Statutes, codes, and regulations
Rhode Island Administrative Code
Title 250 - Department of Environmental ManagementChapter 120 - Air ResourcesSubchapter 05 - Air Pollution Control
Part 35 - Air Pollution Control Regulation No. 35- Control of Volatile Organic Compounds and Volatile Hazardous Air Pollutants from Wood Products Manufacturing Operations
Section 250-RICR-120-05-35.10 - Compliance Procedures and Monitoring Requirements

250 R.I. Code R. 250-RICR-120-05-35.10

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Current through December 26, 2024
Section 250-RICR-120-05-35.10 - Compliance Procedures and Monitoring Requirements
35.10.1Compliance Using Compliant Coatings
A. Compliance with the emissions limitations in §§ 35.7 and 35.8 of this Part through the use of compliant coatings shall be demonstrated by the following methods:
1. Maintaining Certified Product Data Sheets (CPDS) documenting that the VOC and/or VHAP content of each topcoat, filler, stain, toner, ink, multicolored coating, pigmented coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and strippable booth coating meets the applicable emissions limitations in §§ 35.7 and 35.8 of this Part; and
2. Maintaining formulation data and related calculations showing that the VOC and VHAP content of each topcoat, filler, stain, toner, ink, multicolored coating, sealer, washcoat, enamel, basecoat, adhesive and strippable booth coating diluted onsite, as applied, meets the applicable emissions limitations in §§ 35.7 and 35.8 of this Part; and
3. For facilities with continuous coaters, using one of the following procedures:
a. Calculating the VOC and VHAP content, as applicable, of the finishing material in the reservoir from information on the CPDS and records of materials added to the reservoir; or
b. Monitoring the viscosity of the finishing material in the reservoir with a viscosity meter or testing the viscosity of the initial finishing material and retesting the material in the reservoir each time solvent is added. If this option is chosen, the facility shall maintain data that demonstrates the correlation between the viscosity of the finishing material and the VOC and VHAP content, as applicable, of the finishing material; and
4. The Department or EPA will determine compliance either by reviewing the records specified in §§35.10.1(A)(1) through (3) of this Part or by conducting a performance test according to the specifications in §§ 35.12.1 and 35.12.2 of this Part. If the VOC or VHAP content of a coating determined by a performance test using the procedures specified in §§ 35.12.1 and 35.12.2 of this Part is greater than that indicated on a CPDS or by the facility's formulation or viscosity data, the performance test results shall govern.
35.10.2Compliance Using Averaging
A. To demonstrate compliance with the VOC emission limitations for a particular coating category listed in §§35.7.1(B)(1) of this Part for coatings used prior to January 1, 2020, through the use of averaging, the owner or operator of a facility shall, each week:
1. Calculate the average VOC content for all coatings in that category used at the facility using Equation 1.1:

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2. Demonstrate that the value calculated for E VOC is no greater than 0.9 times the emission limitation, in lbs VOC/gallon coating minus water and exempt compounds, as applied, for that coating category, as listed in §35.7.1(B) (1) of this Part
B. To demonstrate compliance with the VOC emission limitations for a particular coating category listed in §35.7.1(C)(1) of this Part for coatings used after January 1, 2020, through the use of averaging, the owner or operator of a facility shall, each week:
1. Calculate the average VOC content for all coatings in that category used at the facility using Equation 1.2:

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2. Demonstrate that the value calculated for E VOC is no greater than 0.9 times the emission limitation, in lbs VOC/lb solids, as applied, for that coating category, as listed in §35.7.1(C)(1) of this Part
C. To demonstrate compliance with the VHAP emission limitations in §§ 35.7.2 and 35.7.3 of this Part through the use of averaging, the owner or operator of a facility shall, each month:
1. Calculate the average VHAP content for all finishing materials used at the facility using Equation 2:

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2 Demonstrate that the value calculated for E VHAP is no greater than one (1) if the facility is complying with § 35.7.2 of this Part and is no greater than 0.8 if the facility is complying with § 35.7.3 of this Part
35.10.3Initial Compliance Using Control Equipment
A. The owner or operator of a facility which uses control equipment to comply with the VOC emission limitations in §35.7.1(B)(1) of this Part for coatings used prior to January 1, 2020, or §35.7.1(C)(1) of this Part for coatings used after January 1, 2020, or the VHAP limitations in §§ 35.7.2 and/or 35.7.3 of this Part shall conduct an initial performance test to measure the capture and control efficiency of the control system using the procedures specified in § 35.12.3 of this Part within ninety (90) days of start-up.
B. Initial compliance with VOC emission limitations for finishing materials through the use of a control system shall be determined as follows:
1. Calculate the overall control efficiency needed (Rn) for each finishing material which will be controlled by the control equipment using the following equation:

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2. Document that the value of C used in Equation 3 in §35.10.3(B)(1) of this Part was calculated from the VOC and solids content of the as-applied finishing material
3. Demonstrate, for all applicable coatings, that the value of Rn calculated using Equation 3 in §35.10.3(B)(1) of this Part is less than or equal to the actual overall control efficiency (R) calculated by substituting the capture efficiency (N) and control efficiency (F) of the control system measured in the initial performance test into Equation 4 in §35.10.3(D)(3) of this Part.

