Tenn. Comp. R. & Regs. 1200-03-18-.42 - WOOD FURNITURE FINISHING AND CLEANING OPERATION

(1) Applicability of this Rule is as follows:

This Rule applies to any wood furniture coating line within a facility located in Davidson, Rutherford, Shelby, Sumner, Williamson or Wilson County whose maximum potential emissions from all wood furniture coating lines within the facility are 100 tons or more of volatile organic compounds (VOC's) per year.

(2) For the purpose of this Rule, the following definitions apply:
(a) "Adhesive" means any chemical substance that is applied for the purpose of bonding two surfaces together other than by mechanical means.
(b) "Administrator" means the Administrator of the United States Environmental Protection Agency or his or her authorized representative.
(c) "Affected Source" means a wood furniture manufacturing facility that meets the criteria listed in Subparagraph (1).
(d) "Alternative method" means any method of sampling and analyzing for an air pollutant that is not a reference or equivalent method but that has been demonstrated to the Technical Secretary and the Administrator's satisfaction to, in specific cases, produce results adequate for a determination of compliance.
(e) "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.
(f) "Baseline conditions" means the conditions that exist prior to an affected source implementing controls, such as a control system.
(g) "Cleaning operations" means operations in which organic solvent is used to remove coating materials from equipment used in the coating operation.
(h) "Coating Solids (or solids)" mean the part of the coating that remains after the coating is dried or cured.
(i) "Continuous coater" means a finishing system that continuously applies finishing materials onto furniture parts moving along a conveyor system. Finishing materials that are not transferred to the part are recycled to the finishing material reservoir. Several types of application methods can be used with a continuous coater including spraying, curtain coating, roll coating, dip coating, and flow coating.
(j) "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.
(k) "Conventional air spray" means a spray coating method in which the coating is atomized by mixing it with compressed air at an air pressure greater than 10 pounds per square inch (gauge) at the point of atomization. Airless and air assisted airless spray technology are not conventional air spray because the coating is not atomized by mixing it with compressed air.
(l) "Disposed offsite" means sending used organic solvent or finishing material outside of the facility for disposal.
(m) "Enamel" means the coat of colored material, usually opaque, that is applied as a protective topcoat over a basecoat, primer, or a previously applied enamel coat. In some cases, another finishing material may be applied as a topcoat over enamel.
(n) "Equivalent method" means any method of sampling and analyzing for an air pollutant that has been demonstrated to the Technical Secretary and the Administrator's satisfaction to have a consistent and quantitatively known relationship to the reference method under specific conditions.
(o) "Final touch-up and repair" means the application of finishing materials after completion of the finishing operation to cover minor imperfections.
(p) "Finishing application station" means the part of a finishing operation where the finishing material is applied, e.g., a spray booth.
(q) "Finishing material" means a coating other than an adhesive. For the wood furniture manufacturing industry, such materials include, but are not limited to, basecoats, stains, washcoats, sealers, topcoats, and enamels.
(r) "Finishing operation" means those activities in which a finishing material is applied to a substrate and is subsequently air-dried, cured in an oven, or cured by radiation.
(s) "Incinerator" means, for the purposes of this industry, an enclosed combustion device that thermally oxidizes volatile organic compounds to CO and CO2. This term does not include devices that burn municipal or hazardous waste material.
(t) "Material safety data sheet (MSDS)" means the documentation required by the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard for a solvent, cleaning material, finishing material, or other material that identifies select reportable hazardous ingredients of the material, safety and health considerations, and handling procedures.
(u) "Normally closed container" means a container that is closed unless an operator is actively engaged in activities such as emptying or filling the container.
(v) "Operating parameter value" means a minimum or maximum value established for a control device or process parameter that, if achieved by itself or in combination with one or more other operating parameter values, determines that an owner or operator has complied with an applicable emission limit.
(w) "Organic solvent" means a liquid containing volatile organic compounds that is used for dissolving or dispersing constituents in a coating, adjusting the viscosity of a coating, or cleaning equipment. When used in a coating the organic solvent evaporates during drying and does not become a part of the dried film.
(x) "Permanent total enclosure" means a permanently installed enclosure that completely surrounds a source of emissions such that all emissions are captured and contained for discharge through a control device.
(y) "Recycled onsite" means the reuse of an organic solvent in a process other than cleaning or washoff.
(z) "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.
(aa) "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. This includes, but is not limited to, nongrain raising stains, equalizer stains, sap stains, body stains, no-wipe stains, penetrating stains, and toners.
(bb) "Storage containers" means vessels or tanks, including mix equipment, used to hold finishing or cleaning materials.
(cc) "Strippable booth coating" means a coating that:
