STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR RESOURCES

AIR POLLUTION CONTROL REGULATION NO. 35

CONTROL OF VOLATILE ORGANIC COMPOUNDS 

AND VOLATILE HAZARDOUS AIR POLLUTANTS

FROM WOOD PRODUCT MANUFACTURING OPERATIONS 

Effective 7 March 1996

Last Amended    19 July 2007

AUTHORITY:	These regulations are authorized pursuant to R.I. Gen. Laws
§ 42-17.1-2(s) and 23-23, as amended, and have been promulgated
pursuant to the procedures set forth in the R.I. Administrative
Procedures Act, R.I. Gen. Laws Chapter 42-35.

RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR RESOURCES

AIR POLLUTION CONTROL REGULATION NO. 35

CONTROL OF VOLATILE ORGANIC COMPOUNDS AND 

VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING
OPERATIONS

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc168800248"  35.1
Definitions	  PAGEREF _Toc168800248 \h  1  

  HYPERLINK \l "_Toc168800249"  35.2	Applicability	  PAGEREF
_Toc168800249 \h  7  

  HYPERLINK \l "_Toc168800250"  35.3	Emission Limitations for Finishing
Operations	  PAGEREF _Toc168800250 \h  8  

  HYPERLINK \l "_Toc168800251"  Table 2.   Emissions Limitations for
Finishing Materials	  PAGEREF _Toc168800251 \h  9  

  HYPERLINK \l "_Toc168800252"  35.4	Emission Limitations for Cleaning
and Gluing Operations	  PAGEREF _Toc168800252 \h  12  

  HYPERLINK \l "_Toc168800253"  35.5	Work Practice Standards	  PAGEREF
_Toc168800253 \h  12  

  HYPERLINK \l "_Toc168800254"  35.6	Compliance Procedures and
Monitoring Requirements	  PAGEREF _Toc168800254 \h  19  

  HYPERLINK \l "_Toc168800255"  35.7	Recordkeeping and Reporting	 
PAGEREF _Toc168800255 \h  25  

  HYPERLINK \l "_Toc168800256"  35.8	Performance Test Methods	  PAGEREF
_Toc168800256 \h  32  

  HYPERLINK \l "_Toc168800257"  35.9	General Provisions	  PAGEREF
_Toc168800257 \h  35  

  HYPERLINK \l "_Toc168800258"  TABLE 1.	LIST OF VOLATILE HAZARDOUS AIR
POLLUTANTS	  PAGEREF _Toc168800258 \h  38  

  HYPERLINK \l "_Toc168800259"  TABLE 3.	POLLUTANTS EXCLUDED FROM USE IN
CLEANING AND WASHOFF SOLVENTS	  PAGEREF _Toc168800259 \h  43  

 

RHODE ISLAND DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR RESOURCES

AIR POLLUTION CONTROL REGULATION NO. 35

CONTROL OF VOLATILE ORGANIC COMPOUNDS AND 

VOLATILE HAZARDOUS AIR POLLUTANTS FROM WOOD PRODUCTS MANUFACTURING
OPERATIONS

35.1	Definitions

	Unless otherwise expressly defined in this section, the terms used in
this regulation shall be defined by reference to the Rhode Island Air
Pollution Control General Definitions Regulation. As used in this
regulation, the following terms shall, where the context permits, be
construed as follows:

35.1. seq level2 \*arabic 1 .	"Adhesive" means a chemical substance that
is applied for the purpose of bonding two surfaces together other than
by mechanical means.

	35.1. seq level2 \*arabic 2 	"Alternative method" means a method of
sampling and analyzing for an air pollutant that is not a reference or
equivalent EPA sampling method but that has been demonstrated to the
EPA's satisfaction to, in specific cases, produce results adequate for a
determination of compliance.

	35.1. seq level2 \*arabic 3 .	"As applied" means the VOC, VHAP and
solids content of the coating material as it is used for coating the
substrate, including the contribution of thinners.

	35.1. seq level2 \*arabic 4 .	"Basecoat" means a coat of colored
material, usually opaque, that is applied before graining inks, glazing
coats, or other opaque finishing materials and is usually topcoated for
protection.

	35.1. seq level2 \*arabic 5 .	"Capture device" means a hood, enclosed
room, floor sweep, or other means of collecting solvent emissions or
other pollutants into a duct so that pollutants can be directed to a
pollution control device such as an incinerator or a carbon adsorber.

	35.1. seq level2 \*arabic 6 .	"Capture efficiency" means the fraction
of all organic vapors generated by a process that are directed to a
control device.

