Indiana Administrative Code
Title 326 - AIR POLLUTION CONTROL DIVISION
Article 8 - VOLATILE ORGANIC COMPOUND RULES
Rule 11 - Wood Furniture Coatings
Section 11-6 - Compliance procedures and monitoring requirements
Universal Citation: 326 IN Admin Code 11-6
Current through March 20, 2024
Authority: IC 13-14-8; IC 13-17-3-4
Affected: IC 13-12
Sec. 6.
(a) The owner or operator of a wood furniture manufacturing operation subject to the emission limits in section 3 of this rule shall demonstrate compliance with the provisions of section 3 of this rule by using any of the following methods:
(1) To support that each sealer, topcoat, and
strippable booth coating meets the requirements of section 3(a)(1) through
3(a)(3) or 3(b) of this rule, maintain documentation that uses 40 CFR 60,
Appendix A, Method 24* data, or data from an equivalent or alternative 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 wood furniture manufacturing operation shall maintain documentation showing
the VOC content of the finishing material as-applied, in kilograms of VOC per
kilogram of solids (kg VOC/kg solids).
(2) To comply through the use of a control
system as described in section 3(a)(5) of this rule the following are required:
(A) Determine the overall control efficiency
needed to demonstrate compliance using Equation 3:
Equation 3: O = ((V - E)/V)(100)
Where: O = overall control efficiency of the capture system and control device as percentage.
V = actual VOC content of the finishing system material or, if multiple finishing materials are used, the daily weighted average VOC content of all finishing materials, as-applied to the substrate in pounds of VOC per pound of solids (lbs VOC/lb solids).
E = equivalent VOC emission limits in lbs VOC/lb solids.
(B) Document that
the value of V in Equation 3 is obtained from the VOC and solids content of the
as-applied finishing material.
(C)
Calculate the overall efficiency of the capture system and control device,
using the procedures in section 7 of this rule, and demonstrate that the value
of the overall control efficiency thus estimated is equal to or greater than
the value of O calculated by Equation 3.
(b) Initial compliance shall be demonstrated as follows:
(1) Owners or operators of a wood
furniture manufacturing operation subject to the provisions of section 3(a)(1)
through 3(a)(3) or 3(b) of this rule that are complying through the procedures
established in subsection (a)(1) shall submit an initial compliance status
report, as required by sections 5 and 9 of this rule, stating that compliant
sealers and topcoats and strippable booth coatings are being used by the wood
furniture manufacturing operations.
(2) Owners or operators of a wood furniture
manufacturing operation subject to the provisions of section 3(a)(1) through
3(a)(3) or 3(b) of this rule that are complying through the procedures
established in subsection (a)(1) and are applying sealers and topcoats using
continuous coaters shall demonstrate initial compliance by either of the
following:
(A) Submitting an initial
compliance status report stating that compliant sealers and 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.
(B) Submitting an initial compliance status
report stating that compliant sealers 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
wood furniture manufacturing operation 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 a wood
furniture manufacturing operation using a control system or capture or control
device to comply with the requirements of this rule, as allowed by section
3(a)(5) of this rule and subsection (a)(2) shall demonstrate initial compliance
by doing the following:
(A) On or before
January 1, 1996, conducting an initial compliance test using the procedures and
test methods listed in section 7 of this rule.
(B) On or before January 1, 1996, calculating
the overall control efficiency.
(C)
On or before January 1, 1996, determining those operating conditions critical
to determining compliance and establishing operating parameters that will
ensure compliance with the standards as follows:
(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
commissioner to establish other operating parameters.
(v) For compliance with a control device not
listed in this rule, the owner or operator shall submit to the department a
description of the control device, test data, verifying the performance of the
device, and appropriate operating values that will be monitored to demonstrate
continuous compliance with the standard. Compliance using this device is
subject to the commissioner's approval.
(D) Owners or operators complying with this
subdivision 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 initial
compliance test required in subsection (c)(3)(A)(iv).
(E) On or before May 1, 1996, 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.
(4)
Owners or operators of a wood furniture manufacturing operation subject to the
continuous compliance plan (CCP) in section 5 of this rule shall submit an
initial compliance status report, as required by section 9(b) of this rule,
stating that the CCP has been developed and procedures have been established
for implementing the provisions of the plan.