1. Is applied to a booth wall to provide a protective film to receive overspray during finishing operations;
2. That is subsequently peeled off and disposed of; and;
3. By achieving 1. and 2., reduces or eliminates the need to use organic solvents to clean booth walls.
(dd) "Temporary total enclosure" means an enclosure that meets the requirements of (7)(e)1.(i) through (iv) and is not permanent, but constructed only to measure the capture efficiency of the capture system of a given source. In addition to meeting the requirements of (7)(e)1.(i) through (iv), any exhaust point from the enclosure shall be at least 4 equivalent duct or hood diameters from each natural draft opening.
(ee) "Topcoat" means the last film-building finishing material applied in a finishing system.
(ff) "Washcoat" means a transparent special purpose coating having a solids content by weight of 12.0 percent or less. Washcoats are applied over initial stains to protect and control color and to stiffen the wood fibers in order to aid sanding.
(gg) "Washoff" operations means those operations in which organic solvent is used to remove coating from a substrate.
(hh) "Waterborne" coating means a coating that contains more than five percent water by weight in its volatile fraction.
(ii) "Wood furniture" facility means all of the pollutant-emitting activities that belong to the same wood furniture industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control of the same person (or persons under common control). The wood furniture industrial grouping includes the following SIC codes: 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, and 2599.
(jj) "Wood furniture manufacturing operations" means the finishing and cleaning operations conducted at a wood furniture facility.
(kk) "Working day" means a day, or any part of a day, in which a facility is engaged in manufacturing.
(3) The nomenclature used in this Rule has the following meaning:
(a) Ak = the area of each natural draft opening (k) in a total enclosure, in square meters.
(b) C = the VOC content of a coating (c), in kilograms of VOC per kilogram of coating solids (kg VOC/kg solids), as applied. Also given in pounds of VOC per pound of coating solids (lb VOC/lb solids), as applied.
(c) Caj = the concentration of VOC in gas stream (j) exiting the emission control device, in parts per million by volume.
(d) Cbi = the concentration of VOC in gas stream (i) entering the emission control device, in parts per million by volume.
(e) Cdi = the concentration of VOC in gas stream (i) entering the emission control device from the affected emission point(s), in parts per million by volume.
(f) Cfk = the concentration of VOC in each uncontrolled gas stream (k) emitted directly to the atmosphere from the affected emission point(s), in parts per million by volume.
(g) E = the emission limit to be achieved by the affected emission point(s), in kg VOC/kg solids.
(h) F = the control device efficiency, expressed as a fraction.
(i) FV = the average inward face velocity across all natural draft openings in a total enclosure, in meters per hour.
(j) N = the capture efficiency, expressed as a fraction.
(k) Qaj = the volumetric flow rate of gas stream (j) exiting the emission control device, in dry standard cubic meters per hour.
(l) Qbi = the volumetric flow rate of gas stream (i) entering the emission control device, in dry standard cubic meters per hour.
(m) Qdi = the volumetric flow rate of gas stream (i) entering the emission control device from the affected emission point(s), in dry standard cubic meters per hour.
(n) Qfk = the volumetric flow rate of each uncontrolled gas stream (k) emitted directly to the atmosphere from the affected emission point(s), in dry standard cubic meters per hour.
(o) Qin i = 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).
(p) Qout j = 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).
(q) R = the overall efficiency of the control system, expressed as a percentage.
(4) Emission Standards
(a) Each owner or operator of an affected source subject to this Rule shall limit VOC emissions from finishing operations by:
1. Using topcoats with a VOC content no greater than 0.8 kg VOC/kg solids (0.8 lb VOC/lb solids), as applied; or
2. Using a finishing system of sealers with a VOC content no greater than 1.9 kg VOC/kg solids (1.9 lb VOC/lb solids), as applied and topcoats with a VOC content no greater than 1.8 kg VOC/kg solids (1.8 lb VOC/lb solids), as applied; or
3. For affected sources using acid-cured alkyd amino vinyl sealers or acid-cured alkyd amino conversion varnish topcoats, using sealers and topcoats based on the following criteria:
(i) If the affected source is using acid-cured alkyd amino vinyl sealers and acid-cured alkyd amino conversion varnish topcoats, the sealer shall contain no more than 2.3 kg VOC/kg solids (2.3 lb VOC/lb solids), as applied, and the topcoat shall contain no more than 2.0 kg VOC/kg solids (2.0 lb VOC/lb solids), as applied; or
(ii) If the affected source is using a sealer other than an acid-cured alkyd amino vinyl sealer and acid-cured alkyd amino conversion varnish topcoats, the sealer shall contain no more than 1.9 kg VOC/kg solids (1.9 lb VOC/lb solids), as applied, and the topcoat shall contain no more than 2.0 kg VOC/kg solids (2.0 lb VOC/lb solids), as applied; or
(iii) If the affected source is using an acid-cured alkyd amino vinyl sealer and a topcoat other than an acid-cured alkyd amino conversion varnish topcoat, the sealer shall contain no more than 2.3 kg VOC/kg solids (2.3 lb VOC/lb solids), as applied, and the topcoat shall contain no more than 1.8 kg VOC/kg solids (1.8 lb VOC/lb solids), as applied; or
4. Meeting the provisions established in Paragraph (10) for sources using an averaging approach and demonstrating that actual emissions from the affected source are less than or equal to allowable emissions using one of the following equations:

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where:

N = number of finishing materials participating in averaging; TCi = kilograms of solids of topcoat "i" used;

SEi = kilograms of solids of sealer "i" used;

WCi = kilograms of solids of washcoat "i" used;

BCi = kilograms of solids of basecoat "i" used;

STi = liters of stain "i" used;

ERTCi = VOC content of topcoat "i" in kg VOC/kg solids, as applied;

ERSEi = VOC content of sealer "i" in kg VOC/kg solids, as applied;

ERWCi = VOC content of washcoat "i" in kg VOC/kg solids, as applied;

ERBCi = VOC content of basecoat "i" in kg VOC/kg solids, as applied; and

ERSTi = VOC content of stain "i" in kg VOC/liter (kg/l),as applied.

5. Using a control system that will achieve an equivalent reduction in emissions as the requirements of Part (a)1. or 2. of this Paragraph, as calculated using the compliance provisions in Part (6)(a)2. of this Rule, as appropriate; or
6. Using a combination of the methods presented in Parts (4)(a)1., 2., 3., 4., and 5. of this Rule.
(b) Each owner or operator of an affected source subject to this Rule shall limit VOC emissions from cleaning operations when using a strippable booth coating. A strippable booth coating shall contain no more than 0.8 kg VOC/kg solids, as applied (0.8 lb VOC/lb solids).
(5) Work Practice Standards
(a) Work practice implementation plan.
1. Each owner or operator of an affected source subject to this Rule shall prepare and maintain a written work practice implementation plan that defines environmentally desirable work practices for each wood furniture manufacturing operation and addresses each of the topics specified in Subparagraphs (b) through (j) of this paragraph. The plan shall be developed no more than 60 days after the compliance date. The written work practice implementation plan shall be available for inspection by the Technical Secretary, upon request. If the Technical Secretary determines that the work practice implementation plan does not adequately address each of the topics specified in Subparagraphs (b) through (j) of this Paragraph, the Technical Secretary shall require the affected source to modify the plan.
(b) Operator training course.

Each owner or operator of an affected source shall train all new and existing personnel, including contract personnel, who are involved in finishing or cleaning operations or implementation of the requirements of this Rule. All personnel shall be given refresher training annually. The affected source shall maintain a copy of the training program with the work practice implementation plan. The training program shall include, at a minimum, the following:

1. A list of all personnel by name and job description that are required to be trained;
2. An outline of the subjects to be covered in the initial and refresher training for each person, 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, appropriate application techniques, appropriate cleaning procedures, appropriate equipment setup and adjustment to minimize finishing material usage and overspray, and appropriate management of cleanup wastes; and
4. A description of the methods to be used at the completion of initial or refresher training to demonstrate and document successful completion.
(c) Leak inspection and maintenance plan.

