63.800(e). Records shall be maintained
for five years.
(3) The source uses matenais
containing no more than 4.5 Mg (5 tons)
of any one HA? per rolling 12-month
period or no more than 114 Mg (12.5
tons; of any combination of HAP per
rolling 12-month period, inducing
materials from source categories other
than wood furniture; and at least 90
percent of the plantwide emissions per
rolling 12-month period are associated
with the manufacture of wood furniture
or wood furniture components. The
owner or operator shall maintain
records that demonstrate that annual
emissions do not exceed these levels,
including monthly usage records for all
:.rushing, gluing, cleaning, and washoff
tnntcnnls. certified product data sheets
for muse materials, and any other
"u( orris necessary to document
(.•missions from sourc.c categories other
t.'inn u ood furnitun: and apon ruqurst
submit such records to the
Adm.nistrnicr These records shall -,
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Federal Register / Vol. GO, No. 235 / Thursday, December 7. 1905 / Rules and Rcgula'.ior.s 629:17
of bonding two surfaces together other
thnn by mechanical means. Under this
subpart. adhesives shall not be
considered coatings or finishing
materials. Products used on humans and
animnls. adhesive tape, contact paper,
or any othet product with an adhesive
incorporated onto or in an inert
suDStrate shall not be considered
adhesives under this subpart.
Administrator means the
Administrator of the United States
Environmental Protection Agency or his
or her authorized representative.
Aerosol adhesive means an adhesive
that is dispensed from a pressurized
container as a suspension of fine solid
or liquid particles Ln gas.
Affected source means a wood
furniture manufacturing facility that is
engaged, either in part or in whole, in
the manufacture of wood furniture or
wood furniture components and that is
located at a plant site that is a major
source as defined in 40 CFR part 63.2,
excluding sources that, meet the criteria
established in § 63 800(a). (b) and (c) of
this subpart.
Alternative method means any
method of sampling and analyzing for
an air pollutant that is not a reference
or equivalent method but has been
demonstrated to the Administrator's
satisfaction to. in specific cases,
produce results adequate for a
determination of compliance.
As applied means the HAP and solids
content of the coating or contact
adhesive that :s actually used for
coating or gluing the substrate. It
includes the contribution of materials
used for in-house dilution of the coating
or contact adhesive.
Basecoat means a coat of colored
matenal. usually opaque, that is applied
before graining inks, glazing coats, or
other opaque finishing materials, and is
usually topcoated for protection.
Baseline conditions means the
conditions that exist prior to an affected
source implementing controls, such as a
ccr.tro! system.
Bdi'.ding enclosure means a building
mousing a process that meets the
requirements of a temporary total
enclosure. The EPA Method 204E is
used to identify all emission points from
tne bunding enclosure and to determine
which emission points must be tested.
For additional information see
Guidelines for Determining Capture
Efficiency. January 1994. Docket No. A-
93-10. Item No IV-B-1.
Capture device means a hood,
unclosed room, floor sweep, or other
means of collecting solvent emissions or
other pollutants into a duct so that iho
pollutant can bo directed to a pollution
control device such as an incinerator or
carbon adsorber.
Capture efficiency means the fraction
of all organic-vapors generated by a
process that are directed to a control
device.
Certified product data sheet (CPDSj
means documentation furnished by
coating or adhesive suppliers or an
outside laboratory that provides the
HAP content of a finishing matenal,
contact adhesive, or solvent, by percent
weight, measured using the EPA
Method 311 (as promulgated in this
subpart), or an equivalent or alternative
method (or formulation data if the
coating meets the criteria specified in
§ 63.805(a)); the solids content of a
finishing material or contact adhesive
by percent weight, determined using
data from the EPA Method 24. or an
alternative or equivalent method (or
formulation data if the coating meets the
criteria specified in § 63.80S(a)); and the
density, measured by EPA Method 24 or
an alternative or equivalent method.
Therefore, the reportable HAP content
should represent the maximum
aggregate emissions potential of the
finishing material, adhesive, or solvent
in concentrations greater than or equal
to 1.0 percent by weight or 0.1 percent
for HAP that are carcinogens, as defined
by the Occupational Safety and Health
Administration Hazard Communication
Standard (29 CFR part 1910). as
formulated. The purpose of the CPDS is
to assist the affected source in
demonstrating compliance with the
emission limitations presented in
§63.802.
(Note: Because the optimum analytical
conditions under EPA Method 311 vary by
coating, the coating or adhesive supplier may
also choose to include on the CPDS the
optimum analytical conditions for analysis of
the coating, adhesive, or solvent using EPA
Method 311. Such information may include.
but not be limited to, separation column,
oven temperature, earner gas, miecnon port
temperature, extraction solvent, and internal
standard.)
Cleaning operations means operations
in which organic solvent is used to
remove coating materials or adhesives
from equipment used in wood furniture
manufacturing operations.
Coating means a protective.
decorative, or functional film applied in
a thin layer to a surface. Such materials
include, but are not limited to, paints,
topcoats, varnishes, sealers, stains,
washcoats, basecoats, enamels, inks,
and temporary protective coatings.
Coating application station means the
part of a coating operation where the
coating is applied, u.g . a spray booth.
Canting operation means those
activities in which a coating is applied
to a substrntt' and is subsequently a;r-
(Inud, cured in an oven, or cured rv,
radiation
Coating solids (or solids) means the
port of iho coating which remains after
the coating is dried or cured, solids
content is determined using data from
the EPA Method 24. or an equivalent or
alternative method.
Compliant coating.'contact adhesive
means a finishing matenal, contact
adhesive, or strippable booth coating
that meets the emission limits specified
in Table 3 of this subpart.
Contact adhesive means an adhesive
that is applied to two substrates, dned.
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 ainng.
Continuous coater means a finishing
system that continuously applies
finishing materials onto furniture parts
moving along a conveyor. Finishing
materials that are not transferred to the
part are recycled to a reservoir. Several
types of application methods can be
used with a continuous coater including
spraying, curtain coating, roll coating.
dip coating, and flow coating.
Continuous compliance means that
the affected source is meeting the
emission limitations and other
requirements of the rule at all times and
is fulfilling all monitoring and
recordkeeping provisions of the rule in
order to demonstrate compliance.
Control device means any equipment
that reduces die quantity of a pollutant
dial is emitted to die air. The device
may destroy or secure die pollutant for
subsequent recovery Includes, but is
not limited to. incinerators, carbon
adsorbers, and condensers.
Control device efficiency means the
ratio of die pollutant released by a
control device and the pollutant-
introduced to die control device.
Control system means the
combination of capture and control
devices used to reduce emissions to the
atmosphere.
Conventional air spray means a spray
coating method in which the coating is
atomized by mixing it with compressed
-11 r and applied at an air pressure greater
than 10 pounds per square inch (gauge)
at the point of atomization. Airless and
air assisted airless spray technologies
are not conventional air spray because
the coating is not atomized by mixing it
with compressed air Electrostatic spray
technology is also not considered
conventional air spray because an
electrostatic charge is employed to
attract the coating to the workpiui u.
Data quality ob/cctivc (DQOl
approach means a set of approvni
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02930 I>dorn! Registrr ' Vol. GO. No. 235 / Thursday. December 7. 1995 / Rules and Regulations
rr.',.j";n 'ha! must ho met so that data
from an alternative test method cnn be
used .n determining thu cnpturu
efficiency of 2 control system For
,idii''ional information, see Cuidc/incs
for Determining Caoturr Efficiency.
lar.uar, 1994 IDocket No A-93-10.
Item \'o IV-B-1).
Dnv means a period of 24 consecutive
hours beginning at midnight iocal time,
or beginning at a time consistent with a
fac:i.;v's operating schedule.
D'.^oosed offsite means sending used
organic solvent or coatings outside of
the facility boundaries for disposal.
Emission means the release or
s discharge, whether directly or
indirectly, of HAP into the ambient air.
Enamel means a coat of colored
material, usually opaque, thai is applied
as a protective topcoat over a basecoat,
primer, or previously applied enamel
coats. In some cases, another finishing
material may be applied as a topcoat
over the enamel.
Equipment leak means emissions of
volatile hazardous air pollutants from
; pumps, valves, flanges, or other
'jequ.prnent used to transfer or apply
coatings, adhesives, or organic solvents.
Equivalent method m.eans any method
of sampling and analyzing for an air
pollutant that has been demonstrated to
tne Administrator's satisfaction to have
a consistent anc quantitatively known
relationship to the reference method,
ur.de: spec.fic conditions.
Finishing material means a coating
usec .r. the wood furniture industry.
Such materials include, but are not
l.r-.itec to. stains, basecoats, washcoats.
er.arneis. seaiers, and topcoats.
r xisning operation means those
operations in which a finishing material
is appued to a substrate and is
subsequently air-dned. cured in an
o\ en or cured by radiation.
roam adhesive means a contact
aches.', e used for gluing foam to fabric.
foam to foam, and fabric to wood.
Gi'-:ng operation means those
operations .n which adhesives are used
',o ;om components, for example, to
a-:p.y a laminate to a wood substrate or
foam to fabric.
Incidental wood furniture
manufacturer means a major source that
is primarily engaged in the manufacture
of products other than wood furniture or
wood furniture components and that
uses no more than 100 gallons per
mon'.i: of finishing material or adhesives
.:'. the manufacture of wood furniture or
wood furniture components.
Incinerator means, for the purposes of
;,'i.b .ndiistry. an enclosed combustion
uev.ce ll'.at '.herm.iliy oxidizes volatile
ur«,mic compounds to CO and CO; Tins
term does not include devices thnt burn
municipal or hnzanious waste material
Janitorial mointenanct: means the
upkeep of equipment or building
str.iLJturcs that ;s not directly reUted to
:he manufacturing process, for example.
cleaning of restroom facilities.
Lo^ur confidence limit fLCL)
approach means a set of approval
cr:!er.a that must be met so that data
from an alternative test method can be
used in determining the capture
efficiency of a control system. For
additional information, see Gu;de/ines
for Determining Capture Efficiency,
January 1994. [Docket No. A-93-10.
Item No. rV-B-1).
Material safety data sheet (MSDS)
means the documentation required for
hazardous chemicals by the
Occupational Safety and Health
Administration (OSHA) Hazard
Communication Standard (29 CFR Part
1910} for a solvent, cleaning material,
contact adhesive, coating, or other
material that identifies select reportable
hazardous ingredients of the material,
safety and health considerations, and
hand'ling procedures.
iVoncomp/i'anf coating/contact
adhesive means a finishing material,
contact adhesive, or stnppable booth
coating that has a VHAP content (VOC
content for the stnppable booth coating)
greater than the emission limitation
presented in Table 3 of this subpart._
.Vonporous substrate means a surface
tnat is impermeable to liquids.
Examples include metal, ngid plastic.
flexible vinyl, and rubber.
formally closed container means a
container that is closed unless an
operator is actively engaged in activities
such as emptying or filling the
container.
Operating parameter value means a
minimum or maximum value
established for a control device or
process parameter that, if achieved by
iise;f or in combination with one or
more other operating parameter values.
determines that an owner or operator
has complied with an applicable
emission limit.
Organic solvent means a volatile
organic liquid that is used for dissolving
or dispersing constituents in a coating
or contact adhesive, adjusting the
viscosity of a coating or contact
adhesive, or cleaning equipment. When
used in a coating or contact adhesive,
the organic solvent evaporates during
drying and does not become a part of
the dried film.
Ovrrnll control efficiency means the
efficiency of a control system,
calculated as the product of the capture
und control devicu efficiencies.
expressed .is n pcre.unt.iije
Prr.7ione.Tf total "ic.'osurp means n
permanently installed enclosure "ha!
i.cmpletely surrounds a source of
emissions such that all emiss.ons are
raptured and contained for discharge
through a control device. For add.uor.a!
information, see Guidelines for
Determining Capture Efficiency. January
ISO-i [Docket No. A-93-10. Item No.
IV-B-11.
Rccvcled onsite means '.he reuse of an
organic solvent in a process other than
cleaning or washoff.
Reference method means any method
of sampling and analyzing for an air
pollutant that is published in Appendix
A of 40 CFR part 60.
Research or laboratory facility means
any stationary source whose primary
purpose is to conduct research and
development to develop new processes
and products where such source is
operated under the close supervision of
technically trained personneLand is not
engaged in the manufacture of products
for commercial sale in commerce.
except in a de minimis manner.
Responsible official has the meaning
given to it in 40 CFR part 70. State
Operating Permit Programs (Title V
permits).
Sealer means a finishing material
used :o seal the pores of a wood
substrate before additional coats of
finishing material are applied Special
purpose finishing materials that are
used in some finishing systems to
optimize aesthetics are not seaiers,
So/Vent means a liquid ased in a
coating or contact adhesive to dissolve
or disperse constituents and.'or to aa:ust
viscosity. It evaporates during drying
and does not become a part of the dried
film.
Stan means any color coat having a
soLds content by weight of no more
than 3.0 percent that is applied in single
or multiple coats direct'.y to the
substrate It includes, but is not limited
to, nongram raising stains, equalizer
stains, prestams. sap stains, body stains
no-wipe stains, penetrating stains, ana
toners
Storage containers means vessels or
tanks, .ncluding mix equipment, used to
hold finishing, gluing, cleaning, or
washoff materials
Stnppable spray booth matenai
means a coating that:
(1) is applied to a spray booth wail to
provide a protective film to receive
overspray during finishing operations.
(2) That ii subsequently peeled off
and disposed, and
(31 By achieving (1) and (-). reduc.es
or eliminates (ho need to use origan.t.
solvents to clean sprav booth wuils
Siib.sfrntc Miiiaiis tl.e surf.ic i- onto
wlm ti a Luatini; 01 ( ont.K '. ,iu!ii">iie ^
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Federal Register / Vol. 60. No. 235 / Thursday. December 7. 1095 / Rules and Regulations 62939
anphcd (or into which a coating or
contact adhesive is impregnated).
Temporary total enclosure moons an
enclosure that meets the requirements of
§ 63.805(e)(l) (i) through (iv) and is not
permanent, but constructed only to
measure the capture efficiency of
pollutants emitted from a given source.
Additionally, any exhaust point from
the enclosure shall be at least four
equivalent duct or hood diameters from
each natural draft opening. For
additional information, see Guidelines
for Determining Capture Efficiency.
'lanuary 1994. (Docket No. A-93-10,
Item No. IV-B-1).
Thinner means a volatile liquid'that is
used to dilute coatings or contact
adhesives (to reduce viscosity, color
strength, and solids, or to modify drying
conditions).
Topcoat means the last film-building
finishing material that is applied in a
finishing system.
Touchup and repair means the
application of finishing'materials to
cover minor finishing imperfections.
VHAP means any volatile hazardous
air pollutant listed in Table 2 to Sub part
JJ.
VHAP of potential concern means any
VHAP from the nonthreshold, high
concern, or unrankable list in Table b of
this subpart.
Volatile organic compound (VOC)
means any organic compound which
participates in atmospheric
photochemical reactions, that is, any
organic compound other than those
which the Administrator designates as
having negligible photochemical
reactivity. A VOC may be measured by
a reference method, an equivalent
method, an alternative method, or by
procedures specified under any rule. A
reference method, an equivalent
method, or an alternative method.
however, may also measure nonreactive
organic compounds. In such cases, the
owner or operator may exclude the
nonxeactive organic compounds when
determining compliance with a
standard. For a list of compounds that
the Administrator has designated as
having negligible photochemical
reactivity, refer to 40 CFR part 51.10.
Washcoat means a transparent special
purpose finishing material having a
solids content by weight of 12.0 percent
by weight or less. Washcoats are applied
over initial stains to protect, to control
color, and to stiffen the wood fibers in
order to aid sanding.
Washoff operations means those
operations in which organic solvent is
usud to remove coating from wood
furniture or a wood furniture
component.
Wood furniture moons any product
made of wood, a wood product such as
rattan or wicker, or an engineered wood
product such as particleboord that is
manufactured under any of the
following standard industrial
classification codes: 2434, 2511. 2512,
2517. 2519. 2521. 2531. 2541. 2599. or
5712.
Wood furniture component means any
part that is used in the manufacture of
wood furniture. Examples include, but
are not limited to, drawer sides, cabinet
doors, seat cushions, and laminated
tops.
Wood furniture manufacturing
operations means the finishing, gluing,
cleaning, and washoff operations
associated with the production of wood
furniture or wood himiture '
components.
(b) The nomenclature used in this
subpart has the following meaning:
(1) Ak = the area of each natural draft
opening (k) in a total enclosure, in
square meters.
(2) Co=the VHAP content of a
finishing material (c), in kilograms of
volatile hazardous air pollutants per
kilogram of coating solids (kg VHAP/kg
solids), as supplied. Also given in
pounds of volatile hazardous air
pollutants per pound of coating solids
(Ib VHAP/lb solids).
(3) CtJ=the concentration of VHAP in
gas stream (j) exiting the control device,
in parts per million by volume.
(4) Ce,=the concentration of VHAP in
gas stream (i) entering the control
device, in parts per million bv volume.
(5) Ca,=the concentration of VHAP in
gas stream (i) entering the control device
from the affected source, in parts per
million by volume.
(6) Cnc='the concentration of VHAP in
uncontrolled gas stream (k) emitted
directly to the atmosphere from the
affected source, in parts per million by
volume.
(7) E=the emission limit achieved by
an emission point or a set of emission
points, in kg VHAP/kg solids (Ib VHAP/
Ib solids).
(8) F=the control device efficiency,
expressed as a fraction.
(9) FV=the average inward face
velocity across all natural draft openings
in a total enclosure, in meters per hour.
(10) G=the VHAP content of a contact
adhesive, in kg VHAP/kg solids (Ib
VHAP/lb solids), as applied.
(11) M=the mass of solids in finishing
material used monthly, kg solids/month
(Ib solids/month).
(12) N=the capture efficiency.
expressed as a fraction.
(13) Q,j=the volumetric flow rate of
gas stream (j) exiting the control device.
in dry standard cubic meturs pur hour.
