Title 7 Natural Resources and Environmental Control
1124 Control of Volatile Organic Compound Emissions
23.0 Coating of Flat Wood Panelling
03/11/11
23.1.1 The provisions of 23.0 of this regulation apply to any flat wood paneling coating line, except as specified in 23.1.2 of this regulation.
23.1.2 The provisions of 23.0 of this regulation do not apply to any flat wood paneling coating line within any facility whose actual emissions without control devices from all flat wood paneling coating lines within the facility are less than 6.8 kilograms (kg) (15 pounds [lb]) of volatile organic compounds (VOCs) per day.
23.1.3 An owner or operator of a facility whose emissions are below the applicability threshold in 23.1.2 of this regulation shall comply with the certification, recordkeeping, and reporting requirements of 23.7.1 of this regulation.
23.1.4 Any facility that becomes or is currently subject to the provisions of 23.0 of this regulation by exceeding the applicability threshold in 23.1.2 of this regulation will remain subject to these provisions even if its emissions later fall below the applicability threshold.
23.1.5 Any facility that is currently subject to a state or federal rule promulgated pursuant to the Clean Air Act Amendments of 1977 by exceeding an applicability threshold is and will remain subject to these provisions, even if its throughput or emissions have fallen or later fall below the applicability threshold.
23.2 Definitions. As used in 23.0 of this regulation, all terms not defined herein shall have the meaning given them in the November 15, 1990 Clean Air Act Amendments (CAAA), or in 2.0 of this regulation.
“Class I hardboard paneling finish” means finishes that meet the specifications for Class I of Voluntary Product Standard PS-59-73 as approved by the American National Standards Institute.
“Class II hardboard paneling finish” means finishes that meet the specifications for Class II of Voluntary Product Standard PS-59-73 as approved by the American National Standards Institute.
"Exterior siding" means wood panels with a flat surface made of solid wood, hardboard, or waferboard and are intended for use in commercial or residential construction, generally as a covering for an outside wall.
“Flat wood paneling coating line” means a coating line used to apply and dry or cure coatings applied to one of the following flat wood paneling product categories: printed interior panels made of hardwood plywood and thin particle board (i.e., less than or equal to 0.64 centimeter (cm) (0.25 inch [in.]) in thickness); natural finish hardwood plywood panels; and hardwood paneling with Class II finishes.
“Hardboard” is a panel manufactured primarily from inter-felted ligno-cellulosic fibers that are consolidated under heat and pressure in a hot press.
“Hardwood plywood” is plywood whose surface layer is a veneer of hardwood.
“Natural finish hardwood plywood panels” means panels whose original grain pattern is enhanced by essentially transparent finishes frequently supplemented by fillers and toners.
“Printed interior panels” means panels whose grain or natural surface is obscured by fillers and basecoats upon which a simulated grain or decorative pattern is printed.
“Thin particleboard” is a manufactured board that is 0.64 cm (0.25 in.) or less in thickness made of individual wood particles that have been coated with a binder and formed into flat sheets by pressure.
“Tileboard” means paneling that meets the specifications for Class I hardboard given by the standard ANSI/AHA A135.4-1995 as approved by the American National Standards Institute. The standard specifies requirements and test methods for water absorption, thickness swelling, modulus of rupture, tensile strength, surface finish, dimensions, squareness, edge straightness, and moisture content for five classes of hardboard. Tileboard is also known as Class I hardboard or tempered hardboard.
23.3 Standards
23.3.1 No owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation shall cause or allow, on any day, VOC emissions from the coating of any one of the following flat wood paneling product categories in excess of the emission limits in Table 23-1 of this regulation:
Table 23-1. VOC Emission Limits from Flat Wood Paneling Coatings.
|
Flat Wood Paneling Product Category |
VOC Content Limits in Coatings, Inks, or Adhesives Being Applied | |
lb/gal |
g/L | |
Printed interior panels made of hardwood, plywood, or thin particleboard |
2.1* |
250 |
Natural finish hardwood plywood panels |
2.1 |
250 |
Class II finishes on hardboard panels |
2.1 |
250 |
Tileboard |
2.1 |
250 |
Exterior siding |
2.1 |
250 |
*This limit of 2.1 lb/gal is equivalent to 5.0 lb VOC per 1,000 ft2 coating area.
