No. 38682 (Amendment): Rule R307-349. Flat Wood Panel Coatings

(Amendment)

DAR File No.: 38682
Filed: 07/07/2014 10:17:39 AM

RULE ANALYSIS

Purpose of the rule or reason for the change:

The EPA has indicated that it cannot approve Rule R307-349 as a Reasonable Available Control Technology (RACT) rule as part of Utah's PM2.5 State Implementation Plan (SIP) until it is amended to clarify that the amount of control removal specified in each rule is based on the entire system and the inspection and recordkeeping requirements of the rule are expanded.

Summary of the rule or change:

The rule is amended to require an overall control efficiency of the add-on emission control system of 90%, clarify methodology for determining capture efficiency, and to include additional recordkeeping requirements for the add-on emission control system.

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

There are no new requirements in this proposed rule for the State of Utah; therefore, there are no anticipated costs or savings.

local governments:

There are no new requirements for local government; therefore, there are no anticipated costs or savings.

small businesses:

There are two options to reduce the emissions of VOCs. The first, and more cost-effective, option for small businesses is to use products that meet the VOC limits as specified in Table 1. The other option, which likely only very few larger sources would do, is to use an add-on emission control system that meets the 90% efficiency threshold.

persons other than small businesses, businesses, or local governmental entities:

There are no new requirements for persons other than small businesses, or local government entities; therefore, there are no anticipated costs or savings.

Compliance costs for affected persons:

There are two options to reduce the emissions of VOCs. The first, and more cost-effective option for small businesses, is to use products that meet the VOC limits as specified in Table 1. The other option, which likely only very few larger sources would do, is to use an add-on emission control system that meets the 90% efficiency threshold. It is difficult to determine the cost of installing and operating an add-on emission control system that meets the 90% requirements, as appropriate emission control systems for each source are extremely variable.

Comments by the department head on the fiscal impact the rule may have on businesses:

In most cases businesses will choose to use products that meet the VOC limits in Table 1 of the rule, as that option is usually the most cost-effective. Should a business choose to install and operate an add-on emission control system that meets the 90% overall capture and control efficiency, there would be additional costs to that business. However because appropriate emission control systems for each source are extremely variable, those costs are difficult to predict.

Amanda Smith, Executive Director

The full text of this rule may be inspected, during regular business hours, at the Division of Administrative Rules, or at:

Environmental Quality
Air QualityRoom Fourth Floor
195 N 1950 W
SALT LAKE CITY, UT 84116-3085

Direct questions regarding this rule to:

• Mark Berger at the above address, by phone at 801-536-4000, by FAX at 801-536-0085, or by Internet E-mail at [e-mail]

Interested persons may present their views on this rule by submitting written comments to the address above no later than 5:00 p.m. on:

09/02/2014

This rule may become effective on:

10/02/2014

Authorized by:

Bryce Bird, Director

RULE TEXT

R307. Environmental Quality, Air Quality.

R307-349. Flat Wood Panel Coatings.

R307-349-1. Purpose.

The purpose of R307-349 is to limit volatile organic compound (VOC) emissions from flat wood paneling coating sources.

 

R307-349-2. Applicability.

[(1) ]R307-349 applies to sources located in Box Elder, Cache, Davis, Salt Lake, Tooele, Utah and Weber counties that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

[(2) In Box Elder and Tooele counties, R307-349 apples to the following sources:

(a) Existing sources as of February 1, 2013 with the potential to emit 5 tons per year or more of VOC, including related cleaning activities; and

(b) New sources as of February 1, 2013 that have the potential to emit 2.7 tons per year or more of VOC, including related cleaning activities.

]

R307-349-3. Definitions.

The following additional definitions apply to R307-349:

"Coating" means a protective, decorative, or functional material applied in a thin layer to a surface. Such materials may include paints, topcoats, varnishes, sealers, stains, washcoats, basecoats, inks, and temporary protective coatings.

"Finishing material" means a coating used in the flat wood panel industry, including basecoats, stains, washcoats, sealers, and topcoats.

"Flat wood paneling" means wood paneling products that are any decorative interior, exterior or tileboard (class I hardboard) panel to which a protective, decorative, or functional material or layer has been applied.

"Sealer" means a finishing material used to seal the pores of a wood substrate before additional coats of finishing material are applied. A washcoat used to optimize aesthetics is not a sealer.

"Strippable booth coating" means a coating that is applied to a booth wall to provide a protective film to receive overspray during finishing and that is subsequently peeled and disposed. Strippable booth coatings are intended to reduce or eliminate the need to use organic solvents to clean booth walls.

"Tileboard" means a premium interior wall paneling product made of hardboard that meets the specifications for Class I given by the standard ANSI/AHA A135.4-1995.