(14) Qhl=tho volumetric How rntc of
gas stream (i) entering the control
device, in dry standard cubic meters per
hour.
(151 Qj,=the volumetric flow rate of
gas stream (i) entering the control device
from the emission point, in dry standard
cubic meters per hour.
(16) Ojv=the volumetric flow rate of
uncontrolled gas stream (k) emitted
directly to the atmosphere from the
emission point, in dry standard cubic
meters per hour.
(17) Q,r,=the volumetric flow rate of
gas stream (i) entering the total
enclosure through a forced makeup air
duct, in standard cubic meters per hour
(wet basis).
(18) Qoij=the volumetric flow rate of
gas stream (j) exiting the total enclosure
through an exhaust duct or hood, in
standard cubic meters per hour (wet
basis).
(19) R=the overall efficiency of the
control system, expressed as a
percentage.
(20) S=the VHAP content of a solvent,
expressed as a weight fraction, added to
finishing materials.
(21) W=the amount of solvent, in
kilograms (pounds), added to finishing
matenals during the monthly averaging
period.
(22) ac=after the control system is
installed and operated.
(23) bc=before control.
§ 53.802 Emission limits.
(a) Each owner or operator of an
existing affected source subject to this
subpart shall:
(1) Limit VHAP emissions from
finishing operations by meeting the
emission limitations for existing sources
presented in Table 3 of this subpart,
using any of the compliance methods m
§ 63.804('a). To determine VHAP
emissions from a finishing material
containing formaldehyde or styrene, the
owner or operator of the affected source
shall use the methods presented in
§ 63.803(0(2) for determining styrene
and formaldehyde usage.
(2) Limit VHAP emissions from
contact adhesives by achieving a VHAP
limit for contact adhesives based on the
following criteria:
(i) For foam adhesives (contact
adhesives used for upholstery
operations) used in products that meet
the upholstered seating flammabihty
requirements of California Technical
Bulletin 116. 117, or 133, the Business
and Institutional Furniture
Manufacturers Association's (BIFMA's)
X5.7. UFAC flammabihty testing, or any
similar requirements from local. State.
or Federal fire regulatory agencies, tha
VHAP content of the adhesive stiall not
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02940 Federal Register Voi 60, No. 235 / Thursday. December 7, 1905 . R^.os ar.a 3egti.-.t;or.s
ox reed 1.8 kg VHAP'kc; so i ids \\ 8 !b
V'HAP !h solids), as applied, or
(11) For nil other contact adhcsivcs
(including foam ndhesivus used in
products that do not meet the standard
presented in paragraph (a)(2!(i) of tins
section, but excluding aerosol adhesi\es
and excluding contact adhesives
applied to nonporous substrates, the
V'HAP content of the adhesive shall not
exceed 1 0 kg VHAP'kg solids t'l 0 !h
VHAP/lb solids), as applied.
(3) Limit HAP emissions from
strippable spray booth coatings by using
coatings that contain no more than 0.8
kg VOC'kg solids (0.8 Ib VOC'lb solids).
as applied.
(b) bach owner or operator of a new
affected source subject to this subpan
shall:
(1) Limit VHAP emissions from
finishing operations by meeting the
emission limitations for new sources
presented in Table 3 of this subpart
using any of the compliance methods in
§ 63.804('d). To determine V'HAP
emissions from a finishing material
containing formaldehyde or styrene, the
owner or operator of the affected source
shall use the methods presented in
§ 53.803(1)(2) for determining styrene
and formaldehyde usage.
(2} Limit VHA? emissions from
contact adhesives by achieving a VHA?
ii.-r.it for contact adhesives. excluding
aerosol adhesives and excluding contact
adhesives applied to nonporous
.sstrates, of no greater than 0 2 kg
'. HA? 'kg solics fo.2 Ib VHAP-'.b solids!.
as applied, using either of the
:orr'pliance methods in §63 304(e)
!3) Limit HAP emissions from
strippable spray booth coatings by using
coatings that contain no more than 0 &
kg VOC'kg solids (0.8 Ib VOC'lb solids'),
as applied
§ S3.803 Work practice standards.
(a) r.ciiir cj'. s.
after tha leak is detected ind
(ii) Final repairs shall ~e made w.•.-..-
15 calendar days after ±e leak is
detected, unless the lenk;ng oquipme-.t
is to be replaced by a new purchase ..-.
which case repairs shall be complete.
within three mor.ths.
(d) Cleaning and washoff solver.:
accounting svs.'e.Ti Eoci owner or
operator of an affected source shall
develop an organic solvent account.r.g
form to record:
(1) The quantity and type of orga...c
solvent used each month for washoff
and cleaning, as defined in § 63.801 zt
this subpart;
(2) The number of pieces washed off.
and the reason for the washoff; and
(3) The quantity of spent solvent
generated from each washoff and
cleaning operation each month, and
whether it is recycled onsite or disposed
offsite.
(e) Chemical composition ofcleanir.g
and washoff solvents. Each owner or
operator of an affected source shall not
use cleaning or washoff solvents that
contain any of the pollutants listed in
Table 4 to this subpart. in
concentrations subject tc MSDS
reporting as required by OSHA.
if) Spray booth cleaning Eacric-.v—er
or operator of an affected source sha.l
not use cnmpounds containing mere
than 8.0 percent by weignt o:'. OC for
cleaning spray cccth corr.pcr.er.ts :'—?'
than conveyors, continuous coaters ar.-
tneu enclosures, or metal filters, 'jr-ess
the spray booth is being refurbished Lf
the spray booth is being refuroishec
that is the spray booth coating or other
protective material used to cover tze
booth is being replaced, lie affected
source shall use no more than l 3 za..c~
of organic solvent per booth to prepare
the surface of tie booth prior to
apolying the booth coa:.ng.
' (g)'Storcge requirement Each owner
or operator of an affected source sr.a..
use normal!v ciosec ccntair.ers for
storing Snisning, gluing, c.eaning. -".-
washoff materials.
(h) Application equipment
requirements Each owner or iperatcr z:
an affected source shall use
conventional air spray guns to apply
finishing materials only under ar.y of
the following circumstances:
(1) To app:y finishing materials ih-t
have a VOC content no greater than : .
Ib V'OC/lb solids, as aopi.ed.
(2) For touchup and repair under -.•-'
following conditions-
ii) Thu toucliup and repair occ-J-s
nhur Lomplt'ti'jn of ti'.o ;".i.ih.:ii;
ODcraticn. or
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Federal Register
60. No 235 Thurseav December
62041
(11) The touchup and repair occurs
after the application of slam and before
Lho application of any other typo of
finishing material, and the materials
used for touchup and repair arc applied
from a container that has a volume of no
more than 2.0 gallons
(3) When spray is automated, that is.
the spray gun is aimed and triggered
automatically, not manually;
(4) When e'missions from the finishing
application station are directed to a
control device;
(5) The conventional air gun is used
to apply finishing materials and the
cumulative total usage of that finishing
material is no more than 5.0 percent of
the total gallons of finishing material
used during that semiannual period; or
(6) The conventional air gun is used
to apply stain on a part for which it is
technically or economically infeasible to
use any other spray application
technology.
The affected source shall demonstrate
technical or economic infeasibility by
submitting to the Administrator a
videotape, a technical report, or other
documentation that supports the
affected source's claim of technical or
economic infeasibility. The following
criteria shall be used, either
independently or in combination, to
support the affected source's claim of
technical or economic infeasibilitv;
(i) 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
(ii) The excessively large vertical
spray area of the part makes it difficult
to avoid sagging or runs in the stain.
(i) Line cleaning. Each owner or
operator of an affected source shall
pump or drain all organic solvent used
for line cleaning into a normally closed
container.
(j) Gun cleaning. Each owner or
operator of an affected source shall
collect all organic solvent used to clean
spray guns into a normally closed
container.
(k) Washoff operations. Each owner or
operator of an affected source shall
control emissions from washoff
operations by:
(1) Using normally closed tanks for
washoff; and
(2) Minimizing dripping by tilting or
rotating the part to drain as much
solvent as possible.
(1) Formulation assessment plan for
finishing operations Each owner or
operator of an affected source shall
prepare and maintain with the work
practice implementation plan a
formulation assessment plan that:
(1) Identifies VHAP from the list
presented in Table 5 of this subpart that
are being used in finishing operations
by the affected source;
(2) Establishes a baseline level of
usage by the affected source, for each
VHAP identified in paragraph (DC) of
this section. The baseline usage level
shall be the highest annual usage from
1994, 1995. or 1996, for each VHAP
identified in paragraph (1)(1) of this
section. 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. 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. Sources using a control device
to reduce emissions may adjust their
usage based on the overall control
efficiency of the control system, which
is determined using the equation in
§ 63.805 (d) or (e).
(3) Tracks the annual usage of each
VHAP identified in (1)(1) by the affected
source that is present in amounts
subject to MSDS reporting as required
by OSHA.
(4) If. after November 1998, the
annual usage of the VHAP identified in
paragraph (1)(1) exceeds its baseline
level, then the owner or operator of the
affected source shall provide a written
notification to the permitting authority
that describes the amount of the
increase and explains the reasons for
exceedance of the baseline level. The
following explanations would relieve
the owner or operator from further
action, unless the affected source is not
in compliance with any State
regulations or requirements for that
VHAP:
(i) The exceedance is no more than
15.0 percent above the baseline level;
(ii) Usage of the VHAP is below the
de minimis level presented in Table 5
of this subpart for that VHAP (sources
using a control device to reduce
emissions may ad)ust their usage based
on the overall control efficiency of the
control system, which is determined
using the procedures in § 63.805 (d) or
(e);
(iii) The affected source is in
compliance with its State's air toxic
regulations or guidelines for the VHAP:
or
(iv) The source of the pollutant is a
finishing material with a VQC content of
no more than 1.0 kg VOC/kg solids (1.0
Ib VOC/lb solids), as applied.
(5) If none of the above explanations
ore tho reuson for the increase, the
owner or operator shall confer with tho
permitting authority to discuss the
reason for tho increase and whether
'hero are practical and reasonable
technology-based solutions for rucur.r.i;
the usage The evaluation of whether a
technology is reasonable and practical
shall be based on cost, quality, and
marketability of the product, whether
the technology is being used
successfully by other wood furniture
manufacturing operations, or other
criteria mutually agreed upon by the
permitting authority and owner or
operator. If there are no practical and
reasonable solutions, the facility need
take no further action. If there are
solutions, the owner or operator shall
develop a plan to reduce usage of the
pollutant to the extent feasible. The plan
shall address the approach to be used to
reduce emissions, a timetable for
implementing the plan, and a schedule
for submitting notification of progress.
(6) If after November 1998, an affected
source uses a VHAP of potential
concern for which a baseline level has
not been previously established, then
the baseline level shall be established as
the de minimis level, based on 70 year
exposure levels and data provided in
the proposed rulemaking pursuant to
Section 11 2 (g) of the CAA, for that
pollutant. A list of VHAP of potential
concern is provided in Table 6 of this
subpart. If usage of the VHAP of
potential concern exceeds the de
rmmmis level, then the affected source
shall provide an explanation to the
permitting authority that documents the
reason for exceedance of the de minirnis
level. If the explanation is not one of
those listed in paragraphs (l)(4)(i)
through (l)(4)(iv). the affected source
shall follow the procedures established
in (1)(5).
§ 63.804 Compliance procedures and
monitoring requirements.
(a) The owner or operator of an
existing affected source subject to
§ 63.802(a)(l) shall comply with those
provisions using any of the methods
presented in §63.804 (a)(l) through
.
(1) Calculate the average VHAP
content for all finishing materials used
at the facility using Equation l. and
maintain a value of E no greater than
1.0;
S,W, -K SjW2 + ' * ' Sn
M<.2 f • • • 1- NO Equation 1
(2} Use compliant finishing materials
according to the following criteria.
(i) Demonstrate that each stain, sealer
and topcoat has a VHAP content of no
more than 1.0 kg VHAP/kg solids (1 0 Ib
VHAP/lb solids), as applied, and each
thinner contains no more than 10 Q
i.
-------
f)2942 Federal Rrqistor Vol 60. No 235
pore.:". '-liAP hv wo1?".; bv mruiitainin!?
ojrt.iipc: product data s;iuets for ead
• rrnt.r.c anc :;i,nner;
•.in Demonstrate that each wash;,oat.
basucoot. and enamel that is purchased
pro-mace, tr.at is. it is not formulated
onsitc 3v tmn.iint; another fir.is;ung
material, has a VHAP content of no
more tnan : 0 Kg VHAP kg solids (1 3 Ib
V HA? ib solids1,, as applied, ar.c each
:."i:::ner contains no more than 10 0
percent VHAP bv weigh: by maintaining
certified product data sheets for each
coat:nc and tninner xnd
iiui Demonstrate that each washcoat.
basecoat. and enamel that is formulated
at the affected source is fonr.ulated
using a finishing material containing no
more than 1.0 kg VHAP'kg solids (1 0 Ib
VHAP/lb solids) and a thinner
containing no more than 3.0 percent
VHAP by weight.
(3) Use a control system with an
overall control efficiency (R) such that
tne value of E* in Equation 2 is no
greater than. 1.0.
R=:(EBC-E1K)/E«x](100) Equation:
The value of £<* in Equation 2 snail
be calculated using Equation 1. or
(4) Use any combination of an
averaging approach, as described in
paragraph [a,'il] of this section.
compliant finishing materials, as
described :n paragraph iaj(2! of tnis
section, and a control system, as
described in paragraph (aM3) cf tr.is
section.
'bl The owner or operator of an
affected source subject to
§ 63 802,aj(2](i) shall comply with the
p-ovisicr.s by using compliant foam
achesives w.th a VHAP content r.o
greater than 1.3 kg VHAP'kg solids (I 8
.0 VHAP/'.b solids), as applied.
'c) The owner or operator of cr.
affected source subject to
§ 53.3C2;aj(2!(:i) shall comply with
tnose provisions by using either of the
methods presented in § 63.304 (c)(l) and
ic.,2!
ill Use compliant contact adhesives
%\ ;tn a VHAP content no greater than 1.0
kg VKA?;kg solids, (1 0 Ib VHAP.'lb
solicsi. as appi.ed. or
12! Use a control system with an
overall control efficiency (R) such that
tr.e value of G*. is no greater than 1.0.
R=i(Gb(.-G».)''Gbe! UOO) Equation 3
(d) Tlit' owner or operator of a new
affected source subject to §63 802!b)(l)
rnc\ ccmpK with those provisions by
us.nt> anv of the following methods
I'D Ca.C'jljte the average \'H.AJ>
content across all finishing materials
used at the facility using Equation 1.
and maintain a value of E no greater
than C 3
;_; Use compliant finishing materials
aci-oriiuig to tin- iolluwir.j; criteria
(i) Demonstrate thai earn sealer and
topcoat has j VHAP content of no rnnrc
tlian n ,'i ki} \'H.\p k,; solids in '] Ib
VK.'.r1 !b solids;, is anol.t'd, cm i'. s:ain
r.as .1 \'HAP content of no more th in 1 0
Krf VHAP/kg soiicsil 'J ,b VHAP I'D
sonds). TS apaLed. ami each thinner
contains no more than 10 0 percent
VHAP by weight.
(n) Demonstrate that each •Aabhcoct.
basecoat. and enamel that is purchased
pre-made. that is. it is not formulated
onsite by thinning another finishing
material, has a VHAP content of no
more than O.S kg VHAP/kg solids JO 3 Ib
VHAP/lb solids), as applied, and each
thinner contains r.o more than 100
percent VHAP by weignt; and
(lii) Demonstrate that each washcoat.
basecoat. and enamel that is formulated
onsite is formulated using a finishing
material containing no more than 0.8 kg
VHAP/kg solids (0.8 Ib VHAP/lb solids)
and a thinner containing no more than
3.0 percent HAP by weight.
(3) Use a control system with an
overall control efficiency (R) such that
'he value of E^. in Equation 4 is no
greater than 0.8.
R=i(Eoc-E»e)/EbJ(100) Equation 4
The value of E^ in Equation 4 snail
be calculated using Equation 1; or
(4) Use any combination of an
averaging approach, as described in
(d!(l), compliant finishing materials, as
described in (d)(2), and a control
system, as described in (d)(3)
(e> The owner or operator of a new
affected source subject to § 63 802;'b!(2)
snail comply with the provisions us.ng
either of the following methods
(1; Use compliant contact adhesives
w.th a VHAP content no greater '.nan 0.2
kg VHAP/kg solids (0.2 !b VHAP.'lb
solids), as applied, or
(2) Use a control system with an
overall control efficiency (R] such that
the value of Cx m Equation 3 is no
greater than 0.2.
(f) Initial compliance 'l! Owners or
operators of an affected source surrec: to
the provisions of § 63 302 tal(l) or ioU:)
that comply through the procedures
established in §63.804 ialUj or idlll)
shall submit the results of the averr.gmg
calculation (Equation 1) for 'he iirit
month with the initial compliance
status report required by § G3 807(b)
The first month's calculation shall
include data for the entire month in
which the compliance date fa lib. For
example, if the source's compliance djie
is November 21, 1997, '.lie averaging
calculation shall include data from
November 1, 1997 to November 3D.
I'JH"
(2) Owners or operators of nn afferted
source subject to the provisions of
^r,T 302 ,'.i;;:; or :>!U, t:;at -CT.P.-
ttinumh thp procedures osntj..vt- i .