23.3.2 As an alternative to compliance with the emission limits in 23.3.1 of this regulation, an owner or operator of a flat wood paneling coating line may meet the requirements of 23.5 of this regulation.
23.4 Work Practice Standards. No owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation shall perform coating operation of any flat wood paneling category in Table 23-1 of this regulation unless the owner or operator meets the work practice requirements of 8.0 of this regulation.
23.5 Control devices
23.5.1 An owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation may comply with 23.0 of this regulation by:
23.5.1.1 Installing and operating a capture system on that line.
23.5.1.2 Installing and operating a control device on that line.
23.5.1.3 Determining for each day the overall emission reduction efficiency needed to demonstrate compliance. The overall emission reduction needed for a day is the greater of:
23.5.1.3.1 lesser of the value calculated according to the procedure in 23.6.2 of this regulation for that day or 95%, or
23.5.1.3.2 90%.
23.5.1.4 Demonstrating each day that the overall emission reduction efficiency achieved for that day, as determined in 3.0of Appendix D of this regulation, is greater than or equal to the overall emission reduction efficiency needed for that day as determined in 23.5.1.3 of this regulation.
23.5.2 An owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation shall ensure that:
23.5.2.1 A capture system and control device are operated at all times that the line is in operation, and the owner or operator demonstrates compliance with 23.0 of this regulation through the applicable coating analysis and capture system and control device efficiency test methods specified in Appendix B, Appendix D and Appendix E of this regulation and in accordance with the capture efficiency test methods in Appendix D of this regulation.
23.5.2.2 The control device is equipped with the applicable monitoring equipment specified in 2.0 of Appendix D of this regulation, and the monitoring equipment is installed, calibrated, operated, and maintained according to the vendor's specifications at all times the control device is in use.
23.6 Test Methods and Efficiency of Control System
23.6.1 The test methods specified in 23.6, Appendix A, Appendix B and Appendix D of this regulation shall be used to determine compliance.
23.6.2 The required overall emission reduction efficiency of the control system for the day shall be calculated according to the following equation:
(23-1)
where:
E = The required overall emission reduction efficiency of the control system for the day.
VOCa = The maximum VOC content of the coatings, as applied, used each day on a coating line in units of lb VOC/gal of coating material applied (or kg VOC/L of coating material applied), as determined by the applicable test methods and procedures specified in Appendix B of this regulation.
S = applicable VOC emission limitation in Table 23-1 of this regulation in terms of lb VOC/gal of coating material applied (or kg VOC/L of coating material applied).
23.7 Recordkeeping and reporting
23.7.1 Requirements for coating sources exempt from emission limitations. An owner or operator of a flat wood paneling coating line that is exempt from the emission limitations of 23.3 of this regulation because combined VOC emissions on any day from all flat wood paneling coating lines at the facility are below the applicability threshold specified in 23.1.2 of this regulation, before the application of capture systems and control devices, shall comply with the following:
23.7.1.1 Certification. Within six months after March11, 2011, the owner or operator of a facility specified in 23.7.1 of this regulation shall certify to the Department that the facility is exempt by providing the following:
23.7.1.1.1 The name and location of the facility.
23.7.1.1.2 The address and telephone number of the person responsible for the facility.
23.7.1.1.3 A declaration that the facility is exempt from the emission limitations of 23.3 of this regulation because combined VOC emissions on any day from all flat wood paneling coating lines at the facility are below the applicability threshold before the application of capture systems and control devices. The following equation shall be used to calculate total VOC emissions for that day:
(23-2)
where:
T = Total VOC emissions from coating lines at the facility for each category of flat wood paneling (as specified in 23.3.1 of this regulation) before the application of capture systems and control devices in units of kg VOC/day (lb VOC/day).
n = Number of different coatings applied on each coating line at the facility.
i = Subscript denoting an individual coating.
C = Mass of VOC per area of coated finished product in units of kg VOC/100 m2 (lb VOC/1,000 ft2).