(c) Continuous compliance shall be demonstrated as follows:
(1) Owners or
operators of a wood furniture manufacturing operation subject to the provisions
of section 3 of this rule that are complying through the procedures established
in subsection (a)(1) shall demonstrate continuous compliance by using compliant
materials, maintaining records that demonstrate the finishing materials are
compliant, and submitting a compliance certification with the semiannual report
required by section 9(c) of this rule. The compliance certification
requirements shall be as follows:
(A) State
that compliant sealers and topcoats and strippable booth coatings have been
used each day in the semiannual reporting period, or should otherwise identify
the days of noncompliance and the reasons for noncompliance. A wood furniture
manufacturing operation 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.
(B)
The compliance certification shall be signed by a responsible
official.
(2) Owners or
operators of a wood furniture manufacturing operation subject to the provisions
of section 3 of this rule that are complying through the procedures established
in subsection (a)(1) and are applying sealers and topcoats using continuous
coaters shall demonstrate continuous compliance by use of the following
procedures:
(A) Using compliant materials, as
determined by the VOC content of the finishing material in the reservoir and
the VOC content as calculated from records, and submitting a compliance
certification with the semiannual report required by section 9(c) of this rule.
The compliance certificate requirements shall be as follows:
(i) State that compliant sealers and topcoats
have been used each day in the semiannual reporting period, or should otherwise
identify the days of noncompliance and the reasons for noncompliance. A wood
furniture manufacturing operation 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.
(B) 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,
maintaining records of solvent additions, and submitting a compliance
certification with the semiannual report required by section 9(c) of this rule.
The compliance certification requirements shall be as follows:
(i) State that compliant sealers and
topcoats, as determined by the VOC content of the finishing material in the
reservoir, have been used each day in the semiannual reporting period.
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, for any day in the semiannual reporting period.
(ii) The compliance certification shall be
signed by a responsible official.
(iii) A wood furniture manufacturing
operation is in violation of the standard when a sample of the as-applied
finishing material exceeds the applicable limit established in section 3(a)(1)
through 3(a)(3) of this rule, as determined using EPA Method 24*, or an
equivalent or alternative 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 a wood furniture manufacturing operation subject to the
provisions of section 3 of this rule that are complying through the use of a
control system or a capture or control device shall demonstrate continuous
compliance by complying with the control system operation, maintenance, and
testing, and control system monitoring, record keeping, and reporting
requirements as follows:
(A) For sources
choosing to meet the emission limit requirements of section 3(a)(5) of this
rule at any facility using a control device or devices, the following
requirements apply:
(i) The control system
shall be operated and maintained according to the manufacturer's
recommendations but may be modified based upon the results of the initial or
subsequent compliance test or upon the written request of the
department.
(ii) The operating and
maintenance procedures shall be followed beginning no later than January 1,
1996. A copy of the procedures shall be submitted to the department no later
than May 1, 199Sec. 6.
(iii) A copy
of the operating and maintenance procedures shall be maintained in a convenient
location at the source property and as close to the control system as possible
for the reference of plant personnel and department inspectors.
(iv) The control system shall be tested
according to the following schedule and under the following situations:
(AA) An initial compliance test shall be
conducted on or before January 1, 1996, and every two (2) years after the date
of the initial test.
(BB) A
compliance test shall also be conducted whenever the owner or operator chooses
to operate a control system under conditions different from those that were in
place at the time of the previous compliance test.
(CC) If the owner or operator chooses to
change the method of compliance with section 3 of this rule, a compliance test
shall be performed within three (3) months of the change.
(DD) A compliance test shall also be
performed within ninety (90) days of the receipt of a written request from the
department or the U.S. EPA.
(EE)
All compliance tests shall be conducted according to a protocol approved by the
department at least thirty (30) days before the test. The protocol shall
contain, at a minimum, the following information:
(aa) Test procedures.
(bb) Operating and control system
parameters.
(cc) Type of VOC
containing process material being used.
(dd) The process and control system
parameters that will be monitored during the test.
(B) Control system
monitoring, record keeping, and reporting requirements are as follows:
(i) Sources that choose to meet the emission
limit requirements of section 3 of this rule with the use of a control device
or devices shall install, calibrate, maintain, and operate, according to the
manufacturer's specification, the following monitoring equipment unless an
alternative monitoring procedure has been approved by the commissioner:
(AA) If a thermal incinerator is used for VOC
reduction, a temperature monitoring device capable of continuously recording
the temperature of the gas stream in the combustion zone of the incinerator
shall be used. The temperature monitoring device shall have an accuracy of one
percent (1%) of the temperature being measured in degrees centigrade or plus or
minus five-tenths degree Centigrade (0.5°C), whichever is
greater.