§03 304 ;.i)!2; or 'dl,2; shall v..•-,.-. : •-.
initial corr.piinni o status rcrior .-•
rnquirt'd by (JO3 OOribl. stn'.ina t1 '.'
compliant stains. wasncn,its. SO.T.-.--S
topcoats, basecoats. enameii, TIC
tmnners. is anpiicable. are beinc ..=e-
by :::e affectea source
(3) Owners or ooerntors of an affer-.-d
source subject to tne provisions cf
§63 802 (a)(l) ortbiC', that are
complying through the proceaures
estaolished in §63 804 ia)(2; or ta',,2.
and are applying coatings using
continuous coaters shall dernonstrre
initial compliance by
(i) Submitting an initial compliance
status report, as required by § 5." 3C""b!
stating that compliant coatings, as
determined by the VHAP content cf tr.e
coating in the reservoir and the VHA?
content as calculated from records: ;r.d
compliant thinners are being used, or
(u) Submitting an initial compliance
status report, as required by § S3.30r;bi.
stating '.hat compliant coatings, as
determined by the VHAP content cf the
coating in the reservoir, are being used.
the viscosity of the coating in the
reservoir is being monitored: and
compliant th.nners are being used Tr.e
affected source shall also submit -cti
tnat demonstrate thit viscosity .s ar.
appropriate parameter for cemcr.sratir.j
compliance
(4) Owners or operators of an affgctez
source subject to the provisions of
§63.802 (a)(l) or (b;(l; that comoiy
througn the procedures establ.shed .r.
§ 53.304 (a)(3) or (d)(2) shall
aemonstrate initial compliance (?\
(.] Suomnting a monitoring plan thr.
identifies each operating parameter t;
be monitored for tne capture device ;.-.d
discusses why each parameter .s
appropriate for demonstrating
continuous compliance.
(u) Conducting an initial perfcrrr.inzs
test as required under § 53.7 using tr.e
procedures and test methods l.stec r.
^53 ~ and §63 805 icj and id) or e.
(iii) Calculating the overaa control
efficiency (R) following the procedures
in § 63 805 (d) or (e): and
(iv) Determining those operating
conditions critical to determining
compliance and estabhsning one or
more operating parameters that will
ensure compliance with the stance's
(A) For compliance wit.'i a thermal
incinerator, minimum combust.or.
temperature shall be the operating
parameter.
(D) For compliance with a cutalv: t
incinerator oquippoti with ,1 li
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Federal Roqistcr
GO. No 233 I Thurscinv. December ". 1005 /
Ruins jnu r\ot;'..ci!.or.s
.lowustrcMin of t'so catalyst bud shall bo
'ho oi-erntint; parameter
iC) for Compliance with a catalytic
•r.c.:iera:cr equipped with a fluidizod
catalvst bed. the minimum gas
•,e:v.perriturc upstream of the catalyst
bee and t.U- pressure drop across the
ca'.r.'.yst uea shall be the operating
oanmeters
(Dl For compliance with a carbon
adsorber, the operating parameters shall
be the total regeneration mass stream
fiow 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
Administrator to establish other
operating parameters.
(E) For compliance with a control
device not listed in this section, one or
more operating parameter values shall
be established using the procedures
identified in § 63.804(g)(4)(vi).
[v] Owners or operators complying
with § 63.804(f)(4) shall calculate each
site-specific operating parameter value
as the' arithmetic average of the
maximum or minimum operating
parameter values, as appropriate, that
demonstrate compliance with the
standards, during the three test runs
required by §63.805(c)(l).
(5) Owners or operators of an affected
source suoiect to the provisions of
§ 63 302 (aj(2) or fb)(2) that comply
through the procedures established in
§ 53 804 (b),~(c;U). or (ej(l), shall submit
an initial compliance status report, as
required by § 63 807fb), stating that
compliant contact adhesives are being
used by the affected source.
{6} Owners or operators of an affected
source subject to the provisions of
§ 63 802 ia)(2)(ii) or fb)(2) that comply
through the procedures established in
§53 804 !c)(2)or(e)(2), shall
demonstrate initial compliance by:
!i) Suomitting a monitoring plan that
identifies each operating parameter to
be monitored for the capture device and
d.scusses why each parameter is
appropriate for demonstrating
continuous compliance;
Jn) Conducting an initial performance
test as required under § 63.7 using the
procedures and test methods listed in
§ 63.7 and § 63.805 (c) and !d) or (e);
(nil Calculating the overall control
efficiency (R) following the procedures
m §G3 80S (d) or (e). and
(iv) Determining those operating
conditions critical to determining
compliance and establishing one or
more operating parameters that will
ensure compliance with the standard
(A) For compliance with a thermal
incinerator, minimum combustion
temperature stiaii be the operating
parameter
[3) For compliance with a catalytic
incinerator equipped with a fixed
catalyst bed. ihe minimi.m gas
temperature both upstream and
downstream of the catalyst shall be the
operating parameter
(C) For compliance with a catalytic
incinerator equipped with a fluidned
catalyst bed. the minimum gas
temperature upstream of the catalyst
bed and the pressure drop across the
catalyst bed shall be the operating
parameters.
(v) Owners or operators complying
with § 63.804(0(6) shall calculate' each
site-specific operating parameter value
as the arithmetic average of the
maximum or minimum operating values
as appropriate, that demonstrate
compliance with the standards, during
the three test runs required by
§63.805(c)(l).
(7) Owners or operators of an affected
source subject to the provisions of
§63.802 (a)(3) or fb)(3) shall submit an
initial compliance status report, as
required by § 63.807fb). stating that
compliant stnppable spray booth
coatings are being used by the affected
source.
(8) Owners or operators of an affected
source subject to the work practice
standards in § 63.803 shall submit an
initial compliance status report, as
required by § 63.807(b), stating that the
work practice implementation plan has
been developed and procedures have
been established for implementing the
provisions of the plan.
(g) Continuous compliance
demonstrations. (1) Owners or operators
of an affected source subject to the
provisions of § 63.802 (a)(l) or (b)(l)
that comply through the procedures
established in § 63.804 (a)(l) or (d)(l)
shall demonstrate continuous
compliance by submitting the results of
the averaging calculation (Equation 1)
for each month within that semiannual
period and submitting a compliance
certification with the semiannual report
required by §63.807(c).
U) The compliance certification shall
state that the value of (E), as calculated
by Equation 1. is no greater than 1.0 for
existing sources or 0.8 for new sources.
An affected source is in violation of the
standard if E is greater than 1.0 for
existing sources or 0.8 for new sources
for any month. A violation of the
monthly average is a separate violation
of the standard for each day of operation
during the month, unless the affected
source can demonstrate through records
that the violation of the monthly avernye
can be attributed to a particular day or
davs during the ponod.
(ii! The
lie sigr.ed in .1 ri.'spons.Dn: oi'.i' .n z\ .,!•
company thai owns or operates :.,e
affected source
(2) Owners or operators of an a:"fe: !f:
source subject to the previsions cf
§63 802 ;a)C; or ^bHD that comply
through the procedures esiabhsnec .n
§63.804 (a)(2) or!d)Ci shall
demonstrate continuous compliance c>
using compliant coatings and thinners.
maintaining records that demonstrate
the coatings and thinners are compliant.
and submitting a compliance
certification with the semiannual report
required by § 63.807(c;.
(i) The compliance certification shau
state that compliant stains, washcoats.
sealers, topcoats, basecoats, enamels.
and thinners, as applicable, have beer.
used each day m the semiannual
reporting period or should otherwise
identify the periods of noncomphance
and the reasons for noncompliance. An
affected source is in violation of the
standard whenever a noncompliant
coating, as demonstrated by records or
by a sample of the coating, is used.
'(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(3) Owners or operators of an affected
source subject to the provisions of
§ 63.802 (a)(l) or (b)(l) that are
complying through the procedures
established in §61.804 (a)(2) or(d;(2]
and are applying coatings using
continuous coaters shall demonstrate
continuous compliance by following tr.e
procedures in paragraph (gj(3) (i) or m)
of this section.
(i) Using compliant coatings, as
determined by the VHAP content of the
coating in the reservoir and the VKA?
content as calculated from records.
using compliant thinners. and
submitting a compliance certification
with the semiannual report requirec by
§63.807(c).
(A) The compliance certification snail
state that compliant coatings have been
used each day in the semiannual
reporting period, or should otherwise
identify the days of noncomphance ana
the reasons for noncomphance An
affected source is m violation of the
standard whenever a noncompliant
coating, as determined by records or by
a sample of the coating, is used Use of
a noncompliant coating is a separate
violation for each day tho noncomphant
coating is used.
(B) the compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source
(11) Using compliant coatings, as
determined by tho VHAP content of the
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02944 rcdrr.il Rncistnr / Vol. GO. No. 235 / Thursday, December 7. 1995 / Rules ar.d R-JC-
coating ;n the reservoir, us.ng compliant
thinners. mnintninmg n viscosity of the
co.itmg in tho reservoir that is no less
•.nan the viscosity of the initial coating
bv monitoring the viscosity with a
Mscosity meter or by testing the
viscosity of the initial coating and
retesting the coating in the reservoir
each time solvent is added, maintaining
records of solvent additions, ar.d
submitting a compliance certification
with the semiannual report required by
§5380:;c).
(A) The compliance certification shall
state that compliant coatings, as
determined by die VHAP content of the
coating in the reservoir, have been used
each day in the semiannual reporting
period. Additionally, the certification
shall state that the viscosity of the
coating in the reservoir has not been less
than the viscosity of the initial coating,
that is. the coating that is .nitially mixed
and placed in the reservoir, for any day
:n the semiannual reporting penod.
(B) The compliance certification shall
be signed by a responsible official of the
company that owns or operates trie
affected source.
(C) An affected source is in violation
of the standard when a sample of the as-
applied coating exceeds the applicable
limit established in §63.804 (a)(2) or
(d}(2). as determined using EPA Method
311, or the viscosity of the coating in the
reservoir is less than the viscosity of the
.r.-.t.ai coating
'4< Owners or operators of an affected
source suoiect to the provisions o:
§ 63.802 (a)(l) or (b)(i) that comply
through the procedures established in
§53 B04(a',(3) or(d)(3) snail
demonstrate continuous compliance by
installing, calibrating, maintaining, and
operating the appropriate monitoring
equipment according to manufacturer's
specifications. The owner or operator
shall also submit the excess emissions
and continuous monitoring system
performance report and summary report
required by § 63.807(dj and § 63 'lO(e) of
suooart A.
(i'l Where a capture/control device is
used, a device to monitor each site-
specific operating parameter estaolished
in accordance with § 63.804(f](6)[i) is
recuired.
f;i) Where an incinerator is used, a
temperature monitoring device
equipped with a continuous recorder is
required
(A) Where a thermal incinerator ,s
used, a temperature monitoring dcv .r.o
shall be installed in the firebox or :n the
ductwork immediately downstream of
tne firebox in a position before any
suostantial heat exchange occurs.
(B) Where a catalytic incinerator
equipped with a fixed catalyst bed is
used, temperature monitoring devices
shall be installed in the gas stream
immediately before and after the
catalyst bed.
(C) Where a catalytic incinerator
equipped with a fluidized catalyst bed
is used, a temperature monitoring
device 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.
The pressure drop shall be measured
monthly at a constant flow rate.
(iii) Where a carbon adsorber is used
one of the following is required:
(A) An integrating 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 or ±0 5 'C,
whichever is greater, and capable of
recording the carbon bed temperature
after each regeneration and within 15
minutes of completing any cooling
cycle:
' (B) An organic monitoring device
equipped with a continuous recorder, to
indicate the concentration level of
organic compounds exiting the carbon
adsorber: or
(C) Any other monitoring device that
has been approved by the Administrator
in accordance with §63.804(f)(4)(iv)(D).
(ivj Owners or operators of an affected
source shall not operate the capture or
control device at a daily average value
greater than or less than (as appropriate)
the operating parameter values. The
daily average value shall be calculated
as the average of all values for a
monitored parameter recorded during
the operating day.
(v) Owners or operators of an affected
source that are complying through the
usfl of a C3',ily..c incinor.Tor ocuipo:
with a fluiciizuc cata'.y.t b^ii sha ',
maintain 3 ror.sta?.! pressure 2r~u
measured rr.onthiv, icross trie cat:,.- *:
bod.
(vi) An owner or operator :v:\z c.^-s -
control device not listed .n § 6j-r 4,
shall submit, for the Administrate.
approval, a description of tne device.
test data verifying performance, inc
appropriate site-specific operating
parameters that will be monncrec '3
demonstrate continuous compiiar.ee
with the standard
(5) Owners or operators of an affectec
source subiect to the provisions of
§ 63.802 (a)(2) (i) or (n) or fb)Cj that
comply through the procedures
established in §63.804 (b). (c)(l). or
(e)(l). shall submit a compliance
certification with the semiannual repcr.
required by § 63.807(c).
(i) The compliance certification shall
state that compliant contact and/or fcarn
adhesives have been used each day in
the semiannual reporting period, or
should otherwise identify each day
noncomphant contact and/or foam
adhesives were used. Each day a
noncompliant contact or foam adhesive
is used is a single violation of the
standard.
(n) The compliance aerification shall
be signed by a responsible official of tr.e
company that owns or operates the
affected source.
(6) Owners or operators of an affectec
source subject to the provisions of
§63 802 !a)(2)(i:) or (b)l2; that corr.p'.y
through the procedures estaons.-.ec ."
§63.804 (c)(2) or iel(2),shau
demonstrate continuous compliance b>
installing, calibrating, maintain.r.g ar.c.
operating tne appropriate monitoring
equipment according to the
manufacturer's specifications The
owner or operator shall also sub TV. .'. -.r.t;
excess emissions and continuous
monitoring system performance -epcr
and summary report required by
§63 807(d) and §63.10(e! of sucpar: \
of this pan.
(i) Where a capture/control device ,s
used, a device to monitor each site-
specific operating parameter esta5ii?".cd
in accordance with § 63 804;f;i6;U, .3
required.
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Federal Register •' Vol. GO. No 235 / Thursday. Doccmbnr 7, 1005 / Rules a::d
0204')
(n) Where an incinerator is used, a
temperature monitoring device
equipped with a continuous recorder is
required.
(A) Where a thermal incinerntor is
used, a temperature monitoring device
shall be installed in the firebox or in the
ductwork immediately downstream of
the firebox in a position before any
substantial heat exchange occurs.
(B) Where a catalytic incinerator
equipped with a fixed catalyst bed is
used, temperature monitoring devices
shall be installed in the gas stream
immediately before and after the
catalyst bed.
(C) Where a catalytic incinerator
equipped with a fluidized catalyst bed
is used, a temperature monitoring
device shall be installed in the gas
stream immediately before the bed. In
addition, a pressure monitonng device
shall be installed to measure the
pressure drop across the catalyst bed.
The pressure drop shall be measured
monthly at a constant flow rate.
(iii) Where a carbon adsorber is used
one of the following is required:
(A) An integrating 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 or ±0.5 °C,
whichever is greater, and capable of
recording the carbon bed temperature
after each regeneration and within 15
minutes of completing any cooling
cycle;
' (B) An organic monitonng device.
equipped with a continuous recorder, to
indicate the concentration level of
organic compounds exiting the carbon
adsorber or
(C) Any other monitoring device that
has been approved by the Administrator
in accordance with §63.804(f)(4)(iv)(D).
(iv) Owners or operators of an affected
source shall not operate the capture or
control device at a daily average value
greater than or less than (as appropriate)
the operating parameter values. The
daily average value shall be calculated
as the average of all values for a
monitored parameter recorded during
the operating day
(v) Owners or operators of an affected
source trial are complying through the
use of a catalytic incinerator equipped
with a fluidized catalyst bed shall
maintain a constant pressure drop.
measured monthly, across the catalyst
hud
(•. i) An owner or operator using a
control uevice not listed in this section
snail submit to the Administrator J
description of the device, test data
verifying thu performance of tlin device.
mid appropriate operating parameter
values that will bo monitored lo
demonstrate continuous compliance!
with tho standard. Compliance using
this device is subject to the
Administrator's approval.
(7) Owners or operators of an affected
source subject to the provisions of
§63 802 (a)(3) or (b)(3) shall submit a
compliance certification with the
semiannual report required by
§63807(c).
(i) The •compliance certification shall
state that compliant strippable spray
booth coatings have been used each day
in the semiannual reporting period, or
should otherwise identify each day
noncompliant materials were used. Each
day a noncompliant strippable booth
coating is used is a single violation of
the standard.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
(8) Owners or operators of an affected
source subject to the work practice
standards in § 63.803 shall submit a
compliance certificalion with the
semiannual report required by
§63.807(c).
(i) The compliance certification shall
state that the work practice
implementation plan is being followed,
or should otherwise identify the
provisions of the plan that have not
been implemented and each day the
provisions were not implemented.
During any period of time that an owner
or operator is required to implement the
provisions of the plan, each failure to
implement an obligation under the plan
dunna any particular day is a violation.
(ii) The compliance certification shall
be signed by a responsible official of the
company that owns or operates the
affected source.
§ 63.805 Performance test methods.
(a) The EPA Method 311 of Appendix
A of part 63 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. The EPA Method 311 shall then
be used to quantify those VHAP
identified through formulation data. The
EPA Method 311 shall not be used to
quantify HAP such as styrene and
formaldehyde that are emitted during
the cure The EPA Method 24 (40 CFR
pan 60. Appendix A) shall be used to
determine the solids content by weight
and the density of coatings. If it is
demonstrated to the satisfaction of Uie
Administrator that a coating does nut
release VOC or HAT byproducts during
the cure for uxamplc. a.! VOC im: i'.AP
present in the coaling is solvent, thfn
batch formulation information sh.ul »e
accepted. The owner or operator of ..n
affected source may request approval
from the Administrator to use an
alternative method for determining ;he
VHAP content of the coating In the
event of any inconsistency between the
EPA Method 24 or Method 311 test data
and a facility's formulation data, that is.
if the EPA Method 24/311 value is
higher, the EPA Method 24/311 test
shall govern unless after consultation, a
regulated source could demonstrate to
the satisfaction of the enforcement
agency that the formulation data were
correct. 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. (Docket No. A-93-10.
Item No. IV-A-1).
(b) Owners or operators
demonstrating compliance in
accordance with § 63.804 (fl(4) or (f)(6)
and § 63.804 (g)(4) or (g)(6). or
complying with any of the other
emission limits of § 63.802 by operating
a capture or control device shall
determine the overall control efficiency
of the control system (R) as the product
of the capture and control device
efficiency, using the test methods cited
in § 63.805(c) and the procedures :n
§63.805 (d)or(e).
