Mo. Code Regs. Ann. tit. 10, § 10-5.530
PURPOSE: This rule limits the volatile organic compound (VOC) emissions from wood furniture manufacturing operations by incorporating reasonably available control technology (RACT) per 172(c)(1) of the Clean Air Act.
(1) Applicability.
(2) Definitions.
seal the pores of a wood substrate before additional coats of finishing material are applied. Washcoats, which are used in some finishing systems to optimize aesthetics, are not sealers.
(3) General Provisions.
(A) Restriction of Emissions.
source shall limit VOC emissions from finishing operations by complying with one (1) of the following requirements:
without sealers, the topcoat shall have a VOC content no greater than Table 1; or Table 1 kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Topcoat 0.8 0.8
applied and—
alkyd amino vinyl or topcoat is not acidcured alkyd amino conversion varnish, the VOC contents shall be no more than shown in Table 2; Table 2 kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Sealer 1.9 1.9 Topcoat 1.8 1.8
alkyd amino vinyl and topcoat is acid-cured alkyd amino conversion varnish, the VOC contents shall be no more than shown in Table 3; Table 3 kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Sealer 2.3 2.3 Topcoat 2.0 2.0
alkyd amino vinyl and topcoat is acid-cured alkyd amino conversion varnish, the VOC contents shall be no more than shown in Table 4; or Table 4 kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Sealer 1.9 1.9 Topcoat 2.0 2.0
alkyd amino vinyl and topcoat is not acidcured alkyd amino conversion varnish, the VOC contents shall be no more than shown in Table 5. Table 5 kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Sealer 2.3 2.3 Topcoat 1.8 1.8 10 CSR 10-5
ation requirements of paragraph (3)(A)1. of this rule, the owner or operator of an affected source may use an averaging approach to verify compliance by using this paragraph. Compliance is demonstrated when actual emissions from the affected source are less than or equal to allowable emissions using one (1) of the following inequalities:
0.9(0.8(TC1 + TC2 +…)) ≥ [(ERTC1)(TC1) + (ERTC2)(TC2) +…] (1)
0.9{[1.8(TC1 + TC2 +…)] + [1.9(SE1 + SE2 +…)] + [9.0 (WC1 + WC2 +…)] + [1.2(BC1 + BC2 +…)] + [0.791(ST1 + ST2 +…)]} ≥ [ERTC1(TC1) + ERTC2(TC2) +…] + [ERSE1(SE1) + ERSE2(SE2) +…] + [ERWC1(WC1) + ERWC2(WC2) +…] + [ERBC1(BC1) + ERBC2(BC2) +…] + [ERST1(ST1) + ERST2 (ST2) + …] (2) where: 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.
Note 1: Various numeric values used in inequalities (0.8, 1.8, 1.9, etc.) are maximum allowable VOC contents for various coatings.
Note 2: The 0.9 multiplying factor on the allowable emissions side of the inequality is used to assure that sources using the averaging approach demonstrate their emissions are no greater than ninety percent (90%) of what they would be if they were using compliant coatings.
For Inequalities (1) and (2), the facility must use the actual VOC content of the finishing materials used prior to the effective date of this rule if the VOC content is less than the allowable VOC content. For example, if the affected source was using topcoats with a VOC content of 1.7 kilograms of VOC per kilogram of solids (1.7 pounds of VOC per pound of solids) before being subject to this rule, the affected source must use that value in Inequality (2) rather than 1.8.
tion requirements of subparagraph (3)(A)1.A. or part (3)(A)1.B.(II) of this rule, the owner or operator of an affected source may use a control system (capture device/control device) that will achieve an equivalent reduction in emissions as demonstrated using the compliance requirements of subparagraph (3)(C)1.B. of this rule.
tion requirements of paragraphs (3)(A)1. and (3)(A)2. of this rule, the owner or operator of an affected source may use a combination of the methods presented in paragraphs (3)(A)1., (3)(A)2., and (3)(A)3. of this rule as demonstrated using the compliance requirements of subparagraph (3)(C)1.C. of this rule.
source shall limit VOC emissions from cleaning operations when using a strippable booth coating to that shown in Table 6.