	35.1. seq level2 \*arabic 7 .	"Certified product data sheet" or "CPDS"
means documentation furnished by a coating supplier or an outside
laboratory that provides the VHAP content, VOC content, solids content,
and density of a finishing material, strippable booth coating, adhesive,
or solvent, measured using EPA Methods 24 and 311, or an equivalent or
alternative method (or formulation data if the coating meets the
criteria specified in Subsection 35.8.1(b)).  The purpose of the CPDS is
to assist the facility in demonstrating compliance with the emission
limitations presented in Sections 35.3, 35.4 and 35.5 of this
regulation.  Therefore, the VOC and VHAP content should represent the
maximum VOC and VHAP emission potential of the finishing material,
strippable booth coating, or solvent.

35.1. seq level2 \*arabic 8 .	"Cleaning operations" means operations in
which organic solvent is used to remove coating materials from equipment
used in wood products manufacturing operations.

	35.1. seq level2 \*arabic 9 .	"Coating" means a protective, decorative,
or functional material applied in a thin layer to a surface.  Such
materials include, but are not limited to, paints, topcoats, varnishes,
sealers, stains, washcoats, basecoats, adhesives, inks, enamels, and
temporary protective coatings.

35.1. seq level2 \*arabic 10  "Coating solids or solids" means the part
of a coating that remains after the coating is dried or cured; solids
content is determined using data from EPA Method 24.

35.1. seq level2 \*arabic 11  "Compliant coating" means a finishing
material, adhesive, or strippable booth coating that meets applicable
emission limitations specified in Section 35.3 and 35.4 of this
regulation.

35.1. seq level2 \*arabic 12  "Contact adhesive" means an adhesive that
is applied to two substrates, dried, and mated under only enough
pressure to result in good contact.  The bond is immediate and
sufficiently strong to hold pieces together without further clamping,
pressure, or airing.

35.1. seq level2 \*arabic 13  "Continuous coater" means a finishing
system that continuously applies finishing materials onto wood parts
moving along a conveyor system.  Finishing materials that are not
transferred to the part are recycled to the finishing material
reservoir.  Several types of application methods can be used with a
continuous coater including spraying, curtain coating, roll coating, dip
coating, and flow coating.

35.1. seq level2 \*arabic 14 . "Continuous compliance" means that the
facility is meeting the applicable emission limitations and other
applicable requirements of this regulation at all times and is
fulfilling all monitoring and recordkeeping provisions of the regulation
in order to demonstrate compliance.

35.1. seq level2 \*arabic 15 . "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.

35.1. seq level2 \*arabic 16 . "Control device efficiency" means the
ratio of the amount of pollutant released by a control device to the
amount of pollutant introduced to the control device, expressed as a
fraction.

35.1. seq level2 \*arabic 17 . "Control system" means the combination of
capture and control devices used to reduce emissions to the atmosphere.

35.1. seq level2 \*arabic 18 . "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 10 pounds per square inch
(gauge) at the point of atomization.  Airless, air assisted airless, and
electrostatic spray technologies are not considered conventional air
spray methods.

35.1. seq level2 \*arabic 19 . "Day" means a period of 24 consecutive
hours beginning at midnight local time, or beginning at a time
consistent with a facility's operating schedule.

35.1. seq level2 \*arabic 20 . "Disposed offsite" means sending used
organic solvent or coatings outside of the facility boundaries for
disposal.

35.1. seq level2 \*arabic 21 . "Emission" means the release or
discharge, directly or indirectly, of one or more air pollutants into
ambient air.

35.1. seq level2 \*arabic 22 . "Enamel" means a coat of colored, usually
opaque material that is applied as a protective topcoat over a basecoat,
primer, or previously applied enamel coats.  In some cases, another
finishing material may be applied as a topcoat over the enamel.

35.1.23 "Equipment leak" means emissions of VOC or VHAP from pumps,
valves, flanges, or other equipment used to transfer or apply finishing
materials, adhesives, or organic solvents.

35.1.24 "Equivalent method" means a method of sampling and analyzing for
an air pollutant that EPA has determined to have a consistent and
quantitatively known relationship to the reference method, under
specific conditions.

35.1.25 "Filler" means a finishing material which is applied to a wood
surface primarily to build up, or fill the voids and imperfections in,
the wood surface to be coated.  Edge filler is included in this
definition.

35.1.26 "Finishing application station" means the part of a finishing
operation where the finishing material is applied, e.g., a spray booth.

35.1.27 "Finishing material" means a coating other than an adhesive. 
For the wood products manufacturing industry, such materials include,
but are not limited to, basecoats, stains, washcoats, enamels, sealers,
and topcoats.

35.1.28 "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.