(c) When an initial compliance
demonstration is required by § 63 804
(f)(4) or (f)(6) of this subpart. the
procedures in paragraphs (c)(l) through
(c)(6) of this section shall be used in
determining initial compliance with the
provisions of this subpart.
(1) The EPA Method 18 (40 CFR pan
60. Appendix A) shall be used to
determine the HAP concentration of
gaseous air streams. The test shall
consist of three separate runs, each
lasting a minimum of 30 minutes.
(2) The EPA Method 1 or 1A (40 CFR
part 60. Appendix A) shall bs used for
sample and velocity traverses.
(3) The EPA Method 2. 2A. 2C. or 2D
(40 CFR part 60. Appendix A) shall he
used to measure velocity and volumetric
flow rates.
(4) The EPA Method 3 (40 CFR part
60. appendix A) shall bu used to analyze
the exhaust gases.
(5) The EPA Method 4 (40 CFR part
GO. Appendix A) shall be used to
measure the moisture in the stock gab
(G) The EPA Methods 2. 2A. 1C. -1.0,
3. and 4 shall be por'.onued. as
applicable, at leas! twice during eacii
test period
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f>294() Federal Rcc;ister
60. No. 235 / Thursday. December 7, 1095 / Rales nr.d Ree'ilaticr.s
Iri; C.ic.h owner or operator ol an
nfrt/r:ed source demonstrating
compliance in accordance with §63 804
f!'4, or (0(6) shall perform a gaseous
emission test using the following
procedures'
II Construct the overall HA?
emission reduction system so that all
volumetric flow rates and total HAP
emissions can be accurately determined
by the applicable test methods specified
in § 63 805(c) (1) through (6);
(2j Determine capture efficiency from
the affected emission point(s) by
capturing, venting, and measuring all
HAP emissions from the affected
emission point(s). Dunng a performance
test, the owner or operator shall isolate
affected emission poinl(s) located in an
area with otncr nonaffectcd qnsoous
emission sources from all other gnscous
emission potnl(s) hv any of the
foiiow ;r.g methods.
(i: 3u.:d a temporary1 total enclosure
(see 5 53 301) around''.he affected
emission pomt;s). or
(11) Use the building that houses the
process as the enclosure (see §63 801).
(iii) Use any alternative protocol and
test method provided they meet either
the requirements of the data quality
obiective (DQO) approach or the lower
confidence level (LCL) approach (see
§63 801);
(iv) Shut down all nonaffected HAP
emission point(s) and continue to
exhaust fugitive emissions from the
affected emission poi-.t's T-rcu^" ;-,•.
building v'ef.tiint.ori v.sier". ar.vl ?;:•,'"•
room exMausts snr:\ as cr. .re OVP.-S \'.\
ex.'iatis; air musi be •.er.tcc: "iro'.j",
stacks suitable for testing or
(v] Use anotre' met.h.ocologv
approved bv the Administrator prcv..:e:..
ii compiles with the EPA criteria for
acceptance under part 63. appendix A.
Method 301.
(3) Operate the control device with :'.!
affected emission points that will
subsequently be delivered to the cor.'.rc:
device connected and operating at
maximum production rate;
(4) Determine the efficiency (F) of the
control aevice using the following
equation:
F -
(Equation 5)
(5) Determine the efficiency (N) of the
capture system using the following
equation.
N =
(Equation 6)
(6) For each affected source
complying with § 63.802(a)(i) in
accordance with §63.804(a)(3).
compliance is demonstrated if the
product of (FxN)dOO) yields a value (R)
such that the value of EK in Equation 2
is no greater than 1.0.
[~] For each new affected source
complying with § 63.802fb)(l) in
accordance with §63.804(d)(3),
compliance is demonstrated if the
product of (FxN)dOO) yields a value (R)
suca mat the value of E,* in Equation 4
is no greater than 0.8.
(3) For each affected source
complying with § 63 802(a)(2)(ii) in
accordance with § 63.804(c)(2),
compliance is demonstrated if the
product of (FxN)(100) yields a value (R)
such mat the value of G* in Equation
3 is no greater than 1.0.
(9) For each new affected source
complying with § 63.802(b)(2) in
accordance with § 63.804(e)(2).
compliance is demonstrated if (he
product of (FxN)dOO) yields a value (R)
such that the value of GK in Equation
3 is no greater than 0.2.
(e) An alternative method to the
compliance method in §63.805(d) is the
installation of a permanent total
enclosure around the affected emission
pomt(s). A permanent total enclosure
presents prima facia evidence that all
HAP emissions from the affected
emission point(s) are directed :o the
control device. Each affected source that
complies using a permanent total
enclosure shall:
(1) Demonstrate that the total
enclosure meets the requirements in
paragraphs (e)(l) (i) through (iv). The
owner or operator of an enclosure that
does not meet these requirements may
apply to the Administrator for approval
of the enclosure as a total enclosure on
a case-by-case basis. The enclosure shall
be considered a total enclosure if it is
demonstrated to the satisfaction of the
Administrator that all HAP emissions
from the affected emission point(s) are
contained and vented to the control
device. The requirements for automatic
approval are as follows:
(i) The total area of all natural draft
openings shall not exceed 5 percent of
the total surface area of the total
enclosure's walls, floor, and ceiling:
(n) All sources of emissions within
the enclosure shall be a minirr.um of
four equivalent diameters away from
each natural draft opening;
(in) The average inward face velocity
(FV) across all natural draft openings
shall be a minimum of 3.600 meters per
hour as determined by the following
procedures.
(A) All forced makeup air ducts and
all exhaust ducts are constructed so that
the volumetric flow rate in each can be
accurately determined by the test
methods specified in § 63.805 (c)(2) and
(3). Volumetric flow rates shall be
calculated without the adfustment
normally made for moisture content.
and
(D) Determine FV by the following
equation:
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Federal Register Vol. 60, No. 235 / Thursday, December 7. 1095 / R.iirs .inc. K^'.;.v.:-;s r>2947
FV = —
(Equation 7)
(iv) All access doors and windows
\vhose areas are not included as natural
draft openings and are not included in
the calculation of FV shall be closed
during rouune operation of the process.
(2) Determine the control device
efficiency using Equation (5), and the
test methods and procedures specified
in §63.805 (c)(l) through (6).
(3) For each affected source
complying with § 63.802(a)(l) in
accordance with §63.804(a)(3),
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is dsmonstrated {N=l};
(ii) The value of F is determined from
Equation 15); and
lui) The product of (FxN)dOO) yields
a value (R! such that the value of Eac in
Equation 2 is no greater than 1 0.
(4) For each new affected source
complying with §63.802fb)(l) in
accordance with § 63.304(d)(3),
compliance is demonstrated if-
(i) The installation of a permanent
total enclosure is demonstrated (N = 1),
(11) The value of F is determined from
Equation [5;; and
<:u) The product of [F*N)(iOO! yields
a value tRJ such that the value of E« iri
Equation 4 :s no greater than 0.8
,5) For each affectec source
complying with §63 802;a)(2)(ii) in
accordance with §63 804v'c)(2j.
compliance :s demonstrated if.
(ii The installation of a permanent
total enc.osare is demonstrated (N=l).
In) The value of F is determined from
Zcuation (5) and
';..:, The product of (FxNKlOO) yields
a \ alue (RJ such that tne value of Gac in
Equation 3 is no greater than 1.0.
'6) For each new affected source
complying with § 63.802(b)(2) in
accordance with § 63.804(e](2).
compliance is demonstrated if:
(i) The installation of a permanent
total enclosure is demonstrated (N=l);
In) The value of F is determined from
Equation J5). and
Uii) The product of (FxNJ(lOO) yields
a value (R) such that the value of Cx in
Equation 3 is no greater than 0.2.
§ 63.805 Recordfceeplng requirements.
(n) The owner or operator of an
affected source sublet to this subpart
sriol! fulfil! all recordkueping
requirements of §63 10 of subpnrt A.
according to the applicability cnturia in
§ GT 8GU(«! of this subpnrt
fb) The owner or operator of an
affected source subject to the emission
limits in § 63.802 of this subpart shall
maintain records of the following:
(1) A certified product data sheet for
each finishing material, thinner, contact
adhesive, and strippable spray booth
coating subject to the emission limits in
§63.802; and
(2) The VHAP content, in kg VHAP/
kg solids (Ib VHAP/lb solids), as
applied, of each finishing material and
contact adhesive sub)ect to the emission
limits in §63.802; and
(3) The VOC content, in kg VOC/kg
solids (Ib VOC/lb solids), as applied, of
each stnppable booth coating subject to
the emission limits m § 63.802 (a)(3) or
fb)(3).
(c) The owner or operator of an
affected source following the
compliance method in § 63.804 (a)(l) or
(d)(l) shall maintain copies of the
averaging calculation for each month
following the compliance date, as well
as the data on the quantity of coatings
and thinners used that is necessary to
support the calculation of E in Equation
\.
[d] The owner or operator of an
affected source following the
compliance procedures of §63 804
(0(3)(ii) and (g)(3)(ii) shall maintain the
records required by § 63 806(b! as well
as records of the following:
(1) Solvent and coating additions to
the continuous coater reservoir;
(2) Viscosity measurements; and
(3) Data demonstrating that viscosity
is an appropriate parameter for
demonstrating compliance.
(e) The owner or operator of an
affected source subject to the work
practice standards in § 63.803 of this
subpart shall maintain onsite the work
practice implementation plan and all
records associated with fulfilling the
requirements of thai plan, including, but
not limned to-
ll) Records demonstrating that the
operator training program required by
§63 803(b) is in place;
(2) Records collected in accordance
with the inspection and maintenance
plan required by § 63 803(c);
(3) Records associated with the
cleaning solvent accounting system
required by §ri3.Q03(d);
(4) Records assocmtud with the
limitation on the use of conventional air
spray guns showing total
material usage and the oercer.tage of
finishing materials applied with
conventional air spray guns for each
semiannual period as required bv
§63.803(h)(5)
(5} Records associated with the
formulation assessment plan recaired
by §63.803(1); and
(6) Copies of documentation such as
logs developed to demonstrate mat tne
other provisions of the work pract.ce
implementation plan are followed.
(f) The owner or operator of an
affected source following the
compliance method of §63.804 (fi(4) or
(g)(4) shall maintain copies of tke
calculations demonstrating that the
overall control efficiency (R) of the
control system results in the value of E.C
required by Equations 2 or 4, records o;
the operating parameter values, and
copies of the semiannual compliance
reports required by § 63.807(d).
(g) The owner or operator of an
affected source following the
compliance method of §63 8C4 'f!(o! or
(gK6), shall maintain copies of T.e
calculations demonstrating that :~e
overall control efficiency R) of :he
control system results in tne appucoo.e
value of Gac calculated using Equation 2,
records of the operating parameter
values, and copies of the semiannual
compliance reports required bv
§63307(d).
fh) The owner or operator of an
affected source subject to the emission
limits in §63 802 and following the
compliance provisions of § 63 834!f; (1).
(21. (3), (5). 17> and (8) and §53 304'.gj
(;), (2), (3), (5). (7), and (8) shall
maintain records of the ccrr.oharce
certifications submitted in acccrciuce
with § 63 607(c) for each semiannual
period following the compliance date
(i) The owner or operator of an
affected source shall maintain records of
ail other information submitted with the
compliance status report required by
§63.9(h)and§63.807(b) and the
semiannual reports required by
§63.807(c)
(j) The owner or operator of an
affected source shall maintain ail
records in accordance with the
requirements of § 63.lO(b)(l).
§63.807 Reporting requirements.
(a) The owner or opurator of an
affuctud sourcu subject to this subpart
-------
G2940 Federal Register
60. No 235 / Thursdav, December 7 100=5
sh.ii'i rj.fi!! n;l reporting roqu'.rerrun's of
5 -'i3 : through § 63 1.0 of suopar. A
; General Provisions) according '.o the
applicability criteria ;.n § 63 OOOjd; cf
this suopart
!'b', The owner or operator of an
affected source demonstrating
corr.~'..ar.ce in accsraance with
§63 304if) ill. (-!, (3i. (5). (7) and (8)'
snail submit trie compliance status
report required oy §53 9(hj of subpart A
(General Provisions) no later than 60
days after the compliance date The
report shai! inciuae me .nformation
required by §63.804:0 !H. (-], t3i, ',5).
(7). and (8) of this subpan.
(c) The owner or operator of an
affected source demonstrating
compliance m accordance with
§53 804(g) (i;. CU3U5), (7), and (8)
shall submit a report covering the
previous 6 months of wood furniture
manufacturing operations:
;*.) The first report shall be submitted
30 calender days after tne end of tne
first 6-month period following the
compliance date
(2) Subsequent reports shall be
submitted 30 calendar days after the end
of each 6-month period following the
first report.
I3i The semiannual reports shrill
include the information recuircd by
§ 63 804'g) ill. (:;. (3!. i'5i, ;-]. ir.d''F .
i statement cf whether '.he affected
scurr.c '.vas in compliance or
noncompliancG. and. if the affected
source was in noncompiiance the
measures taxen to bring the affected
source into compliance.
(4) The frequency of the reports
required by paragraph (c) of tnis section
shall not be reduced from semiannual!)'
regardless of the history of the owner s
or operator's compliance status
(d) The owner or operator of an
affected source demonstrating
compliance in accordance with
§ 63.804(g) (4) and (6) of this subpart
shall submit the excess emissions and
continuous monitoring system
performance report and summary report
required by § 63.10(e) of subpart A. The
report shall include the monitored
operating parameter values required by
§ 63.804(g] (4) and (6). If the source
experiences excess emissions, the report
shall be submitted quarterly for at least
1 year after the excess emissions occur
and until a request to reduce reporting
frequency is approved, as indicated in
§ 63.10(e')(3)(C'i. If no excess emissions
ocrur :;ie report 3r.a.. ~e ^i.~~ '.:o-u
semiannuallv
'i.') The owner or J"IT;;C: cf ar.
affected source requeue to p-~ ! 3C3 1, -
sr.a.l inciuco .p. the notification one cr
norc statements that explains the
reasons for the usage increase The
notification sha.l be submitted no later
than 30 csiencar da> s after the end of
the annual per.od in wmch tr.e usage
increase occurred.
§63.308 Delegation of authority.
(a) In delegating implementation and
enforcement authority to a State under
§ 112(d) of the Clean Air Act. the
authorities contained in paragraph (hi cf
this section shall be retained DV the
Administrator and not transferred to a
State.
fb) The authority conferred in
§63.804(f)(4)(iv)(D)and(E).
§63 804(g)(4!(iii)(C), §63.804(g)(4)(va
§63.804(g)(6)(vi).§63803(a),
§53.3CVd!C!(V;.and § 63.8Q5(e](l)
shall not be delegated to any State.
§§63.809-63.319 [Reserved]
Tables to Subpart H to Part 63
TABLE i.—GENERAL PROVISIONS APPLICABILITY TO SUBPA" JJ
Reference
«''a.
63 ' 0)C 1
52 ',£:,?'
63 '(tJ),3)
63 Kc'1' '
63 t(c'i9)
63 tic, i-t)
63Kc,i5)
63 Me)
632
53 3
534
S3 5
63 Sia)
63 5(t)(1)
52 5ibi'2)
53 SiC:i3)
53 5(bh('i}
63 5(Ci(e)
53 5(6i(7) ...,.
63 6(c)(')
63 6(0(2'
53610(5)
535(e;(')
536(e)(2)
536(e!i3)
635(f)C) . .
Applies to
sucoart .J
Yes
MO
Ves
Yes
No
NO
Yes
Yes
Yes
Yes
Yes
Yes
•^es
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
NO
Comment
Sufcpart jj specifies applicability.
Subcart JJ specifies applicability.
Area sources a/e not sub|ect to suopart JJ
Additional terms are defined m 63. 301 (a) of subpart JJ. When overlap Between suocars A and jj occurs.
subpart JJ takes precedence.
Other units used in subpan JJ are defined in 63.801 (6)
Mav apply when standards are proposed under Section 1 12(0 of the CAA
Applies oniv to affected sources using a control device to comply with the rule
AHected sources complying through the procedures specified in 6330- ;a)C), ia)(2), ib). tc)|i). ISM"".
63 6(0(2!
536(0(3)
53 5(g)
53 5th)
535 (ni-;-
63 6d;'-i ('
Yes
Yes
, Yes
! so
i Yes
! Yes
(OH2), (e)(i), and (e)(2) are suDiect to the emission standards ai ail times, including periods of startup
snutcown. and malfunction.
-------
Federal Register -' Vol 00. No. 235 / Thursday. December 7, 1995 / Rules and Kea'.i.at.o;^ G2049
TABLE 1 — GENERAL PROVISIONS APPLICABILITY TO SUBPART jj — Continued
Reference
53 5(i)(4)(u)
63.6 (i)(5)-(i)(l4) ..
535(i)M6)
63 5(j)
53 7
63 3
63 9(a)
63 9(b) . . ..
639(c)
63 9(d)
63 9(e)
63 9(f)
63 9(a) .. ..
63 9(h) .. .
639(i)
639(j)
63 10(3)
S3 10(b)(1)
5310fb)(2) ...
63 I0(b)(3)
63 10(C)
63 10(d)(1)
53 I0(d)(2) .. . .
63 10(d)(3)
63 10(d)(4)
63 I0(d)(5)
63 10(6)
63 10(0
6311
63 12-63 15
Applies to
subpart JJ
NO.
Yes
Yes
Yes
Yes .
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
NO
Yes
Yes
Yes
Yes
NO
Yes
Comment
Applies only to affected sources using a control device to comply with the ruie.
Applies only to affected sources using a control device to comply with the rule
Existing sources are required to suDmit initial notification report within 270 days ot the effective date.
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with trie rule.
63.9(h)(2)(u) applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with trie rule.
Applies only to affected sources using a control device to comply with the rule.
Applies only to affected sources using a control device to comply with the rule.