 

R307-349-4. [Emission Standards]VOC Content Limit.

(1) Each owner or operator shall not apply coatings with a VOC content in excess of 2.1 pounds of VOC per gallon, excluding water and exempt solvents (compounds not classified as VOC). The equivalent emission limit shall be 2.9 pounds VOCs per gallon solids coating; or

(2) Each owner or operator shall use an add-on control device as specified in R307-349-6.

 

R307-349-5. Work Practice and Recordkeeping.

(1) The owner or operator shall:

(a) Store all VOC-containing coatings, thinners, and cleaning materials in closed containers;

(b) Minimize spills of VOC-containing coatings, thinners, and cleaning materials;

(c) Clean up spills immediately;

(d) Convey any coatings, thinners, and cleaning materials in closed containers or pipes;

(e) Close mixing vessels that contain VOC coatings and other materials except when specifically in use; and

(f) Minimize usage of solvents during cleaning of storage, mixing, and conveying of equipment.

(2) No person shall apply any coating unless the coating application method achieves a demonstrated 65% transfer efficiency.

The following applications achieve a minimum of 65% transfer efficiency and shall be operated in accordance with the manufacturers specifications:

(a) Paint brush;

(b) Flow coat;

(c) Roll coat;

(d) Dip coat;

(e) Detailing or touch-up guns;

(e) High-volume, low-pressure (HVLP) spray;

(f) Hand application methods; or

(g) Other application method capable of achieving at least 65% transfer efficiency, as certified by the manufacturer.

(3) No person shall use organic solvents for cleaning operations that exceed a VOC content of 0.21 pounds per gallon and a strippable booth coating with a VOC content in excess of 3.8 pounds per gallon, excluding water and exempt solvents (compounds that are not defined as VOC).

(4) All sources subject to R307-349 shall maintain records demonstrating compliance with[ all provisions of] R307-349-4 and R307-349-5[ on an annual basis].

(a) Records should include, but not be limited to, inventory and products data sheets of all coatings and solvents subject to R307-349.

(b) These records shall be available to the Director upon request.

 

R307-349-6. [Optional ]Add-On Control[s] Systems Operations.

[(1) The owner or operator may install and maintain an incinerator, carbon adsorption, or any other add-on emission control device, provided that the emission control device will attain at least 90% efficiency performance.

(2) The owner or operator of a control device shall provide documentation that the emission control system will attain the requirements of R307-349-6.

(3) Emission control systems shall be operated and maintained in accordance with the manufacturer recommendations. The owner or operator shall maintain for a minimum of two years records of operating and maintenance sufficient to demonstrate that the equipment is being operated and maintained in accordance with the manufacturer recommendations.

](1) The owner or operator shall install and maintain an incinerator, carbon adsorption, or any other add-on emission control system, provided that the emission control system is operated and maintained in accordance with the manufacturer recommendations in order to maintain at least 90% capture and control efficiency. Determination of overall capture and control efficiency shall be determined using EPA approved methods, as follows.

(a) The capture efficiency of a VOC emission control system's VOC collection device shall be determined according to EPA's "Guidelines for Determining Capture Efficiency," January 9, 1995 and 40 CFR Part 51, Appendix M, Methods 204-204F, as applicable.

(b) The control efficiency of a VOC emission control system's VOC control device shall be determined using test methods in Appendices A-1, A-6, and A-7 to 40 CFR Part 60, for measuring flow rates, total gaseous organic concentrations, or emissions of exempt compounds, as applicable.

(c) An alternative test method may be substituted for the preceding test methods after review and approval by the EPA Administrator.

(2) The owner or operator of a control system shall provide documentation that the emission control system will attain the requirements of R307-349-6(1).

(3) The owner or operator shall maintain records of key system parameters necessary to ensure compliance with R307-349-6. Key system parameters may include, but are not limited to, temperature, pressure and flow rates. Operator inspection schedule, monitoring, recordkeeping, and key parameters shall be in accordance with the manufacturer's recommendations, and as required to demonstrate operations are providing continuous emission reduction from the source during all periods that the operations cause emissions from the source.

(4) The owner or operator shall maintain for a minimum of two years records of operating and maintenance sufficient to demonstrate that the equipment is being operated and maintained in accordance with the manufacturer recommendations.

 

[R307-349-7. Compliance Schedule.

(1) All sources in Davis and Salt Lake counties are subject to this rule as of the effective date of this rule.

(2) Sources in Box Elder, Cache, Tooele, Utah and Weber counties shall be in compliance with this rule by January 1, 2014.

 

]KEY: air pollution, emission controls, flat wood paneling, coatings

Date of Enactment or Last Substantive Amendment: [February 1, 2013]2014

Authorizing, and Implemented or Interpreted Law: 19-2-104(1)(a)

 

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