Each owner or operator of an affected source shall prepare and maintain with the work practice implementation plan a written leak inspection and maintenance plan that specifies:

1. A minimum visual inspection frequency of once per month for all equipment used to transfer or apply finishing materials or organic solvents;
2. An inspection schedule;
3. Methods for documenting the date and results of each inspection and any repairs that were made;
4. The time frame between identifying a leak and making the repair, which adheres to the following schedule:
(i) A first attempt at repair (e.g., tightening of packing glands) shall be made no later than 5 working days after the leak is detected; and
(ii) Final repairs shall be made within 15 working days, unless the leaking equipment is to be replaced by a new purchase, in which case repairs shall be completed within 3 months.
(d) Cleaning solvent accounting system.

Each owner or operator of an affected source shall develop an organic solvent accounting form to record:

1. The quantity and type of organic solvent used each month for washoff and cleaning;
2. The number of pieces washed off, and the reason for the washoff; and
3. The quantity of spent organic solvent generated from each activity, and the quantity that is recycled onsite or disposed offsite each month.
(e) Each owner or operator of an affected source shall not use organic solvents containing more than 8.0 percent by weight of VOC for cleaning spray booth components other than conveyors, continuous coaters and their enclosures, and/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 affected source shall use no more than 1.0 gallon of organic solvent to clean the booth.
(f) Each owner or operator of an affected source shall use normally closed containers for storing finishing and cleaning materials.
(g) Each owner or operator of an affected source shall not use conventional air spray guns for applying finishing materials except under the following circumstances:
1. To apply finishing materials that have a VOC content no greater than 1.0 kg VOC/kg solids (1.0 lb VOC/lb solids), as applied;
2. For final touch-up and repair;
3. If spray is automated, that is, the spray gun is aimed and triggered automatically, not manually;
4. If emissions 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 less than 5 percent of the total gallons of finishing material used during that semiannual reporting period; or
6. The conventional air gun is used to apply coating 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 Technical Secretary 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 infeasibility:
(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.
(h) Each owner or operator of an affected source shall pump or drain all organic solvent used for line cleaning into a normally closed container.
(i) Each owner or operator of an affected source shall collect all organic solvent used to clean spray guns into a normally closed container.
(j) 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 organic solvent as possible.
(6) Compliance Procedures and Monitoring Requirements
(a) The owner or operator of an affected source subject to the emission standards in Paragraph (4) of this Rule shall demonstrate compliance with those provisions and with the initial compliance certification requirements of Paragraph .03(1) of this chapter, except that the date for submittal of the initial compliance certification for each existing source as of August 15, 1995 is November 15, 1996, and for each new sources (after August 15, 1995) is within 180 days after the start-up of that source; and by using any of the following methods:
1. To support that each sealer, topcoat, and strippable booth coating meets the requirements of Parts (4)(a)1., 2., or 3. or Subparagraph (4)(b) of this Rule, maintain documentation in accordance with Rule .81 of this chapter, or data from an alternative or equivalent method, to determine the VOC and solids content of the as supplied finishing material. If solvent or other VOC is added to the finishing material before application, the affected source shall maintain documentation showing the VOC content of the finishing material as applied, in kg VOC/kg solids.
2. To comply through the use of a control system as discussed in (4)(a)5.:
(i) Determine the overall control efficiency needed to demonstrate compliance using Equation 3;

R = ((C - E)/C)(100) (3)