TABLE 2.— LST OF VOLATILE TABLE 2.— LIST OF VOLATILE HAZARD- TABLE 2.— LIST OF VOLATILE HAZARD-
HAZARCOUS AIR POLLUTANTS ous AIR POLLUTANTS — Continued ous AIR POLLUTANTS — Continued
Chemical name
Acetaide^yCe
Acetonitnie
Acetophenone
2-Acetylamincfluorme
Acrolein
Ac."y!amice
Acrviic acid
3enz:dine
Bis(2-ethyihexyl) phthaiate
(OEHP)
Btsfcriiorometnyi) em
SromofQfrn
Carbon disuifide ..
Carbon tetracnionde
Catecnoi
Chioroacetic acid
2-Chioroacetccnenone . . .
Chlorobenzene . . .
Chloroform
CMoromelhyl melhyl ether
CAS No. Chemical name
75070 Cresols (isomers and mixture)
50355 o-Cresol
75058 rrvCresol
98862 p-Cresol
5^963 Cumene
10702S 2,4-0 (2,4-Dicf • -ophenoxyacetic
79061 ac:d. including oalts and esters)
79107 DDE (i,i-Dichloro-2.2-bis (p-
107131 chloropnenyl) etriylene)
107051 D'azom*i*i3n* —
92671 Dibenzofuran
62533 1 ,2-Qibromo-3
-------
02050 Federal Register - Vol. 60, No. 235 / Thursday, December 7. ijQS / Rules and
T*BL= 2.—LIST OF VOLATILE HAZARD-
OUS A;R POLLUTANTS—Continued
Chemical name j CAS No
Methyihycrazine | 6C344
Met*vi occe ilodomethanei 74834
Mei^yi sooutyi Ke'.one (Hexone) . '08'01
Methyl socyanate 624S39
Methyl -nethacryiaie j 30625
Methyl tert-Dutyl ether 16340-4
-.4 -Methyienebis ;2-cnioroanihne) 101 '44
Methylene chloride (Dichloro-
metnane) 75092
4,4'-Methyieneciiphenyl
dnsocyanate (MDI) 101638
4,4'-MetTiyienedianiline 101779
Naphthalene 91203
Nitrobenzene 98953
4-Nitrobiphenyl ' 92933
4-Nitropnenol 100027
2-Nitroprooane 79469
N-Nitroso-N-methyiurea 684935
N-Nitrosodimethyiamine 62759
N-Nitrosomorphonne 59892
Phenol 1C8952
p-Phenyienediamine 106503
Phosgene 75445
Phthaiic anhydnde 85449
Poiychlcnnated biphenyls
(Arociors) 1336363
TABLE 2.—L;ST OF VOLATILE HAZARD- TABLE 2 —LIST c= VCLA"LE HA:A=;
Cus AIP POLLUTANTS—Continued Cus AIR PCLL-'ANTS—Con: ^ec
-ame
Poiycycnc Organic Matter*
1.3-P'Opane sultone
beta-Prcoioiactone
Propionaioehyde
P'opoxur (Baygon)
Propyiene dichionde C.2-Oi-
chloropropanei
Propyiene oxide
1.2-?ropyienimine (2-Methy! azin-
dine)
Qumone
Styrene
Styrene oxide
2,3,7,8-Teupachiorodibenzo-p-
dioxin
1,' ,2.2-Teu-achioroethane
TetrachtoroetMylene
(Perchloroethyiene)
Toluene
2.4-Toluenediamme
Toiuene-2,4-dnsocyanate
o-Toluidine
1.2.4-Tnchlorobenzene
1,1.2-Tnchloroethane
Tnchloroetrryiene
CAS NO
57573
•23336
114251
78875
75569
75558
106514
100425
96093
1746016
79345
127184
108883
95807
584849
95534
120821
79005
79016
2,4 5-Trichloropr.enci .
2.4.5-Tnchioropner.ci
"nethylamine . . . .
Tflluraiin . . . . .
2 2.4-Tnmethvipentare
Vinyl acetate
Vinyl bromiGe
Vinyl chlonoe ...
Vinyhdene chionce (' .'Ochiorc-
etfiyiene)
Xylenes (isomers ana mixture)
o-Xylene
m-Xylene
p-Xylene
aece;
•2-443
'582053
54CS4'
' C8C54
5936C2
750^4
75354
133C2C7
95475
'C83S3
'06423
'Includes mono- anc ci-ethers of ethyiene
glycol. dietnylene glycols and triethyiene giy-
coi: R-(OCH^CH-)Rfi-OR wnere-
n - 1. 2, or 3,
R » allcyl or aryl groups
R' » R. H, or groups which, when removed.
yield glycol ethers with the structure: R-
(OCH;CH;)r-CH. Polymers are excluded from
the glycol category.
0 Includes organic compounds with more
than one benzene 'Tig, and wmcn have a boil-
ing point greater than or equal to 100*0.
TABLE 3.—SUMMARY OF EMISSION LIMITS
Emission point
Existing
source
New source
1.3 *
4.3 '
•0
>~ 3
'0 3
•C 3
«-°C 3
"C 3
1C 2
ere is ro nmit on the VHAP content of these adhesives
''he control device must operate at an efficiency that is equivalent to no greater than 1 0 kilogram (or 0.2 kaogrami ol VHAP being emitted
from the aflec'.ea emission source per kilogram o( solids used.
u ~
'02
-------
rodcral Register / Vol 60. No. 235 / Thursday. December 7. 1905 / Rules ar.cl Reculat;ons 02951
Taste 4.—POLLUTANTS EXCLUDED TABLE 4.—POLLUTANTS EXCLUDED
FROM USE IN CLEANING AND FHOM USE IN CLEANING AND
WASHCFF SOLVENTS WASHOFF SOLVENTS—Continued
TABLE 6 —VHAP OF POTEN~AL
CONCERN—Continued
CAS No I Chemical name
Chemical name
4-Aminobipfienyi
Styrene oxide
Diethyl suttate
N-Nitrosomorpnolme ....
Dimethyl lormamide
Hexamethyiphospnoramide
Acetamide
4 4'-Methyienedianiline
o-Anisidme
2.3.7,3-Tetrachiorodibenzo-p-
dioxin ..
Beryllium salts
Benzidine ,..
N-Nitroso-N-methylurea
Bis(chloromethyl)etrier
Dimethyl carbamoyl chloride . ..
Chromium compounds
(hexavaient)
1 ,2-Propyienimine (2-Methyi
azindine} . .
Arsenic and inorganic \arsenic
Hydrazine
• •-Dimethyl hydraztne
Beryllium compounds
1 ,2-Oibromo-3chlorophenyl 1-2
dichloroethyiene)
QicnlOfvos
Vinyl chlonde
Coke Oven Emiss.ons
E'.hylene oxide
Einyiene thiourea
Vinyl bromide (brcmoethene) . .
Seienium sultiOe (mono and di)
Chioiolorm
Pentachiorophenoi
E'.nyi caroamale (Ureihane)
CAS No Cfwmwj cun*
92671
96093
64675
59892
68122
680319
50355
101779
90040
1746016
92875
684935
542881
79447
75558
99999904
302012
57147
7440417
96123
62759
5C32S
1 336363
75448
119937
12035722
79061
113741
57749
1120714
106990
53963
53963
58899
1 1 1444
122567
8001352
121142
119904
50000
101144
107131
106934
72559
510156
62737
75014
99999908
75218
96457
593602
7488564
67663
87865
51796
Ethyiene dichtonde (1,2-
O'Chloroethane)
Propylene aicnlord* (1,2-
Dichloropropane)
Carbon tetrachioride
Benzene ....
Methyl hydrazine . .
E'hyi ac'yiate
Propylene oxide
Aniline
i 4-Dichlorob*nzeneryethyl acetate 1 1 1 1 59
EPA de 72559
mintmis,
tons/yr 510156 ....
62 /'S/ . ..
' ° 75014
°-2 75218
4 ° 96457
1 ° 593602 ....
0 7 67563
1 ° 87865
l\ 51796
50 107062
100
5-0 78fl75
TABLE 6 —VHAP OF POTENTIAL 7^32 ";;;;;
CONCERN 140885 ....
7cccn
CAS No Chemical name 62533 . .
•If 4fi't
"Nonthreshold" Pollutants 88062 ....
92671 4-Ammobiphenyl.
96093 Slyrene oxide 95534
64675 .. Dieihyl suKaie 114251
N-Nitrosomorpholine
Dimethyl (ormamide
Hexamethy'phospnoramide
Acetamide.
J ,4'-Methyienedianiline
c-Anisidme
2.3,7.8-Tetrachlorodibenzc-D-
dioxmdioxin
Benzidine
N-Nitroso-N-methylurea.
Bis(chloromethyl)ether
Dimethyl carbamoyl chloride.
1 ,2-Propylenimme (2-Methyl
azindine)
1,1 -Dimethyl hydrazme.
1 ,2-Oibromc-3-cnioropropane.
N-Nitrosodimethytamme.
Benzo (a) pyrene.
Poiychlormated biphenyts
(Aroctors).
Heptacnior.
3,3'-Oimethyl benzidine.
Acryiamtde.
hexachlorobenzene.
Chiordane.
1 ,3-Propane suitone.
1 ,3-8utadiene.
2-Acetyiammoflounne.
3.3'-Oichiorobenzidine.
Undane (hexachlorcyciohexane.
gamma).
2, 4- Toluene diamme.
Dichloroethyt ather (Bis(2-
chloroethyl)ether).
1 .2 - Oipftenylhydrazine.
Toxapnene \chlonnated
camphene)
2.4-Omitrotoluene.
3.3'-Dimethoxybenzidine.
Formaldehyde.
4.4'-Methylene bis!2-
cnloroaniline).
Acryionitrile.
Ethyiene dibromide(i ,2-
Oibromoethane).
DDE (1,1-p-chlorophenyl i-2
dichloroethylene)
Chlorobenzilate.
Dichlorvos
Vinyl chlonde
Ethyiene oxioe.
Ethyiene thiourea.
Vinyl bromide (bromoethene!
Chloroform
Pentachiorophenoi.
Ethyl carbamate (Urethane)
Ethyiene dichionde (V2-
Dichioroethane).
Propylene dichlonde ( 1 .2-
Dichioropropane)
Carbon tetrachioride
Benzene
Elhyl acrylate
Propylene oxide
Aniline
1 .4-DichloroDen:eneip!
2.4 6-Tncniorophenol
8is(2-elhyihexyl)pniriaiate
(DEHP)
o-Toiuidme
Propoxur
-------
()2932 Federal Register ' V->1 60. No. 235 / Thursday. Dncnnibcr 7. 1915 / Rules nr.a :<°c;..;v
TAB.E 6.—VHAP OF POTENTIAL
CONCERN—Continued
j Chemicai -
TABLE 5.—VHAP OF POTENTIAL
CONCERN—Continued
~C-C'5 ....
•O-l^i .
75C70 ....
75:52
•33C5C ...
•C6398 ..:..
75C92
',27134
53703
218019
50117
56553
205992
79469
542756
5T9 / 6
225514
193395 ....
189559
73345
51225
75354
S7583
32538
7359'
'9005
74873
£ £ *
•532:93 ..
1319773 ..
•C3394 ...
75343 ...
95437
•35445 ..
74384
I00-i25 ....
i _< / ^5 ...
334533
S5954
•33904 ..."
•35387 .. .
•33054
•25398 ...
'23319 ....
3-2933
T'ic.iloroethyiene
1,4-Oioxane ('
Oiethyleneoxide)
AcetaiCenyde.
Bromotorm.
Captan
Esichiorohydnn
4-
Metnyiene cnicnde
i_Dichioromethane)
Tetracnioroethyiene
(Percnioroethyiene).
Oibenz (ah) antnracene.
Chrysene.
Dimemyl ammoazobenzene.
Benzo (a) antnracene.
Benzo (b) fluoranthene.
2-Nitrooropane.
1 ,3-Dicnioropropene.
7, '
Oimetnyiber.z(a!anthracene.
Benz(c)acridine.
Indenon ,2.3-cd)pyrene.
1 .2:7.8-Dibenzopyrene
1 .1 ,2.2-Tetrachicroethane.
Guinoline.
Vinyiidene chlonde ('
Oicnloroetriylene).
Hexacfiiorcbutadiene.
Pentachioronitrobenzene
(Qumtobenzenej.
Isoonorone.
' ,1 ,2-Tnchloroethane
2-
• .
Methyl cfilonde
fChioromethape!.
nexacnioroetnane
Tnfluralm
CresciaCresylic acid (isomers
and mixture).
rn-Cresol
E'.hvncene dicMonde (i
Oichloroe thane;
o-Cresoi.
c-Cresol.
Methyl iodide (lodomethane).
Styrene1
Ailvl Chloride.
Diazomethane.
2.4.5 - Tnchloropnenoi
ChicramPen.
i ,2 - Epoxybutane
vmyi acetate.
Chloroorene
nyaroquinone.
4-Nitrobipnenyl
1-
"High-Concern" Pollutants
56332
•,3453393
5C344 . .
75218 ..
'5 '554 ....
77731 ...
'373C2 .
5-573 .
•30447 ..
9 "377
. ~ -*1OQ
*- ' o«_O
5M849
'574'
'2CC2
3arathion.
N.cxei Carbonyl
Methyl hycrazine
E'.hyiene oxide
Elhyiene immc
D, methyl suliute
Chioromethyl methyl ether
Dcta-°ropiciac;one
Benz>i chlonde
Senzotricnionde
Acroicm
2.ead
Tetrae'.rwi ieac
'2'08'33 • Mettiylcyclcpemaaienyl mar>-
[ ganese
624839 ... i Methyl isocyanate
7~474 Hexacnlorocycicpentadiene.
52207765 Fluomme
1C2'0681 Cobalt carbonyi.
791'8 Chloroacetic acd.
534521 .... 4,5-Dimtro-o-cresol, and salts.
101533 .... Methylene dipheryl
diisocyanate.
108952 .... Phenol.
62354 Mercury, (acetatc-o) phenyl.
98862 Acetophenone.
108316 Maleic anhydride.
532274 2-Chloroacetophenone.
51235 2.4-Oinrtroprtenol.
108364 2-Methyoxy ethanol.
989-3 Nitrobenzene.
74839 Metnyl bromide
(Bromome thane).
75150 Carbon disulfide.
121697 N,N-Oimethylaniline.
4n:7-q.i or ASTM
D 1-n:-8'J Metiioci
volntilc HAP's wnic
"Unrankable" Pollutants
106514 Quinone.
123386 Propionaldehyde.
12CS09 Catechol.
35443 ! Phthalic anhydride.
453581 | Carbonyl sulfide.
'32649 .... ! Oibenzofurans.
10CC27 4-Nitrophenol.
540841 ... [ 2,2.4-Tnmethyipentane
• '422 ! Diethanolamine.
S22C50 .. 1 riexamethylene-1.5-diisocvanate
j Giycol ethers0
i Polycyclic organic rnanef
' - Currency an EPA weight of evioence
classification is under review
•The EPA does not currently have an offi-
cial weigfit-o(-«vicence classification lor sry-
rene. For purposes of tnis rule, styrene >s
treated as a "nonthreshoid" pollutant (See
aata 'eporr form m appendix A of the hazard
ranking technical background document)
n Except lor 2-ethoxy ethanol. ethyiene giy-
col monobutyl ether, and 2-methoxy etnanci
' Except lor Denzofblfluoranthene.
ber.zoiaianthracene, benzo(a)pyrene. 7 12-
dimethyioenz(a)anthracene. Denz(c)ac.-iC.re.
cnrvsene. diDenz(an) anthracene. 1 2.7.8-
c.cer.zopyrene. mdeno(l ,2.3-cd)pyrene. but in-
cluding dioxms and (urans
3 Appendix A of part 63 is amended
by adding Method 311 to read as
follows:
Appendix A to Part 63—Test Methods
Method 311—Analysis of Hazardous Air
Poltuta::; Compounds in Paints and Coalings
bv Direct In/ection Into n Cns Chromatogrnph
I Scope and Application
1 1 Applicability This method is
.iiipiiL.iuic for dutcrminjtion nf most
c-jinnounds deiigrutcd bv the U S
C.-H'itunrnrrr.jl Protection Agcnrv us voi.it.lc
iiniariious riir pollutants (HAI''s) (Sir
Rffcrciiro 1) (hot arc contained ir. p.iinib .i:u!
< i,.i',,!ii^ Sivrrnr. ethyl nrryl.ilo am! inethvl
iiu'tiMLi'vi.iti; c.iii be nirasurcd bv A.STM 'J
contms when it is rr.iin'.ifacturo': -.0; '3 •„-.". :
w'lich mav form .TS nc contir/,; r.ir'.'s
(rcoction products or cure vola:. cs, \
scpjrnto or rr.ociif.ec 'cst proc-ij -T ^L,S; ;«•
used to miMii.rr '.no?e rcact.cn prouucts 3r
c-ru volr'.^.^s in oracr to Setorrr >::e .r.e '€'.„.
vointile hAi' cm;si'.crs ~cr~. : -sa: "~.g C-r:
\oiar.les arf a sign.f.car: corr.rcr.c-.'. ;f T.»
total HAP content ofscmc ccat.r.gs ~-.s :c-rr.
"coating" used in this rr.etncc sr.ai! oe"
understood to mean paints ar.c coatings.
1.2 Principle The rr.et.1oc uses :r.e
principle of gas chromatograpnic separation
and quantification using a detector tr.a:
responds to concentration differences
Because there are many potential analytical
systems or sets of operating cond.tiocs tnc:
may represent useabie memoes for
determining the concentrations of the
compounds cited in Section 1.1 m the
applicable matrices, ail systems tnat employ
this principle, but. differ only m details of
equipment and operation, may be used as
alternative methods, provided that the
prescribed quality control, calibration, and
method performance requirements are met.
Certified product data sheets 'CPDS1 may
also include information relevant to the
analysis of the coating sample ncl'.ding. 5_t
not limited to, separation column. . -en
temperature, earner gas injection pert
temperature, extraction solvent, anc .r.'err.a.
standard.