Table 6
kg VOC/kg solids lb VOC/lb solids (as applied) (as applied) Strippable booth coating 0.8 0.8
(B) Work Practice Standards. The owner or operator of an affected source shall develop and maintain work practice standards that include, at a minimum:
tion plan that defines work practices for each wood furniture manufacturing operation and addresses each of the topics specified in paragraphs (3)(B)2. through (3)(B)10. of this subsection. The plan shall be developed no more than sixty (60) days after the compliance date of this rule. The owner or operator of the affected source shall comply with each provision of the work practice implementation plan. The written work practice implementation plan shall be available for inspection by the department, upon request. If the department determines that the work practice implementation plan does not adequately address each of the topics specified in paragraphs (3)(B)2. through (3)(B)10. of this subsection, the department may require the affected source to modify the plan;
existing personnel, including contract personnel, who are involved in finishing, cleaning, or washoff operations or implementation of the requirements of this rule. All new personnel, those hired after the effective date of the rule, shall be trained upon hiring. All existing personnel, those hired before the effective date of the rule, shall be trained within six (6) months of the effective date of the 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:
name and job description;
in the initial and refresher training for each position, or group of personnel;
given at the initial and the annual refresher training that include, at a minimum, appropriate application techniques, appropriate cleaning and washoff procedures, appropriate equipment setup and adjustment to minimize finishing material usage and overspray, and appropriate management of cleanup wastes; and
used at the completion of initial or refresher training to demonstrate and document successful completion, and a record of the date each employee is trained;
maintenance plan prepared and maintained with the work practice implementation plan and specify, at a minimum—
quency of once per month for all equipment used to transfer or apply finishing materials or organic solvents;
and results of each inspection and any repairs;
ing an equipment leak and making the repair, which adheres to the following schedule:
tightening of packing glands) shall be made no later than five (5) working days after the equipment leak is detected; and
within fifteen (15) working days, unless the leaking equipment is to be replaced by a new purchase, in which case repairs shall be completed within three (3) months;
accounting system that includes an organic solvent accounting form to record—
solvent used each month for washoff and cleaning;
with the reason for washoff; and
solvent generated from each activity. The net quantity of spent solvent is equivalent to the total amount of organic solvent that is generated from the activity minus any organic solvent that is recycled on-site for operations other than cleaning or washoff and any organic solvent disposed off-site;
pounds containing more than eight (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 one (1.0) gallon of organic solvent to prepare the booth prior to applying the booth coating;
owners or operators of affected sources use normally closed containers for storing finishing, cleaning, and washoff materials;
to ensure owners or operators of affected sources do not use conventional air spray guns for applying finishing materials except for the following conditions:
that have a VOC content no greater than 1.0 kg VOC/kg solids (1.0 lb VOC/lb solids), as applied;
B. To touch-up and repair when—
applied after completion of the finishing operation; or
applied after the stain and before any other type of finishing material is applied, and the finishing materials are applied from a container that has a volume of no more than two (2.0) gallons;
the spray gun is aimed and triggered automatically, not manually);
application station are directed to a control device;
gun is used to apply finishing materials and the cumulative total usage of that finishing material is no more than five (5.0) percent of the total gallons of finishing material used during that semiannual reporting period; or
gun is used to apply stain on a part for which it is technically or economically infeasible to Specific to the St. Louis Metropolitan Area
use any other spray application technology. For this condition, the owner or operator of the affected source shall demonstrate why it is technically or economically infeasible by submitting to the department documentation to support the affected source’s claim. The support documentation shall include the following criteria, either independently or in combination:
high or the part shape is too complex for one (1) operator to coat the part and the finishing application station is not large enough to accommodate an additional operator; or
spray area of the part makes it difficult to avoid sagging or runs in the stain;
organic solvent used for line cleaning into a normally closed container;
solvent used to clean spray guns into a normally closed container; and
emissions from washoff operations by—
washoff; and
rotating the part to drain as much organic solvent as possible.