(ii) Document that the value of C in Equation 3 is obtained from the VOC and solids content of the as-applied finishing material;
(iii) Calculate the overall efficiency of the control device, using the procedures in Subparagraphs (7)(d) or (e), and demonstrate that the value of R calculated by Equation 6 is equal to or greater than the value of R calculated by Equation 3.
(b) Initial compliance.
1. Owners or operators of an affected source subject to the provisions of Parts (4)(a)1., 2., or 3. or Subparagraph (4)(b) that are complying through the procedures established in Part (6)(a)1. shall submit an initial compliance status report, as required by Subparagraph (9)(b), stating that compliant sealers and/or topcoats and strippable booth coatings are being used by the affected source.
2. Owners or operators of an affected source subject to the provisions of Parts (4)(a)1., 2., or 3. that are complying through the procedures established in Part (6)(a)1. and are applying sealers and/or topcoats using continuous coaters shall demonstrate initial compliance by:
(i) Submitting an initial compliance status report stating that compliant sealers and/or topcoats, as determined by the VOC content of the finishing material in the reservoir and the VOC content as calculated from records, are being used; or
(ii) Submitting an initial compliance status report stating that compliant sealers and/or topcoats, as determined by the VOC content of the finishing material in the reservoir, are being used and the viscosity of the finishing material in the reservoir is being monitored. The affected source shall also provide data that demonstrates the correlation between the viscosity of the finishing material and the VOC content of the finishing material in the reservoir.
3. Owners or operators of an affected source using a control system (capture device/control device) to comply with the requirements of this Rule, as allowed by Parts (4)(a)5. and (6)(a)2. shall demonstrate initial compliance by:
(i) Submitting a monitoring plan that identifies the operating parameter to be monitored for the capture device and discusses why the parameter is appropriate for demonstrating ongoing compliance;
(ii) Conducting an initial performance test using the procedures and test methods listed in Subparagraphs (7)(c) and (d) or (e);
(iii) Calculating the overall control efficiency (R) using Equation 6; and
(iv) Determining those operating conditions critical to determining compliance and establishing operating parameters that will ensure compliance with the standard.
(I) For compliance with a thermal incinerator, minimum combustion temperature shall be the operating parameter.
(II) For compliance with a catalytic incinerator equipped with a fixed catalyst bed, the minimum gas temperature both upstream and downstream of the catalyst bed shall be the operating parameter.
(III) For compliance with a catalytic incinerator equipped with a fluidized catalyst bed, the minimum gas temperature upstream of the catalyst bed and the pressure drop across the catalyst bed shall be the operating parameters.
(IV) For compliance with a carbon adsorber, the operating parameters 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 Technical Secretary and the Administrator to establish other operating parameters.
(V) For compliance with a control device not listed in this section, the operating parameter shall be established using the procedures identified in Sub-part (6)(c)3.(vi).
(v) Owners or operators complying with Part (b)3. of this Paragraph shall calculate the 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 test runs required by Rule .84 of this chapter
4. Owners or operators of an affected source subject to the work practice standards in Paragraph (5) shall submit an initial compliance status report, as required by (9)(b), stating that the work practice implementation plan has been developed and procedures have been established for implementing the provisions of the plan.
(c) Continuous compliance demonstrations.
1. Owners or operators of an affected source subject to the provisions of paragraph (4) that are complying through the procedures established in Part (6)(a)(1) shall demonstrate continuous compliance by using compliant materials, maintaining records that demonstrate the finishing materials are compliant materials.
(i) The compliance certification shall state that compliant sealers and/or topcoats and strippable booth coatings have been used each day, or should otherwise identify the days of noncompliance and the reasons for noncompliance. An affected source is in violation of the standard whenever a noncompliant material, as determined by records or by a sample of the finishing material, is used. Use of a noncompliant material is a separate violation for each day the noncompliant material is used.
(ii) The compliance certification shall be signed by a responsible official of the company that owns or operates the affected source.
2. Owners or operators of an affected source subject to the provisions of Paragraph (4) that are complying through the procedures established in Part (6)(a)(1) and are applying sealers and/or topcoats using continuous coaters shall demonstrate continuous compliance by following the procedures in (i) or (ii) of this Part.
(i) Using compliant materials, as determined by the VOC content of the finishing material in the reservoir and the VOC content as calculated from records.
(I) The compliance certification shall state that compliant sealers and/or topcoats have been used each day, or should otherwise identify the days of noncompliance and the reasons for noncompliance. An affected source is in violation of the standard whenever a noncompliant material, as determined by records or by a sample of the finishing material, is used. Use of a noncompliant material is a separate violation for each day the noncompliant material is used.
(II) The compliance certification shall be signed by a responsible official of the company that owns or operates the affected source.
(ii) Using compliant materials, as determined by the VOC content of the finishing material in the reservoir, maintaining a viscosity of the finishing material in the reservoir that is no less than the viscosity of the initial finishing material by monitoring the viscosity with a viscosity meter or by testing the viscosity of the initial finishing material and retesting the material in the reservoir each time solvent is added, and maintaining records of solvent additions.
(I) The compliance certification shall state that compliant sealers and/or topcoats, as determined by the VOC content of the finishing material in the reservoir, have been used each day. Additionally, the certification shall state that the viscosity of the finishing material in the reservoir has not been less than the viscosity of the initial finishing material, that is, the material that is initially mixed and placed in the reservoir.