2. Summery sf Method
Who.e coating •* acded 'o
dimethylforrr.amide ana a suuaoie :r.:err.a.
standard compound is acced. An aiicuc: ;f
the sample mixture is .mectaa or.tc a
chromatographic column contair.ir.g 3
stationary pnase tnat separates '.he anai>
from eacn other and rrorr. ot.-er vo!at..e
compounds contamec .n the sample Th
concentrations of the analytes are deierm;.-';;
by ccrr.oanr.g tnc aetector responses for trie
sample to tne responses octamea us. r.g
i\ik ii mav ui1
nccosbjry !u nnalyzi1 'lie vinipif .''U1^ '
ilifffrcnt CC i :,!umr. or !iff.-:i':i: C,C
npui iitin^ ' unii itit ais
-------
FViWnl Register ,' Vol GO. Vo. 235 / T!uirs,!ny, December 7, ;00r) / Rules nnd R.'yi.h!;cr.s 020"lj
•4 3 Crnsi-cnnlnninntion mny or cur
wiiinrvnr :mir- anuivses specified in Section 11 7 is
,;csiv;ncd to minimize this problem
4 -I Cross-rontnrr.inntion mny also occur .f
:iu' Devices used to transfer contmg curing
•no snmpic preparation process or for
IT.-ting t.nc «ampiu m:o tho GC arc not
.iii'-quaicly cleaned between uses. Ail such
devices should oe cleaned with acetone or
other suitadie solvent and cneckec for plugs
or craciu before and after eac.1 use.
5 Safety
5 1 Many solvents used in coatings are
hazardous Precautions should be taken to
avoid unnc.cssary inhalation and skin or eye
contact. Thjs method may involve hazardous
materials, operations, and equipment. This
test method does not purport to address all
of '.he safery problems associated with its use.
It is the responsibility of the user of this test
method to establish appropriate safery and
health practices and to determine the
applicability of regulatory limitations in
regards to the performance of this test
method.
5.2 Dimethylfonnamide is harmful if
inhaled or absorbed through the skin. The
user should obtain relevant health and safety
information from the manufacturer.
Dunethylformarn.de should be used only
with adequate ventilation. Avoid contact
with skin. eyes, and clothing. In case of
contact, immediately flush skin or eyes with
2ienry of water for at least 15 minutes If eyes
are affected, consult a physician. Remove and
wasc cor.tarr.-.nated clothing before reuse.
5 3 User's manuals for the gas
ch.-c —atograar. and other related equipment
snculc be consulted for specific precautions
to 3e 'ai;en related to their use.
6 Equiomen: snd Supplies
\'ote. Certified proouct data sheets (CPDS)
~.a> a.sc ,nc:ude information relevant to the
anaivsis of tr.e coating sample including, but
net li.T.itea to. separation column, oven
•cmperature carrier gas. injection port
•eT.perature. extraction solvent, and internal
standard.
5 : Sample Collection.
511 Sarr.Dimg Containers Dual-seal
53r~.2 .-.g conta.ners. four to eight fluid ounce
c:~ar.!'. s.-.ou.d be used to coiled the
sn.r.c-ies G.ass sample oottles or plastic
c--'a.~crs Ai-Ji volatile organic compound
VCC irr.perrT.eaole walls must be used for
corrosive substances [eg . etch primers and
certain coating cstaiysts such as methyl ethyl
KL-one !MEK1 peroxide). Sample containers.
caos and ,nner seal liners must be inert to
trie compouncs in the sample and must be
seiectca on a c 1, 4 D.i'i "jcnn! nq fnr-ns nnri IniiHs
needed include" r.o.umg imtn sheets and
sample "an labels
N'olc' The actual requirement will Irprr.d
upon 'he conditions cx.jt.ng ,it '.hi: sourr."
sampled
6 2 Laboratory Equipment and Supnl.i-b
6 2 1 Gas Chromatogr.ipn !CC! Any
instrument equipped with a flame lonization
detector and capable of being temperature
programmed may be used. Optionally, other
types of detectors (e g . a mass spectrometer).
and any necessary interfaces, may be used
provided trial ihe detector system yields an
appropriate and reproducible response to the
anaiytes m tne injected sample. Autosampier
injection may be used, if available.
6.;.2 Recorder If available, an electronic
data station or integrator may be used to
record the gas chromatogram and associated
data. If a stnp chart recorder is used, it must
meet the following criteria: A 1 to 10
millivolt (mV) linear response with a full
scale response time of 2 seconds or less and
a matximum noise level of ±0.03 percent of
full scale Other types of recorders may be
used as appropriate to die specific detector
installed provided that the recorder has a.full
scale response tune of 2 seconds or less and
a maximum noise level of ±0.03 percent of
full scale.
6 2.3 Column. The column must be
constructed of materials that do not react
with components of the sample (e g.. fused
silica, stainless steel, glass). The column
should be of appropriate physical
dimensions (e.g., length, internal diameter]
and contain sufficient suitable stationary
phase to allow separation of the anaiytes.
DB-5. DB-Wax. and F7AP columns a're
commonly used for paint analysis, however.
it :s the responsibility of each analyst to
select appropriate columns ana stationary
phases.
6.2 4 Tube and Tube Fittings. Supplies to
connect tne GC and gas cylinders.
6.2.5 Pressure Regulators. Devices used to
regulate th» pressure between gas cylinders
and the GC
6.2.6 Flow Meter. A device used to
determine the carrier gas flow rate through
the GC Either a digital flow meter or a soap
film bubble meter may be used to measure
gas flow rates.
6 2.7 Septa Seals on the GC injection
port through which liquid or gas samples can
be injected using a syr.ngc.
6.2.8 Liquid Charging Devices Devices
used in inject samples ,nto the CC such as
clean and graduated 1. 5 and 10 microhtcr
(jil) capacity svrmgcs
6.2 9 Vials Containers that can be sealed
•with 3 septum m which samples may be
prepared or stored The recommended size is
25 ml capacity Minincrr*" valves have been
found satisfactory and are available from
Pierce Chemical Company. Rockford. Illinois
6210 Balance Device used to determine
the weights of standards and samples An
analytical balance capable of accurately
weighing tu 0 OOm g is required
7 netigents and Stunrfurds
7 1 Purity of UiMgenf! Kcayent gruili:
clicmtc.ilb ih.ill bo usuil in all It-sts Unless
otherwise specified, all rc.igcrUi iUal!
conform !o the snrr:;Tica:ions of 'in1
Committm on Aninvtic.i, Re,iij''-.-s <•:' •'."
Amoricnn CIiomiLai 5or,riv wlicrn siu ;i
••p'Tification1; arc .ivai.,iti|p Ot.Vr gnu!'1* ~i.,.
be used provided it is- :".-•>: j-icurt.nneei rn,ii
the rcngcnt is of -iufftc:'"V. •mr.ty :o pen;.:
its use without iebscni;'^ "he nccur.icv of
tjcicrmin.ition
11 Cirr.er Gas Helium carrier ^as sr.,ul
have ,1 purity of 99 90S percent or h;g!ier
H.gh puritv nitrogen Tiav also be used OtMor
carrier gases that arc appropriate for the
column system ,md analyte may also be used
Ultra-high purity grade hydrogen jns and
zero-grade air shall be used lor the fiarne
lonization detector.
7 3 Dimethyifonr.amide 'DMFl. Solvent
for all standards and sampics Some ot.-.cr
suitable solvent may be used if DMF is not
compatible with the sample or coeiutes wirr.
a target analyte.
Note: DMF may coelute with ethylbenrene
or p-xylene under the conditions descrisea
m the note under Section 6 2.3.
7 4 Internal Standard Materials. The
internal standard material is used m the
quantitation of the anaiytes for this method.
It shall be gas chroraatography
spectrophotometric quality or. if this grade is
not available, the highest quality available
Obtain the assay for the internal standard
material and maintain at that purity during
use. The recommended internal standard
material is 1-propanol. however, selection of
an appropriate internal standard matenal for
the particular coating and GC conditions
used is the responsibility of cacr. analyst
75 Reference Standard Materials The
reference standard materials are the
chemicals cited in Section 1 1 which are of
known identity and purity and which are
used to assist in tne identification and
quantification of the anaiytes of this method
Thev shall be the highest quality available
Obtain the assays for the reference standard
materials and maintain at those purities
during use
7 6 Stock Reference Standards StocK
reference stanuards are dilutions of the
reference standard material' that may be
used on a daily basis to prepare calibration
standards, calibration check standards, and
riuaiitv control check standards Stock
reference standards may oe prepared from
the reference standard materials or purchased
as certified solutions
~ 6 1 Stocx reference standards shoul'i ue
prctured in dimethvlformamice for each
anaivtc expected m the coating samples to oe
analyzed The concentrations of anaiytes ,p.
the stock reference stand,irds are not
specified but must be adequate to prepare :k.e
calibration standards required in the niutlioc;
A stock reference1 standard mny contain rr.urc
than one analyte provided all annlytes arc
chemically compatible and no analvtcs
coeiute The actual concentrations prepared
must be known to within 0 1 pcrren! (e 3
0 1000 ± U D001 g/g solution) The lollowiim
procedure is suggested Place nljoul .15 ml nl
dimethylforniamide into a t;ired ground-cj.iv,
stoppered 50 nil volumetric flask Weigh the
flask to the nearest 0.1 my Add 1 2 5 g of tlic
reference stand.ird material and rcweigti the
flask Dilute to volume with
ilmirthylforro.imuli: iiml reweigh Stoppe"':'
-------
fi20"4 Frill-nil
GO,
235 / Thurs
•". '-». M".i-r.i. '.:nes C...C . .i'i; '.lie
-r.;.""'ration .a gr ii-> per grnm .::' s.-,, .• * n
-cm 'he -.c-'^in n .v.jjhts. -r^ct.n^ '-r
• e iss.-1 ed p.iri'y oi 'he rci'jrcnc.j stnn<:ar,':
Note' \.!:'.ougn i juss-stjpoercd
. ;,_—.Mtr'C t'.as*. ,s coi'Aemen; ar.'. s'u.'.ari'i:
.j.ass ccr.ta.ner ma', oe user! because ;:OCK
-"fe-ence standards are nreparcd b1. we:.; "it
"52 Transfer v.e stocK reference
standard so.ution ntc one or more Tef.o".-
sra.ed screw-cap jott.es Siore with minima:
-endsracc at - '.0°C to 0°C and protect from
""63 Prcoare fresh stock reference
standards every six months, or sooner it
ana'.vsis results from daily caiibrat.on checu
standards indicate a prooiem. Fresn stocx
reference standards for very volatile HAP's
may have to be prepared more frequently.
77 Calibration Standards. Cahoration
standards are used to determine tne response
of the detector to known amounts of
reference material 'Calibration standards
must :e prepared at a minimum of three
concentration leveis from the stock reference
standards (see Section 7 6). Prepare the
calibration standards in dimethyiformamide
•('see Section 7.3). The lowest concentration
standard should contain a concentration of
anaiyte equivalent either to a concentration
of no more than 0 01% of the analvte in a
coating or to a concentration that s lower
-.nan the actual concentration of the anaiyte
.n the coating, whichever concentration is
nigher The highest concentration standard
shou.d contain a concentration of anaiye
equiva.ent to slightlv more than the highest
concentration exoec'ed for the analvte in a
coatm? The remain.ng calibration standard
sr.o-.d cor.tam a concentration of anar.te
roi.zh.% at the midpoint of the range defined
b'. the .owes: and highest concentration
ca..'oration standards The concentration
-cr.^e of the standards snould thus
correspond to the exoected range of anaiyte
concentrations .n the prepared coating
saxnt3.es !see Section 11 5) Each calibration
standard should contain each anaiyte tor
ce'ect.on by this .method expected in the
actua coating sarr.oies ,e g . some or all of
'..-.e comoounds '..sted in Section 1 1 mav be
.-c.udecl Each calibration standard should
a.so contain an appropriate amount of
.-.te-r.a! standard'material (response for the
:-:err.a standard material is w.th.r. 25 to 75
percent of full scale on the attenuation
se"...-.g for the particular reference standard
concentration level) Calibration Standaras
sr.ou.a oe stored for 1 week only in sealed
•. :ais with minimal headspace. If the stock
-eferencc standards were prepared as
snec.f.'-'d in Section 7 6, the calibration
standards may be prepared by either
•AGic-'ng eacn add.:.on of the S;CCK reference
standard or bv adding known volumes of the
s'ocn reference standard and calculating the
mass o; the standard reference material
,i:.'.ud Alte.-r.at.'.c 1 .'Section 7 7 ',) specifies
• .u oroi "ii^-rc 'o DC followed when tho stock
-"te'encc standard i> added by volume
A.ternnlive 2 Sec'ion 772) specif L'S '.he
:>r"ct".','..re to ue fui'uwed when '.lie stock
- ten'..LL' v.aniiarcl - milled bv weii;'!'.
NolC' T-i ,!ss,^: wit:i Irlo-rninini; 'he
it: is -ecu.-".: "ITI- ind ,r. other se'',,•;:-,
: t';.s rr.i't '.nil. tr.r inalvsi mav :.;i:i .',
ul1. if.'.'i:0'",.'. :o pr-T.are a ".ir.e siiown^ 'ri-
'. i'-nrjiiration \'.ternative 1
3e:orm.re '.lie amount of each s:oc\ retcrrinc1:
standard and -iimcthv.formamide solvent
ri-fdei! to prepare approximately 25 m.i ot :r\<:
stiec fie calibration concentration level
desired To a tared 25 ml nal that can be
sec.ed win a crimp-on or Minmert*1 vaive.
idd the total amount of d:methv;formamidc
calculated to oe needed. As quickly as
practical add the calculated amount of each
stocK reference standard using new pipets for
p.pet tins) for each stock reference standard.
Reweign the vial and seal it Using the
^riown weights of the standard reference
materials per ml in the stock reference
standards, the volumes added, and the total
weight of ail reagents added to the vial.
calculate the weight percent of each standard
reference material in the calibration standard
prepared Repeat this process for each
calibration standard to be prepared.
"72 Preparation Alternative 2.
Determine the amount of eacn stock reference
standard and dimethyiformamide solvent
needed to prepare approximately 25 ml of the
specific calibration concentration level
desired. To a tared 25 ml vial that can be
sealed with a crirnp-on or Mininerr" valve.
add tne total amount of dirnethylformamide
ca.culated to be needed. As quickly as
practical, add the calculated amount of a
SIOCK reference standard using a new pipet
lor piset tip) and reweigh the vial. Repeat
this r/rocess for each stock reference standard
•o be" added Seal the vial after obtaining the
final weignt Using the known weignt
percents of the standard reference materials
in the stock reference standards, the weights
of the stock reference standards added, and
•he total weight of all reagents added to the
v.al. calculate the weight percent of each
standard reference material in the calibration
standard prepared. Repeat this process for
each cal.bration standard to be prepared.
8 Sample Collection. Preservation.
Transport, and Storage
8 i Copies of material safety data sheets
,'MSOS's) for each sampie snould be ootained
prior to sampling The MSDS's contain
information on the ingredients, and physical
and chemical properties data The MSDS's
also contain recommendations for proper
uir.dhng or required safety precautions
Certified product data sheets (CPDS) may
also include information relevant to the
analysis of the coating sampie including, but
not limited to. separation column, oven
temperature, carrier gas. miection port
temperature, extraction solvent, and internal
standard
82 A copy of the blender s worksheet can
DC requested to obtain data on the exact
coat.rig ticmg sampled. A blank coaling d.ita
sneet form (sec Section 18) mny also be used
The manufacturer's formulation information
from the product data sheet snould also be
obtained
H J Prior 'o sample collection, thoroughly
:n,x t.'ic coating '•<> ensure that a
ii "rr.nMs;:i". i*>..'.^ a co i' ni^ : - ,iv "r
-.m/ar ii'vc." ::owevrr '.v;;i- . • ' •,•,,,-•,
"'.s :r.,prr>rrM'<'
sllippine, procedures should -<•• It.;, weti
-------
Federal Rnc;istt:r
fiO. No. 235 / Thursday, December ~. l°'i"
UPS nncj
,cr. s
02055
' ^u.intv Cr>n[.-r>!
') ' Laboratories us.n^ '.his mr'.hor!
sriou'd operate u formal qunhtv control
program Tin: minimum requirements of the
Dro^ram should consist of an initial
vlcnicnbtrntion of 'laboratory capability and an
cnnoing anaivsis of blanks and quah'v
control sjrnpies to evaluate and document
nutiu'.v data The laooratory must maint.nn
records' '.o document the quality of the data
gneraied When results indicate atypical
motnod performance, a quality control check
standard (see Section 9 4) must be ana.vied
:u cor.firm that the measurements were
performed in an m-conirol mode of
operation.
92 Before processing any samples, the
analyst must demonstrate, through analysis
of a reagent blank, that there are no
interferences from the analytical system.
glassware, and reagents that would bias the
sample analysis results. Each time a set of
analytical samples is processed or there is a
change in reagents, a reagent blank should be
processed as a safeguard against chronic
laboratory contamination. The blank samples
should be earned through all stages of the
sample preparation and measurement steps.
9.3 Required instrument quality control
parameters are found in the following
sections:
9.3.1 Baseline stability must be
demonstrated to be te m the calibration standards
Calculate the response factor for t.le internal
standard ,RF,.l and the rcs-ponse factor for
c.icn compound relative to the internal
standard IRRFj for each concentration !evf!
using Equations 5 and 6. Section 12
10224 L'smg the RRF's from the
calibration, calculate the percent relative
standard deviation (percent RSD) for each
anaivtc in the calibration standard usinn
Cquatior. 7. Section 12 The percent RSD !oi
each individual calibration analyte must be
/fiv than IS percent This criterion must be
met m order for the calibration to be val.il
If the criterion is met. the mean RRF s
determined aDove arc to be used until the
next calibration
10J Daily Calibration Checks The
L.ihiir.ition curve (Section 11) 2.21 must be
(.heckru and verified .it least mite each .lav
th.it samples arc analyzed Tins is
-------
62956 Federal Register / Vol. 60, No. 235 / Thursday. December 7, 1905 / Rules and Regulations
accorr.phsnoc bv analyzing a calibration
standard that .3 at a concentration near the
midpoint of :ho working rouge and
performing Lbo chocks in Sections 10 3 1.
