OAR 340-232-0220: Flat Wood Coating

(1) This rule applies to all flat wood manufacturing and surface finishing facilities that manufacture the following products: (a) Printed interior panels made of hardwood plywood and thin particleboard; (b) Natural finish hardwood plywood panels; or (c) Hardboard paneling with Class II finishes. (2) This rule does not apply to the manufacture of exterior siding, tileboard, particleboard used as a furniture component, or paper or plastic laminates on wood or wood-derived substrates. (3) No owner or operator of a flat wood manufacturing facility subject to this rule may emit VOCs from a coating application system in excess of: (a) 2.9 kilograms per 100 square meters of coated finished product (6.0 pounds/1,000 square feet) from printed interior panels, regardless of the number of coats applied; (b) 5.8 kilograms per 100 square meters of coated finished product (12.0 pounds/1,000 square feet) from natural finish hardwood plywood panels, regardless of the number of coats applied; and (c) 4.8 kilograms per 100 square meters of coated finished product (10.0 pounds/1,000 square feet) from Class II finishes on hardboard panels, regardless of the number of coats applied. (4) The emission limits in section (3) must be achieved by: (a) The application of low solvent content coating technology; or (b) An incineration system which oxidizes at least 90.0 percent of the non methane VOCs entering the incinerator (VOC measured as total combustible carbon) to carbon dioxide and water; or (c) An equivalent means of VOC removal. The equivalent means must be approved in writing by DEQ. The time period used to determine equivalency may not exceed 24 hours. (5) A capture system must be used in conjunction with the control devices in subsections (4)(b) and (c). The design and operation of a capture system must be consistent with good engineering practice and must provide for an overall emission reduction sufficient to meet the emission limitations in section (3). (6) Compliance Demonstration: (a) The owner or operator of a VOC source required to comply with this rule must demonstrate compliance by the methods of subsection (c), or an alternative method approved by DEQ; (b) A person proposing to conduct a VOC emissions test must notify DEQ of the intent to test not less than 30 days before the proposed initiation of the tests so DEQ may observe the test; (c) Test procedures in 40 CFR part 60, EPA Method 18, 24, or 25 must be used to determine compliance with section (3); (d) DEQ may accept, instead of the coating analysis required by paragraph (c)(A), a certification by the coating manufacturer of the composition of the coating, if supported by actual batch formulation records. In the event of any inconsistency between a Method 18, 24, or 25 test and a facility's formulation data, the Method 18, 24, or 25 test will govern; (e) If an add-on control device is used, continuous monitors of the following parameters must be installed, periodically calibrated, and operated at all times that the associated control device is operating: (A) Exhaust gas temperature of all incinerators; (B) Temperature rise across a catalytic incinerator bed; and (C) Breakthrough of VOC on a carbon absorption unit. [NOTE: This rule is included in the State of Oregon Clean Air Act Implementation Plan that EQC adopted under OAR 340-200-0040.] [NOTE: View a PDF of referenced EPA Methods by clicking on “Tables” link below OAR 340-232-8010.]