Environmental Quality, Air Quality

Rule R307-343

Ozone Nonattainment and Maintenance Areas: Emissions Standards for Wood Furniture Manufacturing Operations

Change in Proposed Rule

DAR File No.: 36738
Filed: 12/10/2012 11:51:21 AM

RULE ANALYSIS

Purpose of the rule or reason for the change:

During the public comment period, EPA submitted comments regarding the rule applicability threshold, an error in Table 1, the VOC coating limits, the insufficiency of record-keeping requirements, and a lack of VOC content limits on cleaning solvents. The changes to the proposed rule are in response to these comments.

Summary of the rule or change:

Rule applicability in Section R307-343-2 is changed from 5 to 2.7 tons per year or more per year of VOCs. Several definitions are removed from Section R307-343-3. Language is added to Section R307-343-4 to clarify that exempt solvents are not included in the VOC content limits for the coating used. New VOC emissions rates are also added; these rates will become effective beginning 01/01/2015. Section R307-343-6 is changed to clarify that the owner or operator must provide documentation that the emission control system will meet the requirements of Section R307-343-6. (DAR NOTE: This change in proposed rule has been filed to make additional changes to a proposed amendment that was published in the October 1, 2012, issue of the Utah State Bulletin, on page 56. Underlining in the rule below indicates text that has been added since the publication of the proposed rule mentioned above; strike-out indicates text that has been deleted. You must view the change in proposed rule and the proposed amendment together to understand all of the changes that will be enforceable should the agency make this rule effective.)

State statutory or constitutional authorization for this rule:

• Subsection 19-2-104(1)(a)

Anticipated cost or savings to:

the state budget:

The changes to this rule do not result in any new requirements to the state; therefore, there are no anticipated costs or savings to the state budget.

local governments:

The changes to this rule do not result in any new requirements to local governments; therefore, there are no anticipated costs or savings to local governments.

small businesses:

Because the rule's applicability is changed from sources with the potential to emit 5 tons per year VOC to sources with the the potential to emit 2.7 tons per year VOC, the rule will apply more sources resulting in a cost of up to $2,260 per ton of VOC removed.

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

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

Compliance costs for affected persons:

Because the rule's applicability is changed from sources with the potential to emit 5 tons per year VOC to sources with the the potential to emit 2.7 tons per year VOC, the rule will apply more sources resulting in a cost of up to $2,260 per ton of VOC removed.

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

Because the rule's applicability is changed from sources with the potential to emit 5 tons per year VOC to sources with the the potential to emit 2.7 tons per year VOC, the rule will apply more sources resulting in a cost of up to $2,260 per ton of VOC removed.

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 mberger@utah.gov

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:

01/31/2013

This rule may become effective on:

03/07/2013

Authorized by:

Bryce Bird, Director

R307. Environmental Quality, Air Quality.

R307-343. Emissions Standards for Wood Furniture Manufacturing Operations.

R307-343-1. Purpose.

The purpose of R307-343 is to limit volatile organic compound (VOC) emissions from wood furniture manufacturing.

 

R307-343-2. Applicability.

R307-343 applies to wood furniture manufacturing operations, including related cleaning activities, that have the potential to emit 2.7[5] tons or more per year of VOCs and that are located in Box Elder, Cache, Davis, Salt Lake, Utah, Tooele, and Weber counties.

 

R307-343-3. Definitions.

The following additional definitions apply to R307-343:

"Affected source" means a wood furniture manufacturing source that meets the criteria in R307-343-2.

"As applied" means the volatile organic compound and solids content of the finishing material that is actually used for coating the substrate. It includes the contribution of materials used for in-house dilution of the finishing material.

["Capture device" means a hood, enclosed room, floor sweep, or other means of collecting solvent emissions or other pollutants into a duct so that the pollutant can be directed to a pollution control device such as an incinerator or carbon adsorber.

"Certified product data sheet (CPDS)" means documentation furnished by a coating supplier or an outside laboratory that provides the volatile organic compound content by percent weight, the solids content by percent weight, and the density of a finishing material, strippable booth coating, or solvent, measured using EPA Method 24 or an equivalent method, or formulation data if the coating meets the criteria specified in R307-343-7(1).