10 3 Z. ind 10 3 3.
10 2 '. For each analyto in the calibration
standard, calculate the percent difference m
•..IB RR? from ihc last calibration using
Equation 3. Section 12. If the percent
difference for each calibration anaiyte is less
. than 10 percent, the last calibration curve is
assi-mea to be valid, if the percent difference
for any anaiyte is greater than 5 percent, the
analyst sr.ould consider this a warning limit.
if the percent difference for any one
calibration anaiyte exceeds 10 percent,
corrective action must be taken. If no source
of the problem can be determined after
corrective action has been taken, a new three-
point (minimum) calibration must be
generated This criterion must be met before
quantitative analysis begins.
10.3.2 If the RF,, for the internal standard
changes by more than ±20 percent from the
last daily calibration check, the system most
be inspected for malfunctions and
correct.ons made as appropriate.
10 3 3 The retention times for the internal
standard and ail calibration check analytes
must be evaluated. If the retention time for
the internal standard or for any calibration
check anaiyte changes by more than 0.10 mm
from the last calibration, the system must be
inspected for malfunctions and corrections
made as required.
11 Procedure
11 1 All samples and standards must be
allowed to warm to room temperature before
analysis. Observe the given order of
ingredient acdition to minimize loss of
voiat.les
112 Br.ng the GC system to the
determined ::erat.r.g conditions and
condition tr.e column as described in Section
10 1
Note- The temperar-ire of the injection port
may re an especially cr.tical parameter
Information ascut the proper temperature
rr.av Be tOur.C on the CPDS
11.3 Perform the daily calibration checks
as described m Section 10 3. Snmplos are not
to be analyzed until tho criteria in Section
10 3 arc met.
11 4 Place the as-received coating snmple
on ,\ paint shaker, or similar device, nnd
shakn tho sample for a minimum of 5
minutes to achieve hornogemzation.
11.5 Note: Tho steps m this section must
be performed rapidly and without
interruption to avoid loss of volatile organic:.
These steps must be performed in a
laboratory hood free from solvent vapors. All
weights must bo recorded to the nearest 0.1
mg
11.5.1 Add 16 g of dimethylformamide to
each of two tared vials (A and B) capaole of
being septum scaled.
115.2 To each vial add a weight of
coating that will result in the response for the
maioc constituent being in the upper half of
the linear range of the calibration curve.
Note: The magnitude of the response
obviously depends on the amount of sample
iniected into the GC as specified m Section
118. This volume must be the same as used
for preparation of the calibration curve.
otherwise shifts in compound retention times
may occur. If a sample is prepared that
results in a response outside the limits of the
calibration curve, new samples must be
prepared: changing the volume injected to
bring the response within the calibration
curve limits is not permitted.
1153 Adda weight of internal standard
to each vial (A and B) that will result in the
response for the internal standard being
between 25 percent and 75 percent of the
linear range of the calibration curve
115.4 Seal the vials with cnmp-on or
Minmert* septum seals.
11 6 Shake the vials containing ihe
prepared coating samples for 60 seconds
Allow the vials to stand undisturbed for ten
minutes. If solids have not settled out on the
bottom after 10 minutes, then centrifuge at
1.000 rpm for 5 minutes. The analyst also has
the option of miecting the sample without
allowing the solids to settle.
117 Analyses should bo contacted ,n ;n»
foilow.ng oraer doily calibration cnei.k
iarr.r)li\ Tielhod ulnnk. up to '.3 .nioctions
from s.implo vmis (i e . one ir. octicr. eacn
from up to fivo pairs of vials, wnicn
corresponds to analysis of 5 coating ^ar-.rles,
11 8 Iniect the prescribed volume it
supernatant from inn calibration cr.ocx
samnle. tae method blank, and :::e iarnpio
v.als onto the chromatographic colur-.n ar.d
record the c.irornatograms while opcrnt.r.g
the system under tho spec.fied operat.r.g
conditions
Note: The analyst has the option of
meeting the uaseparated sampie.
12 Data Analysis and Calculations
12.1 Qualitative Analysis. An anaiyte 'e 5 .
those cited in Section 1.1) is considered
tentatively identified if two cnteria are
satisfied: ;l! eiution of the sample acalyti
within ±0 05 min of the average GC reter.ncn
time of the same anaiyte in the calibration
standard: and (2} either (a) confirmation of
the identity of the compound by spectral
matching on a gas chromatograph equipped
with a mass selective detector or fb) eiution
of the sampie anaiyte within rO.OS rnm of the
average GC retention time of the same anaiyte
m the calibration standard analyzed on a
dissimilar GC column.
12.1 1 The RT of the sample anaiyte must
meet the cntena specified in Section 9.3.3
12.1 2 When doubt exists as to the
identification of a peak or the resolution of
two or more components possibly com-rsir.g
one peak, additional confirmatory -echn.cues
(listed in Section 12.1) must be usec
12.2 Quantitative Analysis. VVaes in
anaiyte has been ident'f ec. the
quantification of that ;orr.pour.d w:l. re
oased on the internal standard tecnn.que
12 2.1 A single analysis consists of ons
injection from each of rwo sampie v^.a.s A
and 3) prepared using me same coa::t:g
Calculate tne concentration of eacr. .ce-t.f.;-
anaivte in the samsie as follows
HAPwl%=!OOx-
i
where:
Eq. (1)
= weight percent of the anaiyte in coating.
At = Area response of the anaiyte m the sample.
Ws = Weight of internal standard added to sample, g.
A', = Area response of the internal standard in the sample.
= Mean relative response factor for the anaiyte in the calibration standards.
= Weight of coating added to the sample solution, g.
1222 Report results for duplicate analysis
(sampie vm.s A and B) without correction.
12 2 Precision Data. Calculate the percent
difference ue'.ween the measured
concentrations of each analyto in vials A and
B as follows
1231 Calculate the weigh! percent of the
onuiytc in each of thu two sampie viais as
described in Section 12.2.1.
12.J.2 Calculato the percent difference for
ench anulyte as:
%Dif, = !00x-
Eq. .:••
where; A, and 3, are tho measured
concentration-; of the anaiyte in vu.s A ano
B
-------
... '»•.-/- . /. . .' *:.?. j/;. ji*.'.-^"".' •• -
''Federal Register ./ Vol.'60r.Nd;(235^{j'harsday, lWii)&yi7(U995../ Rules and. Regulations G2957
follows:
or '
on9.4)as
. . calibration standards fSoe Section 10222!
is the known truo value of the inWyte in tho as follows-
ocrs.yu^f.'j.v,.- ,-.:•• 7i,. u,.-.' "
•'! i.5 'Obtain' retention times (RT's) from
data st^anon or.mtegrntoror, for
% Accuracy ' = 100 X-- Eq (3) aa st^anon or.me _
' x -j. '' v ' chromalograms from a^ chart recorder,
* calculate tie RT's for analytes hi iho
RT =
Distance from injection to peak maximum
Recorder chart speed
Eq. (4)
126 Calculate the response factor for the
internal standard (See Section 10.2.2.3) as
follows:
where: - • - - -
A* = Area response of the internal
standard.
C» = Weight percent of the internal
standard.
12.7 Calculate the relative response factors
for analvtes in the calibration standards (See
Section 10.2.2.3) as follows:
wherer -
RF..
Eq. (6)
RRF, = Relative response factor for an
individual analyte.
A. = Area response of the analyte being
measured.
C. * Weight percent of the analyte being
measured.
12.8 Calculate the percent relative standard
deviation of the relative response factors for
analyte* in the calibration standards (See
Section 10.2.2.4) as follows:
%RSD = 100x-
where:
n-l
RRF
Eq. (7)
n - Number of calibration concentration levels used for an analytc.
RRFX = Individual RRF for an analyte.
R_RFX = Mean of all RRF's for an analyte.
'.29 Calculate the percent difference in the calibration curve and the daily calibration
relative response factors oetween the cnecks (See Section 10.3) as follows:
; RRF -RRF'
% Difference = •
where:
RRF.
-xlOO Eq. (8)
RRF = mean relative response factor from last calibration.
RRF = relative response factor from calibration check standard.
13 Measurement of Reaction Byproducts
That are HAP. [Reserved!
14 Method Performance. [Reserved]
15 Pollution Prevention. [Reserved!
16. Waste Management
10.1 The coating samples and laboratory
standards and reagents may contain
compounds which require management as
hazardous waste. It is the laboratory's
responsibility to onsura all wastes arc
managed in accordance with all applicable
laws and regulations
16.2 To ovoid Excessive laboratory waste,
obtain only enough sample for laboratory
analysis.
-------
,62950 Federal Register ' Vol 60, No. 235 / Thursday, December 7,
Rules nr.d
Ifi 3 !t ,s recommended thn' h.,cardod
waste coating bonds, used rags jsccl pnprr
'oweis. and other nongiass or non.snarp wnstc
materials be placed T\ a plastic Dng before
Giscosai A separate container, designated
Tor Sharp Ob:cc:s Only," is recommended
fc: collection of discarded glassware and
DLT.er sharp-edge items usea in the
Ijocratorv !t is -^commended that unused or
excess sarr.Dies and reagents be p.aced in a
soiver.t-reSiStant piastic or mete, container
with a lid or cover designed for f.arr.rr.riDio
liquids This container should net oe stored
.n tne area where analytical work ,s
performed It .s recommendea that a record
be kept of all compounds placed in the
container for identification of the contents
upon disposal.
:r References
\ Clean Air Act Amendments. Public Lav,
101-549. Titles I-X1. November. 1990.
2. Standard Test Method for Water Content
of Water-Reducible Paints by Direct Iniection
in'.o a G,is Chromntogrnph ASTM
Designation D3702-79
3 Standard Practice for Sampans L.qu. I
p-iir.ts and Related Pigment Co,it.:ig^ \STM
Ors.'^n.r'on D3925-31
•4 Standard Test Mcthoc fcr Dt'tcrrr.i:ia:.o:;
of D.cnloromethar.e and '..'• '--
Trier,.oroethune in Paints ar.c; Codtinjb b*.
Direct iniection into a Gas Chrornatograpn.
ASTM Designation D4457-3S
5. Standard Test Method for Determining
the Unreacted Monomer Cor.tent of Latexes
Lsing Capillary Column Gas
Chromatography ASTM Des.gnation D48C7-
93
6 Standard Test Method for Determining
Unreacted Monomer Cor.tent of Latexes
Using Gas-Liquid Chromatography ASTM
Designation D 4747-87
7 Method 301—"Field Validation of
Pollutant Measurement Methods from
Various Waste Media." 40 CFR 62. Appendix
A. _
3 "Reagent Chemicals. American Cherr.icai
Society Specifications." American Chemical
',MO :c- t.r.y o! ran5"'"3 -. ;: ••>'•'
\Tirr'.cnn Chnm Ci. ~"'C >:'*' src
Cl'.Tr.icaib nnc: S;.,nd.iri;> "n> :
D V in N'nstrar J Co !i r. Ni1 v
the 'L'ni'cd Siatfs Pharrr.aco?"
~ ~)lC?r:,T75
ir.snector
Date. T.me
S.irr.ple :D»
Source ID
Coating Same/Type
Plant Witness
Tvpe Analysis Required
Special Handling
Sampie Container Lacei
Coating Data
Date:
Source
Data
Sampie ID No.
Samole ID No
Coating-
Supplier Name
Name and Color of Coating
Type of Coating (primer, ciearcoat. etc.)
identification Number lor Coating
Coating Density (!bs/gal) -
Total ^olatiles Content (wi percent)
Water Content (wt percent)
Exe-not Solvents Content (wt percent)
VCC Content 'wt percent)
Sonds Content tvol percent)
D'luent °-ccerties
Nan-e.
'de1": f caticr Number
D'luent Sci'vent Dens.ty ilb&gai)
VCC Content v^t percent)
7, ater Content (wt pe'cent)
ExeTt Solve"; Conte1"! 'wt percent)
C i-e'". Scivert =atic gai diluent soivent/gai coating)
Stock Re''erer.ce Standari
v.arr.e cfReferer.ee Mater.a.
S-sp..er Name
LotNjrr.Der
P^r.ty
N'arre
of
Supplier Name
Lot \umoer
Pujitv __
Date Prepared
Prepared 3v
Sotebocc page r.c
Solvent
Material
pqcpARATION INFORMATION—
Continued
3 Weight =!us Reference ,g
Material
A Weignt After Made to ,g
Volume
5 Weight DMF lines 2- .3
-.3-1)
6 Weight Re!. Material ,3
Mines 3-2)
7 Corrected Weight of Ret- ,9
erence Material (line 6
times purity)
8 c-action Reference Ma- ,3/g
tenal m Standard (Line 7
- Line 5) SOln
9 Total Volume of Sland- . rn1
ard Solution
:0 height Re'erence Ma- ,g/mi
tenal per mi of Solution
(L.ne 7 - Line 3)
CN INFC=MA~;CN—
Continued
Laooratory ID No :or this
Standard
Expiration Date 'or this
Standard.
CALIBRATION STANDARD
Date Prepared
Date Expires
Preparec By
Notebook, oage
Calibration Stancarc idcnt.fication No
Final Weignt Flask Plus
Reagents
Weight Empry F'ask
Total Weight Of Reagents
-------
Federal Register ' Vol. 60, No. 235 / Thursday, December 7, 1995 / Rules and Resulnnons G2050
Anaiyte name1
StocK ref-
erence stand-
ard ID No.
Amount of stock reference standard added (by volume or oy
weight)
Volume
added, ml
Amount in
standard, g/ml
Weight added,
9
Amount
soin
Calculated
weight anaiyte
I. 9
We'r er-
cent ,;e n
calc _: on
starjird"
i
• include internal standard(s).
»Weight percent * weight anaiyte added - total weight of reagents. s
Quality Control Check Standard Notebook/page: PREPARATION INFORMATION
Date Prepared: Quality Control Check Standard Final Weight Flask Plus g
_ Identification No.: Reagents.
a e pves. ^^ Weight Empty Flask ,g
Prepared By Total Weight Ol Reagents . ,g
Amount of stock reference standara added (by volume or oy
Stock ref- | 1 w*fhl) I Calculated
Amount in Weight added, ctanaard nin
added, ml standard, g/ml g stanoaro, g/g
:;::.:::izz: ii~— \
' include internal Standard(s).
»Weignt percent.weignt anaiyte added - total weight of reagents.
Quality Control Check Standard Analysis Analyst .—.
Sate OCCS Analyzed: QCC Expiration Date:
OCCS icentification No.
ANALYSIS RESULTS
Weight percent determined Mee!s cntena in Section
Mean Wt Percent Percent
Anaiyte percent accuracx
Run 1 Run 2 "uh 3
-------
620GO Federal Register / Vol. 60. No. 235 / Thursday, December 7, 1995 / Ruies and Regula-.cr.s
Calibration cf GJS Chromatcgraph
Calibration Date
Calibrated Bv
PART 1.—RETENTION TIMES FOR INDIVIDUAL ANALYTES
Analyte
Stock stand-
ard. ID No
Recorder chart speed
I
Incnes/min.
cm/mm.
Distance !rom 'niection point :o
peak -Maximum i
=eteit,on
Inches
Centimeters
i
i i
•Retention time-distance to peak maxima-'criart speed.
C\L:3RATIONOFGASCHROMATOGRAPH Calibrated By
Calibration Date:
PART 2.—ANALYSIS OF CALIBRATION STANDARDS
. , Cahb. STD ID Canb. STD ID Caiib. STD ID
Analyte No. No. No.
Name:
Cone, in STD ...
Area Response
RT
Name:
Cone, in STD ...
Area Response
RT
Name:
Cone, in ST2 ..
Area Response !
RT
Name-
Cone, in STD ...
Area Respor.se
RT _
Name.
Cone, in STD .
Area Response
RT
Name
Cone m STD
Area Response
RT
Name. ,
Cone. :n STD I
Area Response
RT
Name.
Cone, in STD
Area Response
RT
internal Standard Name
Cone, m STD |
Area Response i
FT . j
Calibration of Gas Chrorr.atograph
CjliOration Da:n .
Calibrated By
-------
Federal Register / Vol. 60. No. 235" / Thursday. December 7. 1995 / Rules and Regu.at.ons G2QC
PART 3.—DATA ANALYSIS FOR CALIBRATION STANDARDS
Anaryte
Name:
RT
Rr
Name:
RT
RF
Name:
RT
RF
Name:
RT
RF
Name:
RT
RF
Name:
RT
RF
Name:
RT
RF
Calib. STD ID
-"
Calib. STD ID
Calib STD ID
Mean
percent RSD
ol RF
IS RT within
±0 05 mm ol
RT for slock?
(Y'N)
Is percent
RSD <30% iY'
N)
Daily Calibration Check
Date:
Analyst:
Calibration Check Standard ID No-:
Expiration Date:
Analyte
Retention Time (RT)
Last
This
Difference •
Resoonse Factor (RF)
Last
This
Difference "
• Retention time (RT) change (difference) must be less than ±0.10 minutes.
"Response factor (RF) cnange (difference) must be less than 20 percent tor each analyte and for the internal standard.
Sample Analysis
Vial A ID No..
Vial B ID No..
Analyzed By
Date:
Sample preparation information
Measured'
Calculated.
wt internal standard
Vial A ($)
v:ai 8 ig)
-------
' " " "• • V"-7- ' - ' . ' •'•J'v£SiWl«X. < •
62962- Federal• Register ./, Vol. 60. No.;235 /•Th'urs.day;,December 7. 1995 / Rules and Regulations
. > • • • • - - - fSriifJ' -••
. -. ANALYSIS JBESUL£S:,.DuPLiCATE SAMPLES
Analyte .