35.1.29 "Foam adhesive" means a contact adhesive used for gluing foam to
fabric, foam to foam, and fabric to wood.

35.1.30 "Gluing operation" means those operations in which adhesives are
used to join components, for example to apply a laminate to a wood
substrate or foam to fabric.

35.1.31 "High-solids stains" means stains containing more than one pound
of solids per gallon and includes wiping stains, glazes, and opaque
stains.

35.1.32 "Incinerator" means an enclosed combustion device that thermally
oxidizes volatile organic compounds to CO and CO2.  This term does not
include devices that burn municipal or hazardous waste material.

	35.1.33 "Ink" means a fluid that contains dyes and/or colorants and is
used to make markings, but not to protect surfaces.

35.1.34 "Low-solids stains" means stains containing one pound of solids
per gallon, or less.

35.1.35 "Major source of Hazardous Air Pollutants" means a facility that
emits or has the potential to emit, in the aggregate, 10 tons per year
(tpy) or more of any Hazardous Air Pollutant (HAP), 25 tpy or more of
any combination of HAPs, or such lesser quantity as the EPA may
establish by rule.

	35.1.36 "Malfunction" means any sudden, infrequent, and not reasonably
preventable failure of air pollution control equipment, process
equipment, or a process to operate in a normal or usual manner. 
Failures that are caused in part by poor maintenance or careless
operation are not malfunctions.

35.1.37 "Multi-colored coating" means a coating which exhibits more than
one color when applied, and which is packaged in a single container and
applied as a single coat.

35.1.38 "Nonpermanent final finish" means a material such as a wax,
polish, nonoxidizing oil, or similar substance that must be periodically
reapplied to a surface over its lifetime to maintain or restore the
reapplied material's intended effect.

35.1.39 "Operating day" means a day, or any part of a day, in which a
facility is engaged in manufacturing.

35.1.40 "Operating parameter value" means a minimum or maximum value
established for a control device or process parameter that, if achieved
by itself or in combination with one or more other operating parameter
values, determines that an owner or operator has complied with an
applicable emission limitation.

35.1.41 "Organic solvent" means a liquid containing VOC that is used for
dissolving or dispersing constituents in a coating, adjusting the
viscosity of a coating, cleaning, or washoff.  When used in a coating,
the organic solvent evaporates during drying and does not become a part
of the dried film.

35.1.42 "Overall control efficiency" means the efficiency of a control
system, calculated as the product of the capture and control device
efficiencies, expressed as a percentage.

35.1.43 "Permanent total enclosure" means a permanently installed
enclosure that completely surrounds a source of emissions such that all
emissions are captured and contained for discharge through a control
device.  The enclosure must meet applicable EPA criteria.

35.1.44 "Pigmented coating" means an opaque coating which contains
binders and colored pigments and which is formulated to hide the wood
surface, either as an undercoat or topcoat.

35.1.45 "Recycled onsite" means the reuse of an organic solvent at the
facility in a process other than cleaning or washoff.

35.1.46 "Sealer" means a finishing material used to seal the pores or
grains 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.

35.1.47 "Shutdown" means the cessation of operation of wood products
manufacturing operations for any purpose.

35.1.48 "Solvent" means a liquid used in a coating for dissolving or
dispersing constituents in a coating, adjusting the viscosity of a
coating, cleaning, or washoff. When used in a coating, it evaporates
during drying and does not become a part of the dried film.

35.1.49 "Stain" means any color coat having a solids content by weight
of not more than 8.0 percent that is applied in single or multiple coats
directly to the substrate.  Stains include, but are not limited to,
nongrain raising stains, equalizer stains, prestains, sap stains, body
stains, no-wipe stains, penetrating stains, and toners.

35.1.50 "Startup" means the setting in operation of wood products
manufacturing operations for any purpose.

35.1.51 "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.

35.1.52 "Substrate" means the surface onto which coatings are applied or
into which coatings are impregnated.

35.1.53 "Thinner" means a volatile liquid that is used to dilute
coatings to reduce viscosity, color strength, and solids, or to modify
drying conditions.

35.1.54 "Toner" means a stain which contains binders and dyes or
pigments to add tint to a coated surface or to even the color of an
initial application of stain.

35.1.55 "Topcoat" means the last film-building finishing material
applied in a finishing system.

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

35.1.57 "Volatile Hazardous Air Pollutant" and "VHAP" means any of the
substances listed in Table 1.

35.1.58 "Washcoat" means a transparent special purpose coating having a
solids content by weight of 12.0 percent or less.  Washcoats are
applied over initial stains to protect and control uniformity of color,
to stiffen the wood fibers, to prepare the wood surface for sanding, and
to partially seal the wood from subsequent staining operations.