(II) The compliance certification shall be signed by a responsible official of the company that owns or operates the affected source.
(III) An affected source is in violation of the standard when a sample of the as-applied finishing material exceeds the applicable limit established in 4(a)(1), (2), or (3), as determined according to and as provided for in Rule .81 of this chapter, or an alternative or equivalent method, or the viscosity of the finishing material in the reservoir is less than the viscosity of the initial finishing material.
3. Owners or operators of an affected source subject to the provisions of Paragraph (4) that are complying through the use of a control system (capture/ control device) shall demonstrate continuous compliance by installing, calibrating, maintaining, and operating the appropriate monitoring equipment according to manufacturers specifications.
(i) Where a capture/control device is used, a device to monitor the site-specific operating parameter established in accordance with 6(b)3.(iv) is required.
(ii) Where an incinerator is used, a temperature monitoring device equipped with a continuous recorder is required.
(I) Where a thermal incinerator 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.
(II) 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.
(III) 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:
(I) An integrating regeneration 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 expressed in degrees Celsius or ±0.5°C, whichever is greater, capable of recording the carbon bed temperature after each regeneration and within 15 minutes of completing any cooling cycle;
(II) An organic monitoring device, equipped with a continuous recorder, to indicate the concentration level of organic compounds exiting the carbon adsorber; or
(III) Any other monitoring device that has been approved by the Technical Secretary and the Administrator as allowed under (6)(c)3.(iv).
(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 value. 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 use of a catalytic incinerator equipped with a fixed catalyst bed shall maintain a constant pressure drop, measured monthly, across the catalyst bed.
(vi) An owner or operator using a control device not listed in this Paragraph shall submit to the Technical Secretary and the Administrator 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 both the Technical Secretary and the Administrator's approval.
4. Owners or operators of an affected source subject to the work practice standards in Paragraph (5) shall demonstrate continuous compliance by following the work practice implementation plan and submitting a compliance certification required by Rule .03 of this chapter.
(i) The compliance certification shall state that the work practice implementation plan is being followed, or should otherwise identify the periods of noncompliance with the work practice standards. Each failure to implement an obligation under the plan during any particular day is a separate violation.
(ii) The compliance certification shall be signed by a responsible official of the company that owns or operates the affected source.
5. The owner or operator of an existing source or of a source having a state or local agency's construction permit before August 15, 1995 (instead of April 22,1993) and subject to this Rule may petition for a source-specific compliance schedule according to and as provided for in Rule .07 of this chapter. The petition for the source-specific compliance schedule must be received by Technical Secretary by February 11, 1996 (instead of October 22, 1993).
(7) Performance Test Methods
(a) The VOC content and the solids content by weight of the as supplied finishing materials shall be determined according to and as provided for in Rule .81 of this chapter. The owner or operator of the affected source may request approval from the Technical Secretary and the Administrator to use an alternative or equivalent method for determining the VOC content of the finishing material. If it is demonstrated to the satisfaction of the Technical Secretary and the Administrator that a finishing material does not release VOC byproducts during the cure, for example, all VOC is organic solvent, then batch formulation information shall be accepted. In the event of any inconsistency between the procedures described in Rule .81 of this chapter and a facility's formulation data, that is, if the procedures described in Rule .81 of this chapter result in higher values, these procedures (Rule .81) shall govern.
(b) Owners or operators demonstrating compliance with the provisions of this Rule via a control system shall determine the overall control efficiency of the control system (R) as the product of the capture and control device efficiencies, using the test methods cited in Subparagraph (7)(c) and the procedures in Subparagraphs (7)(d) or (e).
(c) Owners or operators using a control system shall demonstrate initial compliance using the procedures in Rule .84 of this chapter.
(d) Owners or operators using a control system to demonstrate compliance with this Rule shall use the following procedures:
1. Construct the overall VOC control system so that volumetric flow rates and VOC concentrations can be determined by the test methods specified in Rule .84 of this chapter;
2. Measure the capture efficiency from the affected emission point(s) by capturing, venting, and measuring all VOC emissions from the affected emission point(s). To measure the capture efficiency of a capture device located in an area with non-affected VOC emission point(s), the affected emission point(s) shall be isolated from all other VOC sources by one of the following methods:
(i) Build a temporary total enclosure (see Subparagraph (2)(dd) of this Rule) around the affected emission point(s);
(ii) Shut down all non-affected VOC emission point(s) and continue to exhaust fugitive emissions from the affected emission point(s) through any building ventilation system and other room exhausts such as drying ovens. All exhaust air must be vented through stacks suitable for testing; or
(iii) Use another methodology approved by the Technical Secretary and the Administrator provided that it is constructed and operated in accordance with the guidelines of the latest edition of the Industrial Ventilation Manual , of the American Conference of Governmental Industrial Hygienists.
3. Operate the control system with all affected emission point(s) connected and operating at maximum production rate;
4. Determine the efficiency (F) of the control device using Equation 4; and

