Tenn. Comp. R. & Regs. 1200-03-18-.21 - COATING OF FLAT WOOD PANELING

(1) Applicability of this rule is as follows:
(a) This rule applies to all flat wood paneling coating lines.
(b) This rule does not apply to:
1. Class I hardwood panels, particle board used in furniture, insulation board, exterior siding, tileboard, and softwood plywood coating lines; or
2. Any flat wood paneling coating line within any facility:
(i) In Davidson, Rutherford, Sumner, Williamson, or Wilson County 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 (VOC's) per day or whose maximum theoretical emissions from all flat wood paneling coating lines within the facility are less than 10 tons of volatile organic compounds (VOC's) per year;
(ii) In Hamilton or Shelby County whose potential VOC emissions from all flat wood paneling coating lines within the facility are less than 25 tons of volatile organic compounds (VOC's) per year; or
(iii) In any other county whose potential VOC emissions from all flat wood paneling coating lines within the facility are less than 100 tons of volatile organic compounds (VOC's) per year.
(2) For the purpose of this rule, the following definitions apply:

"Class II hardboard paneling finish" means finishes that meet the specifications of Voluntary Product Standard PS-59-73 as approved by the American National Standards Institute.

"Flat wood paneling coating line" means a coating line used in manufacturing to apply and dry or cure coatings applied to flat wood panels including: printed interior panels made of hardwood plywood and thin particle board (i.e., less than or equal to 0.64 centimeters (cm) (0.25 inches [in]) in thickness); natural finish hardwood plywood panels; and hardwood paneling with Class II finishes.

"Hardboard" is a panel manufactured primarily from interfelted 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 has a colored, waterproof surface coating.

(3) Standards as follow apply:
(a) No owner or operator of a flat wood paneling coating line subject to this rule shall cause or allow VOC emissions from the coating of any flat wood paneling product in excess of the following emission limits:

kg/ 100 2a m lb/1, 000 2a ft
1. Printed interior panels 2.9 6.0
2. Natural finish hardwood plywood panels 5.8 12.0
3. Class II finish on hardwood panels 4.8 10.0

a VOC content values are expressed in units of mass of VOC (kg, lb) per volume of 2 surface to which the coating is applied (100 square meters [m ], 1,000 square feet 2 [ft ]).

(b) As an alternative to compliance with the emission limits in Subparagraph (a) of this paragraph, an owner or operator of a flat wood paneling coating line may meet the requirements of Paragraph (4) or (5) of this rule.
(4) No owner or operator of a flat wood paneling coating line subject to this rule shall apply coatings on that line, during any day, whose weighted average VOC content, calculated in accordance with the procedure in this rule, exceeds the emission limits in this rule.
(5) Control device requirements as follow apply:
(a) An owner or operator of a flat wood paneling coating line subject to this rule may comply with this rule by:
1. Installing and operating a capture system and a control device on that line;
2. Determining for each day the overall emission reduction efficiency needed to demonstrate compliance. The overall emission reduction needed is the lesser of the value calculated according to the procedure in this rule or 95 percent; and
3. Demonstrating each day that the overall emission reduction efficiency achieved is greater than or equal to the overall emission reduction efficiency required.
(b) An owner or operator of a flat wood paneling coating line subject to this rule shall ensure that:
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 this rule through the applicable coating analysis and capture system and control device efficiency test methods specified in this chapter; and
2. The control device is equipped with the applicable monitoring equipment specified in this chapter, 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.
(6) The test methods found in this chapter and in this paragraph as follow shall be used to determine compliance:
(a) The weighted average VOC content, in units of mass of VOC per area of surface coated, of the coatings used on a day on a flat wood paneling coating line shall be calculated using the following equation:

Click to view Image

where

VOCw = The weighted average VOC content of the coatings, as applied, used in units 22 of kg VOC/100 m (lb VOC/1,000 ft );

n = The number of different coatings, as applied, each day;

Vi = The volume of each coating applied in units of L (gal), each day; and

Ci = The VOC content of each coating, as applied, in units of kg VOC/L of coating (lb VOC/gal) ;

a = Constant = 100 m2 if using metric units; and

=1,000 ft2 if using english units.

