250 R.I. Code R. 250-RICR-120-05-35.9

Current through November 7, 2024

Section 250-RICR-120-05-35.9 - Work Practice Standards

35.9.1Work Practice Implementation Plan

A. The owner or operator of a facility subject to this regulation shall prepare and maintain a written work practice implementation plan that defines work practices for each wood products manufacturing operation and addresses each of the topics specified in §§ 35.9.2 through 35.9.6 of this Part.

B. The owner or operator of the facility shall comply with each provision of the work practice implementation plan.

C. The work practice implementation plan shall be available for inspection by the EPA or the Department upon request and shall be modified by the facility if found to be inadequate.

35.9.2Operator Training Course

A. Each owner or operator of a facility subject to this regulation shall train all new and existing personnel, including contract personnel, who are involved in finishing, gluing, cleaning, or washoff operations, use of manufacturing equipment, or implementation of the requirements of this Part.

B. All personnel shall be trained upon hiring. All personnel shall be given refresher training annually.

C. Initial and refresher trainings shall include, at a minimum, the following topics:

1. Appropriate application techniques;

2. Appropriate cleaning and washoff procedures;

3. Appropriate equipment setup and adjustment to minimize finishing material usage and overspray; and

4. Appropriate management of cleanup wastes.

D. The facility shall maintain records of the training program. Records shall include, at a minimum, the following:

1. A list of all current personnel by name and job description who are required to be trained and a record of the date that each employee was trained;

2. An outline of the subjects covered in the initial and refresher training for each position, or group of personnel;

3. Lesson plans for courses to be given at the initial and the annual refresher training that include, at a minimum, the topics specified in §35.9.2(C) of this Part; and

4. A description of the methods to be used to demonstrate successful completion of initial and refresher training.

35.9.3Equipment Operation, Maintenance, Inspection and Repair

A. Equipment Leak Inspection and Repair

1. All equipment used to transfer or apply finishing materials, adhesives, or organic solvents shall be visually inspected for leaks at least once per month.

2. A first attempt at repair shall be made no later than three (3) calendar days after a leak is detected and final repairs shall be made within ten (10) calendar days, unless the leaking equipment is to be replaced by a new purchase, in which case repairs shall be completed within three (3) months.

3. The owner or operator of a source subject to this regulation shall prepare and maintain a written leak inspection and maintenance plan that includes:

a. A schedule for conducting visual inspections required in §35.9.3(A) of this Part; and

b. A log documenting the date and results of each inspection and any repairs that are made.

B. Operation and Maintenance Requirements

1. At all times, including periods of startup, shutdown, and malfunction, owners or operators shall operate and maintain any equipment associated with wood products manufacturing operations, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions.

2. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan required in §35.9.3(B)(4) of this Part.

3. The Department will determine whether acceptable operation and maintenance procedures are being used, based on information which may include, but is not limited to, monitoring results, review of operation and maintenance procedures (including the startup, shutdown, and malfunction plan required in §35.9.3(B)(4) of this Part), review of operation and maintenance records, and inspection of the facility.

4. The owner or operator of a facility subject to this regulation shall develop and implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining equipment associated with wood products manufacturing operations during periods of startup, shutdown, and malfunction and a program of corrective action for malfunctioning process and air pollution control equipment used to comply with this regulation. The facility's standard operating procedures (SOP) manual, an Occupational Safety and Health Administration (OSHA) or another plan can be used to fulfill this requirement, provided the plan meets all the requirements of this paragraph. Startup, shutdown, and malfunction plans shall be maintained at the facility and made available to the Department or the EPA for review upon request and shall be revised if determined to be unacceptable.

5. During periods of startup, shutdown, and malfunction, the owner or operator of a facility subject to this regulation shall operate and maintain equipment associated with wood products manufacturing operations (including associated air pollution control equipment) in accordance with the procedures specified in the startup, shutdown, and malfunction plan developed according to the provisions of §35.9.3(B)(4) of this Part.

6. The owner or operator of a facility subject to this regulation shall keep records of action taken during startups, shutdowns, and malfunctions, including actions taken to correct malfunctions and shall certify, in the semi-annual reports required in § 35.11(G) of this Part, that all such actions were consistent with the procedures specified in the facility's startup, shutdown and malfunction plan developed under §35.9.3(B)(4) of this Part.

7. If actions taken by the owner or operator during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) are not consistent with the procedures specified in the facility's startup, shutdown, and malfunction plan, the owner or operator shall record the actions taken and report such actions to the Office of Air Resources within two (2) working days after beginning actions inconsistent with the plan, followed by a letter within seven (7) working days after the end of the event.

8. If a malfunction occurs that was not adequately addressed in the startup, shutdown, and malfunction plan, the owner or operator shall revise the plan within forty-five (45) days after the event to include detailed procedures for operating and maintaining the source during similar malfunction events and a program of corrective action for similar malfunctions of process or air pollution control equipment.