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

35.1.60 "Wood products facility" means a facility which is engaged in
coating the surface of products manufactured of wood or wood products,
including, but not limited to, particle board, reed, rattan and wicker. 
Wood product coating does not include coating of flat wood panels, as
defined in Air Pollution Control Regulation No. 19.

35.1.61 "Wood products manufacturing operations" means the finishing,
gluing, cleaning and washoff operations conducted at a wood products
facility.

35.2	Applicability

35.2.1	The provisions of this regulation apply to any wood products
facility which has the potential to emit 25 tons per year or more of
volatile organic compounds (VOC) from wood products manufacturing
operations or which is located at a major source of Hazardous Air
Pollutants (HAP).

	35.2.2	The owner or operator of a wood products facility which has
emissions below the applicability thresholds specified in Subsection
35.2.1 but above 15 pounds of VOC in any day shall comply with the
recordkeeping and reporting requirements in Paragraphs (a) and (c) of
Subsection 35.7.1 but the facility shall not be subject to any other
provisions of this regulation.  If the facility becomes subject to the
regulation at a future date due to an increase in emissions of VOC or
VHAP, the facility shall be subject to applicable requirements in this
regulation on and after the date that the applicability thresholds are
reached or the date that the applicable requirement becomes effective,
whichever is later.

	35.2.3	Where ever the term Volatile Organic Compound or VOC is used in
Sections 35.2 through 35.8 and Subsections 35.1.3, 35.1.7, 35.1.23, and
35.1.41, this term should be read as Volatile Organic Compound and
Halogenated Organic Compound or VOC and HOC.

	35.2.4	The owner or operator of a facility which is a major source of
Hazardous Air Pollutants (HAP) but which has not emitted more than
10 tons of any one HAP or more than 25 tons of any combination of HAP,
including emissions from source categories other than wood products, in
any 12 month period since December 1994 may apply to the Director for an
exemption from the VHAP emissions limitations in Subsections 35.3.2,
35.3.3, 35.4.2 and 35.4.3 of this regulation.  Exemption will be given
in the form of an enforceable document, and will include the following
conditions:

		(a)	Average monthly emissions from the facility in any consecutive
twelve month period shall not exceed 1,666 pounds of any one HAP or
4,166 pounds of any combination of HAP; and

		(b)	The following records shall be maintained at the facility for a
period of five years and made available to the Department or the EPA
upon request:

			(1)	The name, identification number, and amount of each finishing,
gluing and washoff material used each month at the facility; and

			(2)	Certified Product Data Sheets showing the VOC and VHAP content of
each finishing, gluing, and washoff material used at the facility; and

			(3)	The type and amount of solvent used as thinners and in cleaning
operations each month at the facility;

			(4)	The average monthly emissions of each HAP from the facility,
calculated monthly for the previous twelve month period.

		(c)	If the limit in Paragraph 35.2.4.(a) is exceeded, applicable VHAP
emission limitations specified in Sections 35.3 and 35.4 shall
immediately apply.

35.3	Emission Limitations for Finishing Operations

	35.3.1	VOC Emission Limitations for Finishing Operations

		(a)	On and after March 7, 1996, the owner or operator of a facility
subject to this regulation which has the potential to emit greater than
or equal to 25 tons per year of volatile organic compounds (VOC) shall
limit VOC emissions from wood products finishing operations by:

			(1)	Using finishing materials which comply with the emissions
limitations in pounds of VOC per gallon of coating minus water and
exempt compounds listed in Table 2; or

			(2)	Using a control system that achieves the emissions limitations in
pounds of VOC per pound of solids listed in Table 2; or

			(3)	Using finishing materials with a weighted average VOC content,
within a particular category of coatings as identified in Table 2, which
conforms with the provisions specified in Subsection 35.6.2(a); or

			(4)	Using a combination of the methods presented in Paragraphs
35.3.1(a)(1), 35.3.1(a)(2), and 35.3.1(a)(3) which is approved by the
Department.

Table 2.   Emissions Limitations for Finishing Materials

 PRIVATE  COATING CATEGORY	lbs VOC/

gal coating minus water and exempt compounds	 lbs VOC/  

lb solids

clear topcoats containing HOC	4.6	  1.2

clear topcoats not containing HOC	5.7	  2.5

fillers	4.2	  1.0

high-solids stains	5.8	  2.7

low-solids stains, toners and washcoats containing HOC	4.0	  0.9

low-solids stains, toners and washcoats not containing HOC	6.7	  7.5

inks	4.2	  1.0

multi-colored coatings	5.7	  2.5

pigmented coatings	5.0	  1.6

sealers containing HOC	4.6	  1.2

sealers not containing HOC	5.7	  2.5



		(b)	In addition to complying with the limitations in Table 2, on and
after March 7, 1998, the owner or operator of a facility subject to this
regulation which has the potential to emit greater than or equal to 25
tons per year of VOC shall:

			(1)	Use topcoats containing no more than 1.8 lbs VOC/lb solids, as
applied, and sealers containing no more than 1.9 lbs VOC/lb solids, as
applied; or

			(2)	Use waterborne topcoats with a VOC content no greater than 0.8 lb
VOC/lb solids, as applied; or

			(3)	Use a control system that achieves equivalent reductions in VOC
emissions from topcoats and sealers.