] "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.

"Compliant coating" means a finishing material or strippable booth coating that meets the emission limits specified in R307-343-4(1).

["Control device" means any equipment that reduces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent recovery. Control devices include, but are not limited to, incinerators, carbon adsorbers, and condensers.

"Control device efficiency" means the ratio of the pollution released by a control device and the pollution introduced to the control device, expressed as a fraction.

] "Control system" means the combination of capture and control devices used to reduce emissions to the atmosphere.

"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 ten pounds per square inch (gauge) at the point of atomization. Airless, air assisted airless spray technologies, and electrostatic spray technology are not considered conventional air spray.

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

"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.

["Normally closed container" means a container that is closed unless an operator is actively engaged in activities such as emptying or filling the container.

] "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.

"Solids" means the part of the coating that remains after the coating is dried or cured; solids content is determined using data from EPA Method 24.

"Stain" means any color coat having a solids content by weight of no more than 8.0% that is applied in single or multiple coats directly to the substrate, including nongrain raising stains, equalizer stains, sap stains, body stains, no-wipe stains, penetrating stains, and toners.

["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) Is subsequently peeled off and disposed; and

(3) By achieving (1) and (2), reduces or eliminates the need to use organic solvents to clean booth walls.

] "Topcoat" means the last film-building finishing material applied in a finishing system. Non-permanent final finishes are not topcoats.

"Touch-up and Repair" means the application of finishing materials to cover minor finishing imperfections.

"Washcoat" means a transparent special purpose coating having a solids content by weight of 12.0% or less that is applied over initial stains to protect and control color and to stiffen the wood fibers in order to aid sanding.

"Washoff operations" means those operations in which organic solvent is used to remove coating from a substrate.

"Wood furniture" means any product made of wood, a wood product such as rattan or wicker, or an engineered wood product such as particleboard that is manufactured under any of the following standard industrial classification codes: 2434, 2511, 2512, 2517, 2519, 2521, 2531, 2541, 2599, or 5712.

"Wood furniture manufacturing operations" means the finishing, cleaning, and washoff operations associated with the production of wood furniture or wood furniture components.

 

R307-343-4. Emission Standards.

(1) Each affected source subject to R307-343 shall limit VOC emissions by:

(a) Using the compliant coating method as described in R307-343-4 (1)(a)(i) or using the control system method as described in R307-343-4 (1)(a)(ii).

(i) Compliant coating method is the use of the topcoats or topcoat/sealer combinations in Table 1:

 

TABLE 1

Compliant Coating VOC Limitations
(values in pounds VOC per pound of [coating]solids, minus water
 and exempt solvents (compounds not classified as VOC), as applied)

COATING CATEGORY                    VOC EMISSION RATES

                            Effective Through      Effective Beginning
                              December 31,2014       January 1, 2015

Topcoats                               0.8                   0.4

Topcoat/Sealer combination

Topcoat                                1.8                   0.9

Sealer                                 1.9                   0.9

Acid-cured, alkyd amino
topcoat/sealer combinations

Acid-cured,alkyd amino topcoat         2.0                   1.0

Acid-cured,alkyd amino vinyl           2.3                   1.2
Sealer

 

(ii) Control system method is the use of a VOC control system achieving a 90% or greater emissions reduction.

(b) Using strippable spray booth coatings that contain no greater than 0.8 pounds VOC per pound solids as applied.

(c) Using closed containers for the storing of finishing, gluing, cleaning and washoff materials.

 

R307-343-5. Application Equipment Requirements.

(1) All coatings shall be applied using equipment having a minimum 65% transfer efficiency, except as allowed under R307-343-5(3) and operated according to the equipment manufacturer specifications. Equipment meeting the transfer efficiency requirement includes, but is not limited to:

(a) Brush, dip, or roll coating;

(b) Electrostatic application; and

(c) High volume, low pressure (HVLP) spray equipment.