(b) Calculate the required overall emission reduction efficiency of the control system for the day according to the following equation:

Click to view Image

where:

E = The required overall emission reduction efficiency of the control system;

VOCa= The maximum VOC content of the coatings, as applied, used each day in a units of kg VOC/100 m2 of surface area coated (lb VOC/1,000 ft2 ), as determined by the applicable test methods and procedures; or the weighted average VOC content, as applied, of the coatings used each day in units of kg VOC/100 m2 of surface area coated (lb VOC/1,000 ft2 ); and

S = VOC emission limitation in terms of kg VOC/100 m of surface area coated (lb VOC/1,000 ft2 ).

(7) Recordkeeping and reporting requirements of this chapter and as follow apply:
(a)

(Reserved)

(b) An owner or operator of a flat wood paneling coating line subject to this rule and complying with Paragraph (3) of this rule by means of the use of complying coatings shall comply with the following:
1. By April 22, 1994, or upon startup of a new coating line, or upon changing the method of compliance for a subject line from daily-weighted averaging or control devices to the use of complying coatings, the owner or operator shall certify to the Technical Secretary that the coating line is in compliance. Such certification shall include:
(i) The name and location of the facility;
(ii) The address and telephone number of the person responsible for the facility;
(iii) Identification of subject sources;
(iv) The name and identification number of each coating, as applied; and
(v) The mass of VOC per area of surface to which the coating is applied in 22 terms of kg VOC/100 m (lb VOC/1,000 ft ) and the surface area coated.
2. On and after April 22, 1994, or on and after the initial startup date, the owner or operator shall collect and record the following information each day and maintain the information for a period of 3 years:
(i) The name and identification number of each coating, as applied; and
(ii) The mass of VOC per area of surface to which the coating is applied for each coating used each day in terms of kg VOC/100 m2 (lb VOC/1, 000 ft2 ).
3. On and after April 22, 1994, the owner or operator shall notify the Technical Secretary in the following instances:
(i) Any record showing use of any non-complying coatings shall be reported by sending a copy of such record to the Technical Secretary within 30 calendar days following that use, and
(ii) At least 30 calendar days before changing the method of compliance from the use of complying coatings to daily-weighted averaging or control devices, the owner or operator shall comply with all requirements of Part (c)1 or (d)1 of this paragraph, respectively.
(c) An owner or operator of a flat wood paneling coating line subject to this rule and complying with Paragraph (3) of this rule by means of weighted averaging on that line shall comply with the following:
1. By April 22, 1994, or upon startup of a new flat wood paneling coating line, or upon changing the method of compliance for a flat wood paneling coating line from the use of complying coatings or control devices to daily-weighted averaging, the owner or operator shall certify to the Technical Secretary that the coating line is in compliance with this subparagraph. Such certification shall include:
(i) The name and location of the facility.
(ii) The address and telephone number of the person responsible for the facility.
(iii) Identification of subject sources.
(iv) The name and identification number of each coating line which will comply by means of weighted averaging;
(v) The instrument or method by which the owner or operator will accurately measure or calculate the volume of each coating (excluding water and/or exempt compounds), as applied, used each day on each coating line;
(vi) The method by which the owner or operator will create and maintain records as required in Part 2 of this subparagraph, with an example of the format in which the records will be kept; and
(vii) Calculation of the weighted average, using the procedure in Subparagraph (6)(a) of this rule, for a day representative of current or projected maximum production levels.
2. On and after April 22, 1994, or on and after the initial startup date, the owner or operator shall collect and record all of the following information each day for each subject coating line and maintain the information for a period of 3 years:
(i) The name and identification number of each coating, as applied;
(ii) The mass of VOC per volume (excluding water and/or exempt compounds) and the volume of each coating (excluding water and/or exempt compounds), as applied, used each day; and
(iii) The weighted average VOC content of all coatings, as applied, calculated according to the procedure in Subparagraph (6)(a) of this rule.
3. On and after April 22, 1994, the owner or operator shall notify the Technical Secretary in the following instances:
(i) Any record showing noncompliance with the applicable daily-weighted average requirements shall be reported by sending a copy of the record to the Technical Secretary within 30 calendar days following the occurrence.
(ii) At least 30 calendar days before changing the method of compliance from daily-weighted averaging to the use of complying coatings or control devices, the owner or operator shall comply with all requirements of Part (b)1 or (d)1 of this paragraph, respectively.
(d) Any owner or operator of a flat wood paneling coating line subject to this rule and complying with Paragraph (3) of this rule by the use of control devices shall comply with the following:
1. By April 22, 1994, 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 or weighted averaging to control devices, the owner or operator of the subject coating line shall perform or shall have performed, as applicable, a compliance test. Testing shall be pursuant to the procedures in this chapter and Paragraph (6) of this rule. No later than 60 days after the completion of the performance testing, the owner or operator of the subject coating line shall submit to the Technical Secretary the results of all tests and calculations necessary to demonstrate that the subject coating line is in compliance.
2. On and after April 22, 1994, or on and after the initial startup date, the owner or operator shall collect and record all of the following information each day for each coating line and maintain the information for a period of 3 years:
(i) The name and identification number of each coating used;
(ii) The mass of VOC per area of surface to which the coating is applied in terms of kg VOC/100 m2 (lb VOC/1,000 ft2 ), and the surface area coated;
(iii) The maximum VOC content (mass of VOC per area of surface to which the coating is applied in terms of kg VOC/100 m2 [lb VOC/1,000 ft2 ] or the weighted average VOC content (mass of VOC per area of surface to which the coating is applied in terms of kg VOC/100 m2 [lb VOC/1,000 ft2 ]) of the coatings used;
(iv) The required overall emission reduction efficiency as determined in Subparagraph (6)(b) of this rule;
(v) The actual overall emission reduction efficiency achieved as determined in this chapter;
(vi) Control device monitoring data;
(vii) A log of operating time for the capture system, control device, monitoring equipment, and the associated coating line;
(viii) 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;
(ix) For thermal incinerators, all 3-hour periods of operation in which the average combustion temperature was more than 28°C (50°F) below the average combustion temperature during the most recent performance test that demonstrated that the facility was in compliance;
(x) For catalytic incinerators:
(I) Continuous records of the temperature of the gas stream both upstream and downstream of the incinerator;
(II) Records of all 3-hour periods of operation for which the average temperature measured befoe the catalyst bed is more than 28°C (50°F) below the gas stream temperature measured before the catalyst bed during the most recent determination of destruction efficiency of the catalytic incinerator that demonstrated that the facility was in compliance; and
(III) Records of all 3-hour periods for which the average temperature across the catalyst bed is less than 80 percent of the temperature difference measured during the most recent determination of the destruction efficiency of the catalytic incinerator that demonstrated that the facility was in compliance.
(xi) For carbon adsorbers, all 3-hour periods of operation during which the average VOC concentration or reading of organics in the exhaust gases is more than 20 percent 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. This specification applies only to carbon adsorbers for which stack emission testing was required to demonstrate compliance with a standard of this chapter.
3. On and after April 22, 1994, the owner or operator shall notify the Technical Secretary of any instance of noncompliance with the applicable requirements for control devices, such instance of noncompliance including any period of operation during which the parameter boundaries established during the most recent performance test are exceeded as specified in Subparts 2(ix), (x), and (xi) of this subparagraph, by sending a copy of that notice to the Technical Secretary within 30 calendar days following the occurrence.

Notes

Tenn. Comp. R. & Regs. 1200-03-18-.21
Original rule filed May 15, 1992; effective July 10, 1979. Amendment filed March 23, 1981; effective May 7, 1981. Amendment filed January 19, 1983; effective February 18, 1983. Amendment filed September 26, 1986; effective November 10, 1986. Amendment filed September 21, 1988; effective November 6, 1988. Amendment filed September 22, 1989; effective November 11, 1989. Amendment filed April 23, 1992; effective June 7, 1992. Repeal and new rule filed March 8, 1993; effective April 22, 1993. Amendment filed July 27, 1995; effective October 9, 1995.

Authority: T.C.A. §§ 4-5-202 and 68-201-105.

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