		(c)	A facility subject to the emissions limits in Table 2 may be
required, at the discretion of the Department, to undergo a review every
two years to determine whether the limitations in Paragraphs (a) and (b)
of this subsection represent Reasonably Available Control Technology
(RACT) for the finishing operations at that facility at that time. 
Facilities shall comply with emissions limitations determined to be RACT
within one year of that determination and shall thereafter operate in
compliance with those limitations.

	35.3.2	VHAP Emission Limitations for Finishing Operations at Existing
Facilities

		(a)	On and after March 7, 1998, the owner or operator of a facility
subject to this regulation which is a major source of HAP and which
began operations before December 6, 1994 shall limit VHAP emissions from
wood products finishing operations by:

			(1)	Using stains, washcoats, sealers, topcoats, basecoats, and
enamels with VHAP contents no higher than 1.0 lb VHAP/lb solids, as
applied; thinners for stains, sealers, and topcoats that contain no more
than 10% VHAP by weight; and thinners for washcoats, basecoats and
enamels that contain no more than 3% VHAP by weight; or

			(2)	Using finishing materials with a weighted average VHAP content of
no greater than 1.0 lb VHAP/lb solids, as applied, calculated using the
procedures in Subsection 35.6.2(b), and thinners with VHAP contents as
specified in Paragraph 35.3.2(a)(1); or

			(3)	Using a control system that achieves a reduction in emissions
equivalent to that which would be achieved by complying with the
requirements of Paragraph (1) or (2) of this subsection, calculated
according to the procedures in Subsection 35.6.3(c) of this regulation;
or

			(4)	Using a combination of the methods presented in Paragraphs (1)
and (3) of this subsection which is approved by the Department.

		(b)	The formaldehyde content of a finishing material shall be
calculated as the amount of free formaldehyde present in the finishing
material when it is applied.

		(c)	The styrene content of a finishing material shall be based on an
estimate of unreacted styrene, which shall be calculated by multiplying
the amount of styrene monomer in the finishing material when it is
applied by a factor of 0.16.

	35.3.3	VHAP Emission Limitations for Finishing Operations at New
Facilities

		(a)	On and after March 7, 1996, the owner or operator of a facility
subject to this regulation which is a major source of HAP and began
operation on or after December 6, 1994 shall limit VHAP emissions from
wood products finishing operations by:

			(1)	Using stains with VHAP contents no greater than 1.0 lb VHAP/lb
solids, as applied; washcoats, sealers, topcoats, basecoats, and enamels
with VHAP contents no greater than 0.8 lb VHAP/lb solids, as applied;
thinners for stains, sealers, and topcoats that contain no more than 10%
VHAP by weight; and thinners for washcoats, basecoats and enamels that
contain no more than 3% VHAP by weight; or

			(2)	Using finishing materials with a weighted average VHAP content of
no greater than 0.8 lb VHAP/lb solids, as applied, calculated using the
procedures in Subsection 35.6.2(b), and thinners with VHAP contents as
specified in Paragraph 35.3.3(a)(1); or

			(3)	Using a control system that achieves a reduction in emissions
equivalent to that which would be achieved by complying with the
requirements of Paragraph (1) or (2) of this subsection, calculated
according to the procedures in provisions in Subsection 35.6.3(c) of
this regulation; or

			(4)	Using a combination of the methods presented in Paragraphs (1)
and (3) of this subsection which is approved by the Department.

		(b)	The formaldehyde content of a finishing material shall be
calculated as the amount of free formaldehyde present in the finishing
material when it is applied.

		(c)	The styrene content of a finishing material shall be based on an
estimate of unreacted styrene, which shall be calculated by multiplying
the amount of styrene monomer in the finishing material when it is
applied by a factor of 0.16.

35.4	Emission Limitations for Cleaning and Gluing Operations

	35.4.1	VOC Emission Limitations for Cleaning Operations

	On and after March 7, 1996, any strippable booth coating used at a
facility subject to this regulation must contain no more than 0.8 lb
VOC/lb solids, as applied.