D = The surface area coated at the facility each day in units of m2/day (ft2/day).
a = Constant = 100 m2 if using metric units.
= 1,000 ft2 if using English units.
23.7.1.2 Recordkeeping. On and after March 11, 2011, the owner or operator of a facility specified in 23.7.1 of this regulation shall collect and record all of the following information each day and maintain the information at the facility for a period of five years:
23.7.1.2.1 The name and identification number of each coating, as applied, used to coat each type of flat wood paneling product.
23.7.1.2.2 The volume of coating (i) (excluding water and exempt compounds), as applied, used each day to coat each type of flat wood paneling product (specified in 23.3.1 of this regulation), and the surface area coated each day of each type of flat wood paneling product.
23.7.1.2.3 The total VOC emissions at the facility, as calculated using the equation under 23.7.1.1.3 of this regulation.
23.7.1.3 Reporting. On and after March 11, 2011, the owner or operator of a facility specified in 23.7.1 of this regulation shall notify the Department of any record showing that combined VOC emissions from all coating lines at the coating facility exceed 6.8 kg (15 lb) on any day, before the application of capture systems and control devices. A copy of such record shall be sent to the Department within 45 calendar days after the exceedance occurs. This requirement is in addition to any other exceedance reporting requirements mandated by the State of Delaware.
23.7.2 Requirements for coating sources using complying coatings. An owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation and complying with 23.3 of this regulation by means of the use of complying coatings shall comply with the following:
23.7.2.1 Certification. By Within six months after March 11, 2011, or upon startup of a new coating line, or upon changing the method of compliance for an existing coating line from control devices to the use of complying coatings, the owner or operator of a coating line specified in 23.7.2 of this regulation shall certify to the Department that the coating line is or will be in compliance with the requirements of the applicable section of this regulation on and after March 11, 2011, or on and after the initial startup date. Such certification shall include:
23.7.2.1.1 The name and location of the facility.
23.7.2.1.2 The address and telephone number of the person responsible for the facility.
23.7.2.1.3 Identification of subject sources.
23.7.2.1.4 The name and identification number of each coating, as applied, used to coat each type of flat wood paneling product.
23.7.2.1.5 The VOC content of each coating for each type of flat wood paneling product (specified in 23.3.1 of this regulation) in terms of lb VOC/gal of coating material applied (or kg VOC/L of coating material applied) and the volume of each coating (in terms of gal or L) coated each day of each type of flat wood paneling product.
23.7.2.2 Recordkeeping. On and after March 11, 2011, or on and after the initial startup date, the owner or operator of a coating line referenced in 23.7.2 of this regulation and complying by the use of complying coatings shall collect and record all of the following information each day for each coating line and maintain the information at the facility for a period of five years:
23.7.2.2.1 The name and identification number of each coating, as applied, used to coat each type of flat wood paneling product.
23.7.2.2.2 The VOC content of each coating for each type of flat wood paneling product (specified in 23.3.1 of this regulation) for each coating used each day in terms of lb VOC/gal of coating material applied (or kg VOC/L of coating material applied) and the volume of each coating (in terms of gal or L) coated each day of each type of flat wood paneling product.
23.7.2.3 Reporting. On and after March 11, 2011, the owner or operator of a flat wood paneling coating line referenced in 23.7.2 of this regulation shall notify the Department in either of the following instances:
23.7.2.3.1 Any record showing use of any noncomplying coatings shall be reported by sending a copy of such record to the Department within 45 calendar days following that use. This reporting requirement is in addition to any other exceedance reporting mandated by the State of Delaware.
23.7.2.3.2 At least 30 calendar days before changing the method of compliance from the use of complying coatings to control devices, the owner or operator shall comply with all requirements of 23.7.3.1 of this regulation, as well as 7 DE Admin. Code 1102. Upon changing the method of compliance from the use of complying coatings to control devices, the owner or operator shall comply with all requirements of the section applicable to the coating line referenced in 23.7.3 of this regulation.