(C) Compliance Procedures and Monitoring Requirements.
source subject to the emission standards in subsection (3)(A) of this rule shall demonstrate compliance with those requirements by using one (1) of the following methods:
topcoat, and strippable booth coating meets the applicable requirements of paragraphs (3)(A)1. and (3)(A)5. of this rule, the owner or operator shall maintain certified product data sheets for each of these finishing materials. If solvent or other VOC is added to the finishing material before application, the owner or operator shall maintain documentation showing the VOC content of the finishing material as applied, in kg VOC/kg solids (lb VOC/lb solids); or
the use of a control system (capture device/control device) per paragraph (3)(A)3. of this rule, the owner or operator shall—
efficiency needed to demonstrate compliance using Equation (3) as follows;
R = [(C – E)/C] × 100 (3)
where: R =the overall efficiency of the control system, expressed as a percentage; 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; and E =the emission limit achieved by the affected emission point(s), in kg VOC/kg solids;
Equation (3) is obtained from the VOC and solids content of the as-applied finishing material; and
of the control device, using the procedure in subsection (5)(D) of this rule, and demonstrate that the value of the overall efficiency of the control system, expressed as a percentage, is equal to or greater than the value of R calculated by Equation (3); or
through the use of a combination of the methods per paragraph (3)(A)4. of this rule, the owner or operator shall meet all individual compliance requirements for the applicable methods being combined.
2. Initial compliance.
affected source subject to a requirement of paragraph (3)(A)1. or (3)(A)5. of this rule that is complying through the method established in subparagraph (3)(C)1.A. of this rule, shall submit an initial compliance status report, as required by paragraph (4)(A)2. of this rule, stating that compliant sealers and/or topcoats and strippable booth coatings are being used by the affected source.
ed source subject to a requirement of paragraph (3)(A)1. of this rule that is complying through the method established in subparagraph (3)(C)1.A. of this rule and is applying sealers and/or topcoats using continuous coaters shall demonstrate initial compliance by—
ance 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
ance 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. 10 CSR 10-5
affected source demonstrating compliance with this rule through the use of a control system (capture device/control device) per paragraph (3)(A)3. and subparagraph (3)(C)1.B. of this rule, shall demonstrate initial compliance by—
that identifies the operating parameter to be monitored for the capture device and discusses why the parameter is appropriate for demonstrating ongoing compliance;
mance test using the procedures and test methods listed in subsections (5)(C) and (5)(D) of this rule (test methods in paragraphs (5)(C)3., (5)(C)4., and (5)(C)5. of this rule shall be performed, as applicable, at least twice during each test period);
efficiency using the procedure in subsection (5)(D) of this rule;
conditions critical to determining compliance and establishing operating parameters that will ensure compliance with the standard as follows:
mal incinerator, minimum combustion temperature shall be the operating parameter;
alytic incinerator equipped with a fixed catalyst bed, the minimum gas temperature both upstream and downstream of the catalyst bed shall be the operating parameter;
alytic 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; and
bon 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 director to establish other operating parameters; and
affected source demonstrating compliance with this rule per subparagraph (3)(C)2.C. of this rule 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 three (3) test runs required by paragraph (5)(C)1. of this rule.
affected source subject to the work practice standards in subsection (3)(B) of this rule shall submit an initial compliance status report, as required by paragraph (4)(A)3. of this rule, stating that the work practice implementation plan has been developed and procedures have been established for implementing the provisions of the plan.
(D) Special Requirements for Sources Using An Averaging Approach. The owner or operator of an affected source complying with the emission limitations in subsection (3)(A) of this rule through the procedures established in paragraph (3)(A)2. of this rule shall also meet the following requirements:
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 paragraph (3)(A)2. of this rule 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 inequalities in paragraph (3)(A)2. of this rule. These inequalities ensure that the affected source is achieving an additional ten percent (10%) reduction in emissions when compared to affected sources using a compliant coatings approach to meet the requirements of the rule;
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 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;
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;
or operator of the affected source shall specify methods and procedures for quantifying emissions. Quantification procedures for VOC content are included in section (5) of this rule. The owner or operator shall specify methods to be used for determining the usage of each finishing material. 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 Inequality (1) or (2) in paragraph (3)(A)2. of this rule, on a daily basis to a level of certainty comparable to that for traditional control strategies applicable to surface coating sources;
reporting. The owner or operator of an affected source shall provide a summary of the monitoring, record keeping, and reporting procedures that will be used to demonstrate daily compliance with the inequalities presented in paragraph (3)(A)2. of this rule. The monitoring, record keeping, 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. Furthermore, the procedures shall include methods for determining required data when monitoring, record keeping, and reporting violations result in missing, inadequate, or erroneous monitoring and record keeping. These procedures must ensure that sources have sufficiently strong incentive to properly perform monitoring and record keeping;
or operator of an affected source shall submit an averaging proposal for state and EPA approval by July 31, 2001; and
affected source may submit an averaging approach proposal to the director for consideration in meeting the compliance requirements of this rule. The director shall take the following actions:
posal submittal is complete and notify the submitter of the completeness status within thirty (30) calendar days of receipt of the proposal; and
al within thirty (30) calendar days of determining that a proposal submittal is complete.