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C. Initial compliance with VHAP emission limitations for finishing materials through the use of a control system shall be determined as follows:
1. Calculate the overall control efficiency needed, Rn, so that the value of Eac in Equation 5 is no greater than 1.0 if complying with § 35.7.2 of this Part and so that the value of Eac in Equation 5 in §35.10.3(C)(1) of this Part is no greater than 0.8 if complying with § 35.7.3 of this Part;

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2 Demonstrate that the value of R n calculated using Equation 5 in §35.10.3(C)(1) of this Part is less than or equal to the actual overall control efficiency (Ra) calculated using the capture efficiency (N) and control efficiency (F) of the control system measured in the initial performance test and Equation 4 in §35.10.3(B)(3) of this Part.

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D. Initial compliance with VHAP emission limitations for gluing materials through the use of a control system shall be determined as follows:
1. Calculate the overall control efficiency of the control system needed (Rn) so that the value of Gac in Equation 6 in §35.10.3(D)(1) of this Part is no greater than 1.0 if complying with § 35.8(B) of this Part and 0.2 if complying with § 35.8(C) of this Part;
2 Demonstrate that the value of Rn calculated using Equation 6 in §35.10.3(D)(1) of this Part is less than or equal to the actual overall control efficiency (Ra) calculated using the capture efficiency (N) and control efficiency (F) of the control system measured in the initial performance test and Equation 4 in §35.10.3(B)(3) of this Part.
35.10.4Continuous Compliance Using Control Equipment
A. The owners or operator of a facility that is complying with the emission limitations in this regulation through the use of a control system shall demonstrate continuous compliance by installing, calibrating, maintaining, and operating appropriate monitoring equipment according to manufacturers' specifications.
B. The monitoring equipment installed pursuant to §35.10.4(A) of this Part shall measure operating parameters which indicate ongoing compliance with the control efficiency requirements in this regulation.
C. Where a thermal incinerator is used, the operating parameter to be monitored shall be minimum combustion temperature, and a temperature monitoring device equipped with a continuous recorder shall be installed in the firebox or in the ductwork immediately downstream of the firebox in a position before any substantial heat exchange occurs.
D. Where a catalytic incinerator equipped with a fixed catalyst bed is used, the operating parameter to be monitored shall be the minimum gas temperature upstream and downstream of the catalyst bed and temperature monitoring devices equipped with continuous recorders shall be installed in the gas stream immediately before and after the catalyst bed.
E. Where a catalytic incinerator equipped with a fluidized catalyst bed is used, the operating parameters to be monitored shall be the minimum gas temperature upstream of the catalyst bed and the pressure drop across the catalyst bed, and temperature monitoring devices equipped with continuous recorders shall be installed in the gas stream immediately before the bed. In addition, a pressure monitoring device shall be installed to determine the pressure drop across the catalyst bed. A constant pressure drop, as measured monthly at a constant flow rate, shall be maintained.
F. Where a carbon adsorber is used, the operating parameters to be monitored shall be either the total regeneration mass stream flow for each regeneration cycle and the carbon bed temperature after each regeneration, or the concentration level of organic compounds exiting the adsorber, unless the owner or operator requests and receives approval from the Department and the EPA to establish other operating parameters. One of the following devices is required to monitor these parameters:
1. An integrating regeneration stream flow monitoring device having an accuracy of ± ten percent (10%), capable of recording the total regeneration stream mass flow for each regeneration cycle; and a carbon bed temperature monitoring device having an accuracy of one percent (+1%) of the temperature being monitored expressed in degrees Celsius or ± 0.5°C, whichever is greater, capable of recording the carbon bed temperature after each regeneration and within fifteen (15) minutes of completing any cooling cycle;
2. An organic monitoring device, equipped with a continuous recorder, to indicate the concentration level of organic compounds exiting the carbon adsorber; or
3. Another monitoring device that has been approved by the Department and the EPA.
G. A facility using a control device not listed in this section to comply with this regulation shall submit to the Office of Air Resources a description of the device, test data verifying the performance of the device, and appropriate operating parameter values that will be monitored to demonstrate continuous compliance with the standard. Compliance using this device is subject to the approval of the Department and the EPA.
H. Operating parameter values indicating compliance shall be calculated as the arithmetic average of the maximum or minimum value of those parameters, as appropriate, measured during the three (3) test runs of the initial performance test, provided that the initial performance test demonstrated compliance.
I. The capture or control device shall be operated so that the average of all values for a monitored parameter recorded during each operating day is in compliance with the operating parameter value calculated according to the procedures in §35.10.4(H) of this Part.

250 R.I. Code R. 250-RICR-120-05-35.10

Adopted effective 1/13/2019