35.9.4Cleaning and Washoff Solvent Requirements

A. The owner or operator of a facility subject to this regulation shall account for organic solvent use in cleaning and washoff operations by recording the following information:

1. The quantity and types of organic solvent used in washoff and cleaning operations each month;

2. The number of pieces washed off, and the reason for the washoff; and

3. The quantity of spent organic solvent generated from each washoff and cleaning activity each month, and whether it is recycled onsite or disposed offsite.

B. Facilities subject to this regulation shall not use cleaning or washoff solvents that contain any of the pollutants listed in § 35.14 of this Part in concentrations greater than 0.1%.

C. Spray Booth Cleaning

1. Facilities subject to this regulation shall not use compounds containing more than eight percent (8%) by weight of VOC for cleaning spray booth components other than conveyors, continuous coaters and their enclosures, or metal filters, unless the spray booth is being refurbished. If the spray booth is being refurbished, that is, the spray booth coating or other material used to cover the booth is being replaced, the facility shall use no more than one (1) gallon of organic solvent per booth to prepare the booth prior to applying the booth coating.

D. Storage Requirements

1. All finishing, gluing, cleaning, and washoff materials shall be stored in containers that are closed at all times except when material is being added or removed.

35.9.5Application Equipment Requirements

A. The owner or operator of any wood products facility which has the potential to emit twenty-five (25) tons per year or more of volatile organic compounds (VOC) from wood products manufacturing operations, and is not a major source of HAP from wood product manufacturing operations shall not use conventional air spray guns to apply finishing materials, except in the following situations:

1. When applying finishing materials that have a VOC content no greater than 1.0 lb VOC/lb solids, as applied;

2. Touch-up or repair that occurs after the completion of a finishing operation;

3. Touch-up or repair that occurs after the stain and before any other type of finishing material is applied, provided that the touch-up finishing materials are applied from a container that has a volume of no more than two (2) gallons;

4. If the spray gun is aimed and triggered automatically, not manually;

5. If emissions from the finishing application station are directed to a control device;

6. For application of a finishing material if the total usage of that finishing material is no more than five percent (5%) of the total gallons of all finishing materials used at that facility during that semi-annual reporting period, as specified in § 35.11(G)(1)(a) of this Part; or

7. The application of stain on a part for which it is technically or economically infeasible to use any other spray application technology. The facility must demonstrate technical or economic infeasibility by submitting documentation to the Department that the following criteria, either independently or in combination, are met:

a. 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

b. The excessively large vertical spray area of the part makes it difficult to avoid sagging or runs in the stain.

8. Line Cleaning a. All organic solvent used for line cleaning shall be pumped or drained into a container that is closed at all times except when material is being added or removed.

9. Gun Cleaning

a. All organic solvent used to clean spray guns shall be collected in a container that is closed at all times except when material is being added or removed.

B. Beginning January 1, 2020, the owner or operator of a facility which is a major source of hazardous air pollutants from wood products manufacturing operations shall not use conventional air spray guns except when all emissions from the finishing application station are routed to a functioning control device.

35.9.6Washoff Operations

A. Emissions from washoff operations shall be controlled by:

1. Using tanks for washoff that are closed at all times except when material is being added or removed; and

2. Minimizing dripping by tilting or rotating the part to drain as much organic solvent as possible.

35.9.7Formulation Assessment Plan

A. Each owner or operator of a facility that is subject to this regulation and that is a major source of hazardous air pollutants from wood products manufacturing operations shall prepare and maintain a formulation assessment plan that:

1. Lists all VHAP from § 37.13 of this Part that are being used in finishing operations at the facility.

2. Establishes a baseline level of usage by the facility for each VHAP as follows:

a. The baseline usage level shall be the annual usage from the most recent calendar year for each VHAP;

b. 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;

c. For styrene, the baseline level of usage shall be an estimate of unreacted styrene, which shall be calculated by multiplying the amount of styrene monomer in the finishing material when it is applied by a factor of 0.16; and

d. Facilities using a control device to reduce emissions may adjust their baseline usage based on the overall control efficiency of the control system, calculated using Equation 5 in §35.10.3(C)(1) of this Part.

e. The baseline levels for a VHAP that was not used in the most recent calendar year shall be established as twenty percent (20%) of the Minimum Quantity for that substance specified in Part 22 of this of this Subchapter (Air Toxics).

3. Tracks the annual usage of each VHAP used by the facility.

4. If the usage of a VHAP in any year exceeds its baseline level, then the owner or operator of the facility shall provide a written notification to the Division by January 31 of the following year that specifies the amount of the increase and explains the reasons for the increase. The Department will determine whether the increase would cause an exceedance of the Acceptable Ambient Levels specified in Part 22 of this Subchapter (Air Toxics). If those limits are exceeded, the Department will develop a timetable for the facility to achieve compliance and a schedule for submitting notification of progress.

250 R.I. Code R. 250-RICR-120-05-35.9

Amended effective 1/13/2019