(4) Reporting and Record Keeping.
(A) Reporting Requirements.
source using a control system to comply with this rule is required to submit a written report of the results from the performance test in (3)(C)2.C.(II) of this rule to the director within sixty (60) calendar days of completion of the performance test.
source subject to this rule shall submit an initial compliance report within sixty (60) calendar days after the compliance date. The report shall include the items required in paragraph (3)(C)2. of this rule.
source subject to this rule and demonstrating compliance in accordance with subparagraph (3)(C)1.A. or (3)(C)1.B. of this rule shall submit a semiannual report covering the previous six (6) months of wood furniture manufacturing operations according to the following schedule:
thirty (30) calendar days after the end of the first six (6)-month period following the compliance date;
mitted within thirty (30) calendar days after the end of each six (6)-month period following the first report; and
include a statement of whether the affected source was in compliance or noncompliance, and, if the affected source was in noncompliance, the measures taken to bring the affected source into compliance.
(B) Record Keeping Requirements.
source subject to the emission standards in subsection (3)(A) of this rule shall maintain records of the following:
each finishing material and strippable booth coating subject to the emission limits in subsection (3)(A) of this rule; and
solids (lb VOC/lb solids), as applied, of each finishing material and strippable booth coating subject to the emission limits in subsection (3)(A) of this rule, and copies of data sheets documenting how the as-applied values were determined.
source following the compliance method of subparagraph (3)(C)1.B. of this rule shall maintain the following records:
port the equivalency of using a control system, as well as the data necessary to support the calculation of E in Equation (3) and the calculation of overall efficiency for a control system for subsection (5)(D) of this rule;
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
across the catalyst bed for facilities complying with the emission limitations using a catalytic incinerator with a fluidized catalyst bed.
source subject to the work practice standards in subsection (3)(B) of this rule shall maintain, on-site, the work practice implementation plan and all records associated with fulfilling the Specific to the St. Louis Metropolitan Area
requirements of that plan, including, but not limited to:
operator training program is in place;
with the inspection and maintenance plan;
ing solvent accounting system;
tion 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 for each semiannual reporting period;
of compounds used for cleaning booth components, except for solvent used to clean conveyors, continuous coaters and their enclosures, and/or metal filters; and
tation developed to demonstrate that the other provisions of the work practice implementation plan are followed.
paragraph (4)(B)1. of this rule, the owner or operator of an affected source that complies through the method established in subparagraph (3)(C)1.A. or by demonstrating compliance with subsection (3)(A) of this rule shall maintain a copy of the compliance certifications submitted in accordance with paragraph (4)(A)3. of this rule for each semiannual period following the compliance date.
source shall maintain a copy of all other information submitted with the initial status report required by paragraph (4)(A)2. of this rule and the semiannual reports required by paragraph (4)(A)3. of this rule.
source shall maintain all records for a minimum of five (5) years.
required by paragraphs (4)(B)1. through (4)(B)6. of this rule constitutes a violation of the rule for each day records are not maintained.
(5) Test Methods.
(R) as the product of the capture and control device efficiencies, using the test methods cited in subsection (5)(C) of this rule and the procedure in subsection (5)(D) of this rule.
(C) Owners or operators using a control system shall demonstrate initial compliance using the following 40 CFR 60 methods as incorporated by reference in 10 CSR 10- 6.030(22).
air streams shall be determined with a test consisting of three (3) separate runs, each lasting a minimum of thirty (30) minutes using one (1) of the following reference methods:
determined by using one (1) of the following reference methods:
shall be determined by using one (1) of the following reference methods:
Method 3.
gas, use Method 4.
AUTHORITY: section 643.050, RSMo 2016.* Original rule filed July 15, 1999, effective Feb. 29, 2000. Amended: Filed May 9, 2018, effective Feb. 28, 2019. *Original authority: 643.050, RSMo 1965, amended 1972, 1992, 1993, 1995.