(2) Other coating application methods that achieve emission reductions equivalent to HVLP or electrostatic spray application methods may be used.

(3) Conventional air spray methods may be used under the following circumstances:

(a) To apply finishing materials that have no greater than 1.0 pound of VOC per pound of solids, as applied;

(b) For touch-up and repair under the following circumstances:

(i) The touchup and repair occurs after completion of the finishing operation; or

(ii) The touchup and repair occurs after the application of stain and before the application of any other type of finishing material, and the materials used for touchup and repair are applied from a container that has a volume of no more than 2.0 gallons;

(c) When the spray gun is aimed and triggered automatically, not manually;

(d) When the emissions from the finishing application station are directed to a control device;

(e) When the conventional air gun is used to apply finishing materials and the cumulative total usage of that finishing material is no more than 10% of the total gallons of finishing material used during the calendar year; or

(f) When the conventional air gun is used to apply stain on a part for which it is technically or economically infeasible to use any other spray application technology. 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.

 

R307-343-6. Control Systems Operations.

(1) Emission control systems shall be operated and maintained in accordance with the manufacturer recommendations in order to maintain continuous emission reduction of 90%.

(2) The owner or operator of a control device shall provide [certification]documentation [from the manufacturer ]that the emission control system will attain the requirements of R307-343[required efficiency performance].

(3) 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.

 

R307-343-7. Work Practices and Recordkeeping.

(1) Control techniques and work practices shall be implemented at all times to reduce VOC emissions from fugitive type sources. Control techniques and work practices shall include, but are not limited to:

(a) Storing all VOC-containing coatings, thinners, and coating-related waste materials in closed containers;

(b) Ensuring that mixing and storage containers used for VOC-containing coatings, thinners, and coating-related waste material are kept closed at all times except when depositing or removing these materials;

(c) Minimizing spills of VOC-containing coatings, thinners, and coating-related waste materials; and

(d) Conveying VOC-containing coatings, thinners, and coating-related waste materials from one location to another in closed container or pipes.

(2) The work practices for cleaning materials shall be implemented at all times to reduce VOC emissions from fugitive type sources. The work practices shall include, but are not limited to:

(a) Storing all VOC-containing cleaning materials and used shop towels in closed containers;

(b) Ensuring that storage containers used for VOC-containing cleaning materials are kept closed at all times except when depositing or removing these materials;

(c) Minimizing spills of VOC-containing cleaning materials;

(d) Conveying VOC-containing cleaning materials from one location to another in closed container or pipes; and

(e) Minimizing VOC emission from cleaning of application, storage, mixing, and conveying equipment by ensuring that equipment cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers.

(3) [A certified product data sheet shall be maintained for each sealer, topcoat, and strippable booth coating used to demonstrate compliance with the emission standards in R307-343-4. If solvent or other VOC is added before application, documentation shall be maintained showing the VOC content as applied in pounds VOC per pounds solid.] All persons shall perform solvent cleaning operations with cleaning material having VOC content of 0.21 pounds per gallon or less.

(4) [The owner or operator shall demonstrate compliance with the requirements of R307-343-5.]All sources subject to R307-343 shall maintain records demonstrating compliance with all provisions of R307-343 on an annual basis.

(a) Records shall include, but not be limited to, inventory and product data sheets for all coatings and solvents subject to R307-343.

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

 

R307-343-8. Compliance Schedule.

(1) Sources in Salt Lake and Davis counties that have the potential to emit 2.7[5] or more tons but less than 25 tons of VOC per year shall be in compliance by September 1, 2013.

(2) Sources in Salt Lake and Davis counties that have the potential to emit 25 tons or more of VOC per year shall be in compliance upon the effective date of this rule.

(3) All sources in Box Elder, Cache, Utah and Weber counties shall be in compliance with this rule by January 1, 2014.

 

KEY: air pollution, wood furniture, coatings

Date of Enactment or Last Substantive Amendment: [2012]2013

Notice of Continuation: February 1, 2012

Authorizing, and Implemented or Interpreted Law: 19-2-104(1)(a); 19-2-104(3)(e)