	35.4.2	VHAP Emission Limitations for Existing Gluing Operations

	On and after March 7, 1996, the owner or operator of a facility subject
to this regulation which is a major source of HAP and which began
operation before December 6, 1994 shall limit VHAP emissions from
contact adhesives used in gluing operations as follows:

		(a)	 For foam adhesives used in products that meet the upholstered
seating flammability requirements of California Technical Bulletin 116,
117, or 133, the Business and Institutional Furniture Manufacturers
Association's (BIFMA's) X5.7, UFAC flammability testing, or any similar
requirements from local, State, or Federal fire regulatory agencies, the
VHAP content of the adhesive shall not exceed 1.8 lb VHAP/lb solids, as
applied;

		(b)	For all other contact adhesives, including foam adhesives used in
products that do not meet the standards presented in Paragraph (a) of
this subsection, the VHAP content of the adhesive shall not exceed
1.0 lb VHAP/lb solids, as applied; or

		(c)	By using a control system that will achieve a reduction in VHAP
emissions equivalent to that which would be achieved by complying with
the requirements of Paragraph (b) of this subsection, as calculated
using the procedures in Subsection 35.6.3(d) of this regulation.

	35.4.3	VHAP Emission Limitations for New Gluing Operations

	On and after March 7, 1996, the owner or operator of a facility subject
to this regulation which is a major source of HAP and which began
operation on or after December 6, 1994 shall not use contact adhesives
which have VHAP contents higher than 0.2 lb VHAP/lb solids, as applied
or shall use a control system that achieves an equivalent reduction in
emissions of VHAP, as calculated using the procedures in Subsection
35.6.3(d).

35.5	Work Practice Standards

	The owner or operator of a facility subject to this regulation shall
implement the following work practice standards by March 7, 1996, except
where another date is specified.

	35.5.1	Work Practice Implementation Plan

		(a)	The owner or operator of a facility subject to this regulation
shall prepare and maintain a written work practice implementation plan
that defines work practices for each wood products manufacturing
operation and addresses each of the topics specified in Subsections
35.5.2 through 35.5.10.

		(b)	The work practice implementation plan shall be developed by May 6,
1996 and shall be subject to the approval of the Department.

		(c)	The owner or operator of the facility shall comply with each
provision of the work practice implementation plan.

		(d)	The work practice implementation plan shall be available for
inspection by the EPA or the Department upon request and shall be
modified by the facility if found to be inadequate.

	35.5.2	Operator Training Course

		(a)	Each owner or operator of a facility subject to this regulation
shall train all new and existing personnel, including contract
personnel, who are involved in finishing, gluing, cleaning, or washoff
operations, use of manufacturing equipment, or implementation of the
requirements of this regulation.

		(b)	All personnel shall be trained by November 6, 1996, or upon
hiring, whichever is later.  All personnel shall be given refresher
training annually.

		(c)	Initial and refresher trainings shall include, at a minimum, the
following topics:

			(1)	Appropriate application techniques;

			(2)	Appropriate cleaning and washoff procedures;

			(3)	Appropriate equipment setup and adjustment to minimize finishing
material usage and overspray; and

			(4)	Appropriate management of cleanup wastes.

		(d)	The facility shall maintain records of the training program. 
Records shall include, at a minimum, the following:

			(1)	A list of all current personnel by name and job description who
are required to be trained and a record of the date that each employee
was trained;

			(2)	An outline of the subjects covered in the initial and refresher
training for each position, or group of personnel;

			(3)	Lesson plans for courses to be given at the initial and the
annual refresher training that include, at a minimum, the topics
specified in Paragraph (c) of this subsection; and

			(4)	A description of the methods to be used to demonstrate successful
completion of initial and refresher training.

	35.5.3	Equipment Operation, Maintenance, Inspection and Repair

		(a)	Equipment Leak Inspection and Repair   

			(1)	After March 6, 1996, all equipment used to transfer or apply
finishing materials, adhesives, or organic solvents shall be visually
inspected for leaks at least once per month.

			(2)	A first attempt at repair shall be made no later than 3 calendar
days after a leak is detected and final repairs shall be made within 10
calendar days, unless the leaking equipment is to be replaced by a new
purchase, in which case repairs shall be completed within 3 months.

			(3)	Each owner or operator of a source subject to this regulation
shall prepare and maintain a written leak inspection and maintenance
plan that includes:

				(i)	A schedule for conducting visual inspections required in
Paragraph (a) of this subsection; and

				(ii)	A log documenting the date and results of each inspection and
any repairs that are made.