23.7.3 Requirements for coating sources using control devices. Any owner or operator of a flat wood paneling coating line subject to 23.0 of this regulation and complying with 23.3 of this regulation by the use of control devices shall comply with the following:
23.7.3.1 Testing of control equipment. By Within six months after March 11, 2011, or upon startup of a new coating line, or upon changing the method of compliance for an existing coating line from the use of complying coatings to control devices, the owner or operator of the subject coating line shall perform a compliance test. Testing shall be performed within 90 days of startup, and pursuant to the procedures in Appendix A, Appendix B and Appendix D of this regulation and 23.6 of this regulation. The owner or operator of the subject coating line shall submit to the Department the results of all tests and calculations necessary to demonstrate that the subject coating line is or will be in compliance with the applicable section of this regulation on and after March 11, 2011, or on and after the initial startup date.
23.7.3.2 Recordkeeping. On and after March 11, 2011, or on and after the initial startup date, the owner or operator of a coating line referenced in 23.7.3 of this regulation shall collect and record all of the following information each day for each coating line and maintain the information at the facility for a period of five years:
23.7.3.2.1 The name and identification number of each coating used on each coating line, as applied, used to coat each type of flat wood paneling product.
23.7.3.2.2 The VOC content of each coating for each type of flat wood paneling product (specified in 23.3.1 of this regulation) in terms of lb VOC/gal of coating material applied (or kg VOC/L of coating material applied), and the volume of each coating (in terms of gal or L) coated each day of each type of flat wood paneling product.
23.7.3.2.3 The maximum VOC content of the coatings, as applied, used each day (in terms of lb VOC/gal of coating material applied [or kg VOC/L of coating material applied].
23.7.3.2.4 The required overall emission reduction efficiency for each day for each coating line as determined in 23.6.2 of this regulation.
23.7.3.2.5 The actual overall emission reduction efficiency achieved for each day for each coating line as determined in 3.0 of Appendix D of this regulation.
23.7.3.2.6 Control device monitoring data.
23.7.3.2.7 A log of operating time for the capture system, control device, monitoring equipment, and the associated coating line.
23.7.3.2.8 A maintenance log for the capture system, control device, and monitoring equipment detailing all routine and non-routine maintenance performed including dates and duration of any outages.
23.7.3.2.9 For thermal incinerators, all 3-hour periods of operation in which the average combustion temperature was more than 10°C (50°F) below the average combustion temperature during the most recent performance test that demonstrated that the facility was in compliance. The combustion chamber set-point shall be no less than that during the most recent performance test that demonstrated that the facility was in compliance.
23.7.3.2.10 For catalytic incinerators, all three-hour periods of operation in which the average temperature of the process vent stream immediately before the catalyst bed is more than 10°C (50°F) below the average temperature of the process vent stream immediately before the catalyst bed during the most recent performance test that demonstrated that the facility was in compliance. The set-point for the process vent stream immediately before the catalyst bed shall be no less than that during the most recent performance test that demonstrated that the facility was in compliance.
23.7.3.2.11 For carbon adsorbers, all three-hour periods of operation during which either the average VOC concentration or the reading of organics in the exhaust gases is more than 20% greater than the average exhaust gas concentration or reading measured by the organics monitoring device during the most recent determination of the recovery efficiency of the carbon adsorber that demonstrated that the facility was in compliance.
23.7.3.3 Reporting. On and after March 11, 2011, the owner or operator of a subject coating line referenced in 23.7.3 of this regulation shall notify the Department in the following instances:
23.7.3.3.1 Any record showing noncompliance with the applicable requirements for control devices shall be reported by sending a copy of the record to the Department within 45 calendar days following the occurrence. This requirement is in addition to any other exceedance reporting mandated by the State of Delaware.
23.7.3.3.2 At least 30 calendar days before changing the method of compliance from control devices to the use of complying coatings, the owner or operator shall comply with all requirements of 23.7.2.1 of this regulation, and 7 DE Admin. Code 1102. Upon changing the method of compliance from control devices to the use of complying coatings, the owner or operator shall comply with all requirements of the Section applicable to the coating line referenced in 23.7.2 of this regulation.
14 DE Reg. 902 (03/01/11)