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5. Determine the efficiency (N) of the capture system using Equation 5;

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6. Compliance is demonstrated if the value of (R) in Equation 6 is greater than or equal to the value of R calculated by Equation 3 in accordance with Subpart (6)(a)2.(i).

R = (F x N)(100) (6)

(e) An alternative to the compliance method presented in Subparagraph (7)(d) is the installation of a permanent total enclosure. A permanent total enclosure presents prima facia evidence that all VOC emissions from the affected emission point(s) are directed to the control device. Each affected source that complies using a permanent total enclosure shall:
1. Demonstrate that the total enclosure meets the following requirements:
(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;
(ii) All sources of emissions within the enclosure shall be a minimum of four equivalent diameters away from each natural draft opening;
(iii) 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:
(I) 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 and procedures specified in Rule .83 of this chapter. Volumetric flow rates shall be calculated without the adjustment normally made for moisture content; and
(II) Determine FV by the following equation:

Click to view Image

(iv) All access doors and windows whose areas are not included as natural draft openings and are not included in the calculation of FV shall be closed during routine operation of the process.
2. Determine the control device efficiency using Equation 4, and the test methods and procedures specified in Subparagraph (7)(c).
3. If the permanent enclosure is demonstrated to be total, the value of N in Equation 5 is equal to 1.
4. For owners or operators using a control system to comply with the provisions of this Rule, compliance is demonstrated if:
(i) The installation of a permanent total enclosure is demonstrated (N=1); and
(ii) The value of (R) calculated by Equation 6 in accordance with paragraph (7)(d) is greater than or equal to the value of R calculated by Equation 3 in accordance with Part (6)(a)2.
(8) Recordkeeping Requirements
(a) The owner or operator of an affected source subject to the emission limits in Paragraph (4) of this Rule shall maintain records of the following:
1. A list of each finishing material and strippable booth coating subject to the emission limits in Paragraph (4);
2. The VOC and solids content, as applied, of each finishing material and strippable booth coating subject to the emission limits in Paragraph (4), and copies of data sheets documenting how the as applied values were determined.
(b) The owner or operator of an affected source following the compliance procedures of paragraph (6)(c)2. shall maintain the records required by paragraph (8)(a) and records of the following:
1. Solvent and finishing material additions to the continuous coater reservoir; and
2. Viscosity measurements.
(c) The owner or operator of an affected source following the compliance method of paragraph (6)(a)2. shall maintain the following records:
1. Copies of the calculations to support the equivalency of using a control system, as well as the data that are necessary to support the calculation of E in Equation 3 and the calculation of R in Equation 6;
2. Records of the daily average value of each continuously monitored parameter for each operating day. If all recorded values for a monitored parameter are within the range established during the initial performance test, the owner or operator may record that all values were within the range rather than calculating and recording an average for that day; and
3. Records of the pressure drop across the catalyst bed for facilities complying with the emission limitations using a catalytic incinerator with a fluidized catalyst bed.
(d) The owner or operator of an affected source subject to the work practice standards in Paragraph (5) of this Rule shall maintain onsite the work practice implementation plan and all records associated with fulfilling the requirements of that plan, including, but not limited to:
1. Records demonstrating that the operator training program is in place;
2. Records maintained in accordance with the inspection and maintenance plan;
3. Records associated with the cleaning solvent accounting system;
4. Records associated with the limitation on the use of conventional air spray guns showing total finishing material usage and the percentage of finishing materials applied with conventional air spray guns; and;
5. Records showing the VOC content of solvent used for cleaning booth components, except for solvent used to clean conveyors, continuous coaters and their enclosures, and/or metal filters; and
6. Copies of logs and other documentation developed to demonstrate that the other provisions of the work practice implementation plan are followed.
(e) The owner or operator of an affected source shall maintain a copy of all other information submitted with the initial status report required by Subparagraph (9)(b).
(f) The owner or operator of an affected source shall maintain all records for a minimum of 5 years.
(g) Failure to maintain the records required by (a) through (f) of this Paragraph shall constitute a violation of the Rule for each day records are not maintained.
(9) Reporting Requirements
(a) The owner or operator of an affected source using a control system to fulfill the requirements of this Rule are subject to the following reporting requirements:
1. The owner or operator of an affected source subject to this Rule shall submit an initial compliance report by the compliance date. The report shall include the items required by Subparagraph (6)(b) of this Rule.
2. The owner or operator of an affected source subject to this Rule and demonstrating compliance in accordance with Parts (6)(a)1. or 2. shall comply with Rule .03 of this chapter, except that the date for compliance for an existing source as of August 15, 1995 is November 15, 1996, and for each new source (after August 15, 1995) is within 180 days after the start-up of that source.
(10) Special Provisions for Sources Using an Averaging Approach