		(b)	Operation and Maintenance Requirements

			(1)	At all times, including periods of startup, shutdown, and
malfunction, owners or operators shall operate and maintain any
equipment associated with wood products manufacturing operations,
including associated air pollution control equipment, in a manner
consistent with good air pollution control practices for minimizing
emissions.

			(2)	Malfunctions shall be corrected as soon as practicable after
their occurrence in accordance with the startup, shutdown, and
malfunction plan required in Paragraph (b)(4) of this subsection.

			(3)	The Department will determine whether acceptable operation and
maintenance procedures are being used, based on information which may
include, but is not limited to, monitoring results, review of operation
and maintenance procedures (including the startup, shutdown, and
malfunction plan required in Paragraph (b)(4) of this subsection),
review of operation and maintenance records, and inspection of the
facility.

			(4)	The owner or operator of a facility subject to this regulation
shall develop and implement a written startup, shutdown, and malfunction
plan that describes, in detail, procedures for operating and maintaining
equipment associated with wood products manufacturing operations during
periods of startup, shutdown, and malfunction and a program of
corrective action for malfunctioning process and air pollution control
equipment used to comply with this regulation.  The facility's standard
operating procedures (SOP) manual, an Occupational Safety and Health
Administration (OSHA) or another plan can be used to fulfill this
requirement, provided the plan meets all the requirements of this

			paragraph.  Startup, shutdown, and malfunction plans shall be
maintained at the facility and made available to the Department or the
EPA for review upon request and shall be revised if determined to be
unacceptable.

			(5)	During periods of startup, shutdown, and malfunction, the owner
or operator of a facility subject to this regulation shall operate and
maintain equipment associated with wood products manufacturing
operations (including associated air pollution control equipment) in
accordance with the procedures specified in the startup, shutdown, and
malfunction plan developed according to the provisions of
Paragraph (b)(4) of this subsection.

			(6)	The owner or operator of a facility subject to this regulation
shall keep records of action taken during startups, shutdowns, and
malfunctions, including actions taken to correct malfunctions and shall
certify, in the semi-annual reports required in Subsection 35.7.7, that
all such actions were consistent with the procedures specified in the
facility's startup, shutdown and malfunction plan developed under
Paragraph (b)(4) of this subsection

.

			(7)	If actions taken by the owner or operator during a startup,
shutdown, or malfunction (including an action taken to correct a
malfunction) are not consistent with the procedures specified in the
facility's startup, shutdown, and malfunction plan, the owner or
operator shall record the actions taken and report such actions to the
Office of Air Resources within 2 working days after beginning actions
inconsistent with the plan, followed by a letter within 7 working days
after the end of the event.

			(8)	If a malfunction occurs that was not adequately addressed in the
startup, shutdown, and malfunction plan, the owner or operator shall
revise the plan within 45 days after the event to include detailed
procedures for operating and maintaining the source during similar
malfunction events and a program of corrective action for similar
malfunctions of process or air pollution control equipment.

	35.5.4	Cleaning and Washoff Solvent Requirements

		(a)	The owner or operator of a facility subject to this regulation
shall account for organic solvent use in cleaning and washoff operations
by recording the following information:

			(1)	The quantity and types of organic solvent used in washoff and
cleaning operations each month;

			(2)	The number of pieces washed off, and the reason for the washoff;
and

			(3)	The quantity of spent organic solvent generated from each washoff
and cleaning activity each month, and whether it is recycled onsite or
disposed offsite.

		(b)	Facilities subject to this regulation shall not use cleaning or
washoff solvents that contain any of the pollutants listed in Table 3 in
concentrations greater than 0.1%.

	35.5.5	Spray Booth Cleaning

	Facilities subject to this regulation shall not use compounds
containing more than 8.0 percent by weight of VOC for cleaning spray
booth components other than conveyors, continuous coaters and their
enclosures, 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 facility shall use no more than 1.0 gallon of organic
solvent per booth to prepare the booth prior to applying the booth
coating.

	35.5.6	Storage Requirements

	All finishing, gluing, cleaning, and washoff materials shall be stored
in containers that are closed at all times except when material is being
added or removed.