(BB) If a catalytic
incinerator is used for VOC reduction, a temperature device capable of
continuously recording the temperature in the gas stream immediately before and
after the catalyst bed of the incinerator shall be used. The temperature
monitoring device shall have an accuracy of one percent (1%) of the temperature
being measured in degrees centigrade plus or minus five-tenths degree
Centigrade (0.5°C), whichever is greater.
(CC) If a carbon adsorber is used to remove
and recover VOC from the gas stream, a VOC monitoring device capable of
continuously recording the concentration level of VOC at the outlet of the
carbon bed shall be used. The monitoring device shall be based on a detection
principle such as infrared, photoionization, or thermal conductivity.
(DD) Where a VOC recovery device other than a
carbon adsorber is used, the source shall provide to the department information
describing the operation of the device and the process parameters that would
indicate proper operation and maintenance of the control device. The department
may request further information and will specify appropriate monitoring
procedures and reporting requirements.
(ii) Sources subject to the requirements of
this rule shall maintain the following records:
(AA) A log of the operating time of the
facility, the facility's capture system, control device, and monitoring
equipment.
(BB) A maintenance log
for the capture system, the control device, and the monitoring equipment
detailing all routine and nonroutine maintenance performed. The log shall
include the dates and duration of any outages of the capture system, the
control device, or the monitoring system.
(CC) The following additional records shall
be maintained for facilities using thermal incinerators:
(aa) Continuous records of the temperature in
the gas stream in the combustion zone of the incinerator.
(bb) Records of all three (3) hour periods of
operation for which the average combustion temperature of the gas stream in the
combustion zone was more than fifty degrees Fahrenheit (50°F) below the
combustion zone temperature that existed during the most recent compliance test
that demonstrated that the facility was in compliance.
(DD) The following additional records shall
be maintained for facilities using catalytic incinerators:
(aa) Continuous records of the temperature of
the gas stream both upstream and downstream of the catalyst bed of the
incinerator.
(bb) Records of all
three (3) hour periods of operation for which the average temperature measured
at the process vent stream immediately before the catalyst bed is more than
fifty degrees Fahrenheit (50°F) below the average temperature of the
process vent stream that existed during the most recent compliance test that
demonstrated that the facility was in compliance.
(cc) Records of all three (3) hour periods of
operation for which the average temperature difference across the catalyst bed
is less than eighty percent (80%) of the temperature difference measured during
the most recent compliance test that demonstrated that the facility was in
compliance.
(EE) The
following additional records shall be maintained for facilities using carbon
adsorbers:
(aa) Continuous records of the VOC
concentration level or reading in the exhaust stream of the carbon
adsorber.
(bb) Records of all three
(3) hour periods of operation during which the average VOC concentration level
or reading in the exhaust gas is more than twenty percent (20%) greater than
the average exhaust gas concentration level or reading measured by the organic
monitoring device during the most recent determination of the recovery
efficiency of the carbon adsorber that demonstrated that the facility was in
compliance.
(FF)
Facilities using VOC recovery devices other than carbon adsorbers shall
maintain the monitoring records and meet the reporting requirements specified
by item (i)(DD).
(GG) Information
requirements in subitems (BB), (CC)(bb), (DD)(bb), (DD)(cc), and (EE)(bb) shall
be submitted to the department within thirty (30) days of occurrence. The
following information shall accompany the submittal:
(aa) The name and location of the
facility.
(bb) Identification of
the control system where the excess emission occurred and the facility it
served.
(cc) The time, date, and
duration of the exceedance.
(dd)
Corrective action taken.
(4) Owners or operators of a wood furniture
manufacturing operation subject to the CCP in section 5 of this rule shall
demonstrate continuous compliance by following the provisions of the CCP and
submitting a compliance certification with the semiannual report required by
section 9(c) of this rule. The compliance certification requirements shall be
as follows:
(A) State that the CCP is being
followed, or shall 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.
(B) The compliance certification shall be
signed by a responsible official.
*This document is incorporated by reference. Copies may be obtained from the Government Printing Office, 732 North Capitol Street NW, Washington, D.C. 20401 or are available for review and copying at the Indiana Department of Environmental Management, Office of Air Quality, Indiana Government Center-North, Tenth Floor, 100 North Senate Avenue, Indianapolis, Indiana 46204.
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