-
Internal Standard -
• - Area response '
Vial A
Vial B
-
\. *t
Wt percent ,n sampie
Vial A
Vial B
-~
Average
[FR Dot 95-29358 Filed 12-&-95: 8:45 am]
BILLING COOE U40-M-P
-------
-------
APPENDIX E
LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
-------
-------
Table E-l includes a list of volatile hazardous air pollutants. The NESHAP emission
limits are based only on the VHAP content of the coatings and adhesives, not the total HAP
content. Some coatings, particularly the stains, may contain small amounts of metals that are
also HAP, but the emission limit does not include these compounds. Therefore, the list
presented here is only for VHAP. For a listing of all 189 hazardous air pollutants, see Section
112 of the 1990 Clean Air Act Amendments^
TABLE E-l. LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS
Chemical name
CAS No.
Acetaldehyde
Acetamide
Acetonitrile
Acetophenone
2-Acetylaminofluorine
Acrolem
Acrylamide
Acrylic acid
Acrylonitrile
Allyl chloride
4-Aminobiphenyl
Aniline
o-Amsidme
Benzene
Benzidine
Benzotrichloride
Benzyl chloride
Biphenyl
Bis(2-ethylhexyl)phthalate (DEHP)
Bis(chloromethyl)ether
Bromoform
1,3-Butadiene
Carbon disulfide
Carbon tetrachloride
75070
60355
75058
98862
53963
107028
79061
79107
107131
107051
92671
62533
90040
71432
92875
98077
100447
92524
117817
542881
75252
106990
75150
56235
Carbonyl sulfide
463581
E-l
-------
TABLE E-l. (continued)
Chemical name
CAS No.
Catechol
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chloroform
Chloromethyl methyl ether
Chloroprene
Cresols (isomers and mixture)
o-Cresol
m-Cresol
p-Cresol
Cumene
2,4-D (2,4-Dichlorophenoxyacetic acid, including salts and esters)
DDE (1,1 -Dichloro-2,2-bis(p-chlorophenyl)ethylene)
Diazome thane
Dibenzofuran
1,2-Dibromo-3-chloropropane
Dibutylphthalate
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1,3-Dichloropropene
Diethanolamine
N,N-Dimethylaniline
Diethyl sulfate
3,3'-Dimethoxybenzidine
4-Dimethylaminoazobenzene
3,3'-Dimethylbenzidine
120809
79118
532274
108907
67663
107302
126998
1319773
95487
108394
106445
98828
94757
72559
334883
132649
96128
84742
106467
91941
111444
542756
111422
121697
64675
119904
60117
119937
Dimethyicarbamoyl chloride
79447
E-2
-------
TABLE E-l. (continued)
Chemical name
CAS No.
N.N-Dimethylformamide
1,1 -Dimethylhydrazine
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane (1,4-Diethyleneoxide)
1,2-Diphenylhydrazine
Epichlorohydrin (l-Chloro-2,3-epoxypropane)
1,2-Epoxybutane
Ethyl acrylate
Ethylbenzene
Ethyl carbamate (Urethane)
Ethyl chloride (Chloroethane)
Ethylene dibromide (Dlbromoethane)
Ethylene dichloride (1,2-Dichloroethane)
Ethylene glycol
Ethylene oxide
Ethylenethiourea
Ethylidene dichloride (1,1-Dichloroethane)
Formaldehyde
Glycol ethers
Hexachlorobenzene
Hexachloro-1,3-butadiene
Hexachloroe thane
Hexamethylene-1,6-diisocyanate
Hexamethylphosphoramide
68122
57147
131113
77781
51285
121142
123911
122667
106898
106887
140885
100414
51796
75003
106934
107062
107211
75218
96457
75343
50000
0
118741
87683
67721
822060
680319
Hexane
110543
E-3
-------
TABLE E-l
[continued)
Chemical name
CAS No.
Hydrazine
Hydroquinone
Isophorone
Maleic anhydride
Methanol
Methyl bromide (Bromomethane)
Methyl chloride (Chloromethane)
Methyl chloroform (1,1,1 -Trichloroethane)
Methyl ethyl ketone (2-Butanone)
Methylhydrazine
Methyl iodide (lodomethane)
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl methacrylate
Methyl tert-butyl ether
4,4'-Methylenebis(2-chloroaniline)
Methylene chloride (Dichloromethane)
4,4'-Methylenediphenyl diisocyanate (MDI)
4,4'-Methylenedianiline
Naphthalene
Nitrobenzene
4-Nitrobiphenyl
4-Nitrophenol
2-Nitropropane
N-Nitroso-N-methylurea
N-Nitrosodimethylamine
N-Nitrosomorpholine
Phenol
302012
123319
78591
108316
67561
74839
74873
71556
78933
60344
74884
108101
624839
80626
1634044
101144
75092
101688
101779
91203
98953
92933
100027
79469
684935
62759
59892
108952
p-Phenylenediamme
106503
E-4
-------
TABLE E-l
[continued)
Chemical name
CAS No.
Phosgene
Phthalic anhydride
Polychlorinated biphenyls (Aroclors)
Polycyclic Organic Matterb
1,3-Propane sultone
beta-Propiolactone
Propionaldehyde
Propoxur (Baygon)
Propylene dichloride (1,2-Dichloropropane)
Propylene oxide
1,2-PropyIenimine (2-Methyl aziridine)
Quinone
Styrene
Styrene oxide
2,3,7,8-TetrachIorodibenzo-p-dioxin
1,1,2,2-Tetrachloroethane
Tetrachloroethylene (Perchloroethylene)
Toluene
2,4-Toluenediamme
Toluene-2,4-diisocyanate
o-Toluidine
1,2,4-Trichlorobenzene
1,1,2-Trichloroe thane
Trichloroethylene
2,4,5-Tnchlorophenol
2,4,6-Trichlorophenol
Triethylamine
Trifluralin
75445
85449
1336363
0
1120714
57578
123386
114261
78875
75569
75558
106514
100425
96093
1746016
79345
127184
108883
95807
584849
95534
120821
79005
79016
95954
88062
121448
1582098
2.2,4-Tnmethylpentane
540841
E-5
-------
TABLE E-l. (continued)
Chemical name
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride ( 1 , 1 -Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylene
m-Xylene
p-Xylene
CAS No.
108054
593602
75014
75354
1330207
95476
108383
106423
Includes 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.
Includes organic compounds with more than one benzene ring, and which have a boiling
point greater than or equal to 100°C.
E-6
-------
APPENDIX F
POLLUTANTS EXCLUDED FROM USE IN
CLEANING AND WASHOFF SOLVENTS
-------
-------
POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF SOLVENTS
Chemical Name
:AS NO.
4-Aminobiphenyl
Styrene oxide
Diethyl sulfate
^-Nitrosomorpholine
Dimethyl formamide
Hexamethylphosphoramide
Acetamide
4,4'-Methylenedianiline
o-Anisidine
2,3,7,8-Tetrachlorodibenzo-p-dioxin
Beryllium salts
Benzidine
N-Nitroso-N-methylurea
Bis(chloromethyl)ether
Dimethyl carbamoyl chloride
Chromium compounds (hexavalent)
1,2-Propylenimine (2-Methyl aziridine)
Arsenic and inorganic arsenic compounds
Hydrazine
1,1 -Dimethyl hydrazine
Beryllium compounds
1,2-Dibromo-3-chloropropane
N-Nitrosodimethylamine
Cadmium compounds
Benzo (a) pyrene
Polychlorinated biphenyls (Aroclors)
HeptachJor
3,3'-Dimethyl benzidine
Nickel subsulfide
Acrylamide
Hexachlorobenzene
Chlordane
1,3-Propane sultone
92671
96093
64675
59892
68122
680319
60355
101779
90040
1746016
92875
684935
542881
79447
75558
99999904
302012
57147
7440417
96128
62759
50328
1336363
76448
119937
12035722
79061
118741
57749
1120714
106990
F-l
-------
Chemical Name
CAS No.
Nickel refinery dust
2-Acetylaminoflourine
3,3 '-Dichlorobenzidine
Lindane (hexachlorcyclohexane, gamma)
2,4-Toluene diamine
Dichloroethyl ether (Bis(2-chloroethyl)ether)
1,2 - Diphenylhydrazine
Toxaphene (chlorinated camphene)
2,4-Dinitrotoluene
3,3'-Dimethoxybenzidine
Formaldehyde
4,4'-Methylenebis(2-chloroaniline)
Acrylonitrile
Ethylene dibromide( 1,2-Dibromoethane)
DDE (1,1-p-chlorophenyl 1-2 dichloroethylene)
Chlorobenzilate
Dichlorvos
Vinyl chloride
Coke Oven Emissions
Ethylene oxide
Ethylene thiourea
Vinyl bromide (bromoethene)
Selenium sulfide (mono and di)
Chloroform
Pentachlorophenol
Ethyl carbamate (Urethane)
Ethylene dichloride (1,2-Dichloroethane)
Propylene dichloride (1,2-Dichloropropane)
Carbon tetrachloride
Benzene
Methyl hydrazine
Ethyl acrylate
53963
53963
58899
95807
111444
122667
8001352
121142
119904
50000
101144
107131
106934
72559
510156
62737
75014
99999908
75218
96457
593602
7488564
67663
87865
51796
107062
78875
56235
71432
60344
140885
75569
F-2
-------
Chemical Name
CAS No.
Aniline
1,4-Dichlorobenzene(p)
2,4,6-Trichlorophenol
Bis(2-ethylhexyl)phthalate (DEHP)
o-Toluidine
Propoxur
Trichloroethylene
1,4-Dioxane (1,4-Diethyleneoxide)
Acetaldehyde
Bromoform
Captan
Epichlorohydrin
Methylene chloride (Dichloromethane)
Tetrachloroethylene (Perchloroethylene)
Dibenz (ah) anthracene
Chrysene
Dimethyl aminoazobenzene
Benzo (a) anthracene
Benzo (b) fluoranthene
Antimony trioxide
2-Nitropropane
1,3-Dichloropropene
7, 12-Dimethylbenz(a)anthracene
Benz(c)acridine
Indeno( 1,2,3-cd)pyrene
1,2:7,8-Dibenzopyrene
62533
106467
88062
117817
95534
114261
79016
123911
75070
75252
133062
106898
75092
127184
53703
218019
60117
56553
205992
1309644
79469
542756
57976
225514
193395
189559
F-3
-------
-------
APPENDIX G
SOURCES OF TECHNICAL AND REGULATORY INFORMATION
Applicability Determination Index (ADI) (http://134.67.104.12/cfdocs/adiwww/adiwww.html-ssi)
The ADI is a database that contains memoranda that have been issued by the EPA on applicability
associated with compliance issues. It is made available through the Office of Air Quality Planning and
Standards (OAQPS) Technology Transfer Network (TTN) Bulletin Board System (BBS).
Clean Air Compliance for Wood Furniture Manufacturers
(http://funnelweb.utcc.utk.edu/-cis/announce/wfmanual.pdf)
This site provides a compliance document, developed by the EPA and University of Tennessee. This
guide, which can be downloaded, details the issues related to compliance with the Wood Furniture
Manufacturers NESHAP.
Do Your Process Materials Contain Regulated Chemicals? How to Read a Material Safety Data
Sheet (MSDS) to Find Out.
http://pprc.pnl.gov:80/pprc/sbapAvood.html
Pacific Northwest Pollution Prevention Resource Center (PPRC)
1326 Fifth Ave., Suite 650
Seattle, WA 98101
The PPRC is a nonprofit organization that supports projects that result in pollution prevention, toxic use
elimination and reduction. PPRC Website offers regulatory fact sheets, pollution prevention
opportunities, and compliance guidance.
Emission Estimation Worksheet
http://pprc.pnl. gov:80/pprc/sbap/wood.html
Pacific Northwest Pollution Prevention Resource Center (PPRC)
1326 Fifth Ave., Suite 650
Seattle, WA 98101
PPRC provides a worksheet to assist in calculating mass-balances and annual emissions.
Enviro$en$e (http://es.inel.gov)
EnviroSenSe is a large repository of information dealing with: pollution prevention, compliance
assurance, enforcement information, and databases.
Facts About Wood Furniture Manufacturing Operations MACT
Wisconsin Department of Natural Resources (DNR)
Bureau of Air Management
P.O. Box 7921
101 South Webster Street
Madison, Wisconsin 53707-7921
Phone: (608) 267-6897
This fact sheet, developed by Wisconsin DNR's Small Business Clean Air Assistance Program,
summarizes the emission, work practice, and recordkeeping requirements of the NESHAP.
G-l
-------
Fact Sheet: NESHAP for Wood Furniture Manufacturing Operations
http://www.deq.state.la.us/oarp/sbap/forms.htm
Louisiana Department of Environmental Quality (LA DEQ)
Office of Air Quality and Radiation Protection
P.O. Box 82135
Baton Rouge, LA 70884-2135
Phone:(504)765-0219
This fact sheet, developed LA DEQ, summarizes the emission, work practice, and recordkeeping
requirements of the NESHAP.
Fact Sheet for Wood Furniture NESHAP
South Coast Air Quality Management District (SCAQMD)
21865 East Copley Drive
Diamond Bar, CA 91765-4182
Phone: (909) 396-2000
This fact sheet, developed SCAQMD, summarizes the emission, work practice, and recordkeeping
requirements of the NESHAP.
Furniture/Wood Manufacturing and Reflnishing, U.S. EPA, RCRA Fact Sheet. (EPA/530-SW-90-
027c) This document is an overview of the wood furniture manufacturing industry and the hazardous
waste in produces.
New York Department of Environmental Conservation
Division of Air Resources
50 Wolf Road
Albany, NY 12233-3250
Phone:(518)457-7230
NY DEC is planning to publish a wood furniture NESHAP guidance document in 1998. The document
will include regulatory summaries, compliance checklists, and commonly asked questions.
North Carolina Department of Environment, Health, and Natural Resources (NC DEHNR)
Division of Air Quality
P.O. Box 29580
Raleigh, NC 27626-0580
Phone:(919)715-6232
NC DEHNR Division of Pollution Prevention and Environmental Assistance offers a web page
http:www.owr.ehnr.state.nc.us/ref/00017.htm that provides information on regulatory incentives,
emission reduction, and pollution prevention opportunities. The Division of Air Quality is also
developing a wood furniture NESHAP fact sheet.
Pollution Prevention Options in Wood Furniture Manufacturing, A Bibliographic Report, U.S.
EPA, Office of Pollution Prevention and Toxics, February 1992. (EPA/560/8-92/001C)
G-2
-------
Wood Furniture Manufacturing Industry Compliance and Pollution Prevention Workbook
http://pprc.pnl. gov:80/pprc/sbap/wood.html
Pacific Northwest Pollution Prevention Resource Center (PPRC)
1326 Fifth Ave., Suite 650
Seattle, WA 98101
The workbook is scheduled to be completed in the spring of 1997 and will contain information on
waste inventories, emission estimation, and pollution prevention opportunities.
Wood Furniture: The Clean Air Act and Pollution Prevention Opportunities
Northeast Waste Management Official Association (NEWMOA)
129 Portland Street
Boston, MA 02114
(617)367-8558
This guidance document, developed by NEWMOA and the Northeast States for Coordinating Air Use
Management, focuses on pollution prevention guidance, but also contains an overview of the CTG and
NESHAP requirements.
Wood Furniture and Fixtures Industry Sector Notebook
(http://es.inel.gov/comply/sector/index.htmlfwood)
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
Telephone orders: (202) 512-1800
The notebook provides a overview of the industries classified as 25 in the SIC code and includes: a
comprehensive environmental profile; industrial process information; pollution prevention techniques;
pollutant release data; regulatory requirements; compliance/enforcement history; innovative programs;
and contact names.
Wood Furniture MACT Implementation Strategy
Illinois Environmental Protection Agency (IEPA)
Bureau of Air
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
Phone:(217)785-4140
IEPA is in the process of developing a wood furniture implementation document that will contain
applicability flowcharts, compliance schedule, and compliance assurance. As of yet there is no set
publication date.
G-3
-------
Wood Furniture Manufacturing Fact Sheet
Virginia Department of Environmental Quality
Office of Small Business Assistance
629 East Main Street
Richmond, Virginia 23219
Phone: (804) 698-4394
This fact sheet summarizes the requirements of the NESHAP and is available at
http:\v\vw.deq.state.va.us/osba/smallbiz.html on the world wide web or contact Richard Rasmussen,
Director of Small Business Assistance.
G-4
-------
TECHNICAL REPORT DATA
1 REPORT NO 2
EPA 456/R-97-005
4 TITLE AND SUBTITLE
Wood Furniture Manufacturing Operations NESHAP
Implementation Document
7 AUTHOR! S)
Susan A. Rasor
9 PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
5520 Dillard Road, Suite 100
Gary, NC 27511
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 277 1 1
3 RECIPIENT'S ACCESSION NO
5 REPORT DATE
September 1997 ;
6 PERFORMING ORGANIZATION CODE
8 PERFORMING ORGANIZATION REPORT NO
4203-30-02
10 PROGRAM ELEMENT NO
11 CONTRACT/GRANT NO
68-D3-0031,WA30
1 3. TYPE OF REPORT AND PERIOD COVERED
Final
14 SPONSORING AGENCY CODE
EPA/200/04
15 SUPPLEMENTARY NOTES
Project Officer is Gilbert Wood, Mail Drop 12, (919) 541-5272
16 ABSTRACT
National emissions standards to control emissions of HAP from new and existing wood furniture
manufacturing operations were promulgated in 1995. This document contains information to assist State and
local air pollution control agencies as well as the regulated community in the implementation of these ;
standards. This document provides a common sense summary of the NESHAP requirements and provides
answers to commonly asked questions on the NESHAP. Sample inspection sheets are also provided as is a !
bibliography of Federal, State and private sources of additional information related to these standards.
17 KEY WORDS AND DOCUMENT ANALYSIS
a DESCRIPTORS
Air pollution
Air pollution control
National emissions standards
Hazardous air pollutants
Wood furniture industry
Implementation guidance
18 DISTRIBUTION STATEMENT
Unlimited
b IDENTIFIERS/OPEN ENDED TERMS
Air pollution control
Wood furniture
Stationary sources
19 SECURITY CLASS
Unclassified
20. SECURITY CLASS (Page)
Unclassified
c COSAT1 field/Group
13B
21 NO OF PAGES
22 PRICE
EPA Form 2220-1 (Rev. 4-7T)
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