The owner or operator of an affected source complying with the emission limitations established in Paragraph (4) through the procedures established in (4)(a)4. shall also meet the provisions established in (a) through (i) of this Paragraph.

(a) Program goals and rationale. The owner or operator of the affected source shall provide a summary of the reasons why the affected source would like to comply with the emission limitations through the procedures established in (4)(a)4. and a summary of how averaging can be used to meet the emission limitations. The affected source shall also document that the additional environmental benefit requirement is being met through the use of the equations in (4)(a)4. These equations ensure that the affected source is achieving an additional 10 percent reduction in emissions when compared to affected sources using a compliant coatings approach to meet the requirements of the Rule.
(b) Program scope. The owner or operator of the affected source shall describe the types of finishing materials that will be included in the affected source's averaging program. Stains, basecoats, washcoats, sealers, and topcoats may all be used in the averaging program. Finishing materials that are applied using continuous coaters may only be used in an averaging program if the affected source can determine the amount of finishing material used each day.
(c) Program baseline. The baseline for each finishing material included in the averaging program shall be the lower of the actual or allowable emission rate as of the effective date of this rule, August 15, 1995. In no case shall the facility baseline emission rate be higher than what was presumed in the 1990 emissions inventory for the facility unless the State has accounted for the increase in emissions as growth.
(d) Quantification procedures. The owner or operator of the affected source shall describe how emissions and changes in emissions will be quantified, including methods for quantifying usage of each finishing material. Quantification procedures for VOC content are included in Paragraph (7). The quantification methods used shall be accurate enough to ensure that the affected source's actual emissions are less than the allowable emissions, as calculated using Equation 1 or 2 in Part (4)(a)4., on a daily basis.
(e) Monitoring, recordkeeping, and reporting. The owner or operator of an affected source shall provide a summary of the monitoring, recordkeeping, and reporting procedures that will be used to demonstrate daily compliance with the equations presented in (4)(a)4. The monitoring, recordkeeping, and reporting procedures shall be structured in such a way that inspectors and facility owners can determine an affected source's compliance status for any day.
(f) Implementation schedule. The owner or operator of an affected source shall submit an averaging proposal for Technical Secretary and the Administrator's approval for each existing source as of 180 days after August 15, 1995, and for each new source (after August 15, 1995) which is within 180 days after the start-up of that source. This must ensure that all sources are in compliance with the State's Rule by the November 15, 1996. Submittal of the averaging proposal does not provide an exemption from this Rule. The source must submit the averaging proposal by a date that allows sufficient time for the Administrator's approval.

Notes

Tenn. Comp. R. & Regs. 1200-03-18-.42
Original rule filed June 2, 1995; effective August 15, 1995. Amendment filed March 13, 1997; effective May 27, 1997. Amendment filed June 13, 1997; effective August 28, 1997.

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

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