	35.5.7	Application Equipment Requirements

	Conventional air spray guns shall not be used to apply finishing
materials, except in the following situations:

		(a)	When applying finishing materials before March 6, 1998 at a
facility which is not a major source of HAP or which began operation
prior to December 6, 1994;

		(b)	When applying finishing materials that have a VOC content no
greater than 1.0 lb VOC/lb solids, as applied;

		(c)	Touch-up or repair that occurs after the completion of a finishing
operation;

		(d)	Touch-up or repair that occurs after the stain and before any
other type of finishing material is applied, provided that the touch-up
finishing materials are applied from a container that has a volume of no
more than 2.0 gallons;

		(e)	If the spray gun is aimed and triggered automatically, not
manually;

		(f)	If emissions from the finishing application station are directed
to a control device;

		(g)	For application of a finishing material if the total usage of that
finishing material is no more than 5.0 percent of the total gallons of
all finishing materials used at that facility during that semi-annual
reporting period, as specified in Subsection 35.7.7(a).; or

		(h)	The application of stain on a part for which it is technically or
economically infeasible to use any other spray application technology. 
The facility must demonstrate technical or economic infeasibility by
submitting documentation to the Department that the following criteria,
either independently or in combination, are met:

			(1)	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

			(2)	The excessively large vertical spray area of the part makes it
difficult to avoid sagging or runs in the stain.

	35.5.8	Line Cleaning

	All organic solvent used for line cleaning shall be pumped or drained
into a container that is closed at all times except when material is
being added or removed.

	35.5.9	Gun Cleaning

	All organic solvent used to clean spray guns shall be collected in a
container that is closed at all times except when material is being
added or removed.

	35.5.10  Washoff operations

	Emissions from washoff operations shall be controlled by:

		(a)	Using tanks for washoff that are closed at all times except when
material is being added or removed; and

		(b)	Minimizing dripping by tilting or rotating the part to drain as
much organic solvent as possible.

	35.5.11  Formulation Assessment Plan

	Each owner or operator of a facility that is subject to this regulation
and that is a major source of Hazardous Air Pollutants shall prepare and
maintain a formulation assessment plan that:

		(a)	Lists all VHAP from Table 1 that are being used in finishing
operations at the facility.

		(b)	Establishes a baseline level of usage by the facility for each
VHAP as follows:

			(1)	The baseline usage level shall be the annual usage from the
calendar year 1994 for each VHAP;

			(2)	For formaldehyde, the baseline level of usage shall be based on
the amount of free formaldehyde present in the finishing material when
it is applied;

			(3)	For styrene, the baseline level of usage shall be an estimate of
unreacted styrene, which shall be calculated by multiplying the amount
of styrene monomer in the finishing material when it is applied by a
factor of 0.16; and

			(4)	Facilities using a control device to reduce emissions may adjust
their baseline usage based on the overall control efficiency of the
control system, calculated using Equation 5 in Paragraph 35.6.3(c).

			(5)	The baseline levels for a VHAP that was not used in 1994 shall be
established as 20% of the Reportable Quantity for that substance
specified in Table III of Regulation No. 22.

		(c)	Tracks the annual usage of each VHAP used by the facility.

		(d)	If, beginning with the calendar year 1998, the usage of a VHAP in
any year exceeds its baseline level, then the owner or operator of the
facility shall provide a written notification to the Division by 31
January of the following year that specifies the amount of the increase
and explains the reasons for the increase.  The Department will
determine whether the increase would cause an exceedance of the
Acceptable Ambient Levels specified in Air Pollution Control Regulation
No. 22.  If Regulation No. 22 limits are exceeded, the Department will
develop a timetable for the facility to achieve compliance and a
schedule for submitting notification of progress.

35.6	Compliance Procedures and Monitoring Requirements

	35.6.1	Compliance Using Compliant Coatings

	Compliance with the emissions limitations in Sections 35.3 and 35.4 of
this regulation through the use of compliant coatings shall be
demonstrated by the following methods:

		(a)	Maintaining Certified Product Data Sheets (CPDS) documenting that
the VOC and/or VHAP content of each topcoat, filler, stain, toner, ink,
multi-colored coating, pigmented coating, sealer, washcoat, enamel,
basecoat, thinner, adhesive and strippable booth coating meets the
applicable emissions limitations in Sections 35.3 and 35.4 in lb
VOC/gallon of coating or lb VHAP/lb of solids; and

		(b)	Maintaining formulation data and related calculations showing that
the VOC and VHAP content of each topcoat, filler, stain, toner, ink,
multi-colored coating, sealer, washcoat, enamel, basecoat, adhesive and
strippable booth coating diluted onsite, as applied, meets the
applicable emissions limitations in Sections 35.3 and 35.4 in lb
VOC/gallon of coating or lb VHAP/lb of solids; and

		(c)	For facilities with continuous coaters, using one of the following
procedures:

			(1)	Calculating the VOC and VHAP content, as applicable, of the
finishing material in the reservoir from information on the CPDS and
records of materials added to the reservoir; or

			(2)	Monitoring the viscosity of the finishing material in the
reservoir with a viscosity meter or testing the viscosity of the initial
finishing material and retesting the material in the reservoir each time
solvent is added.  If this option is chosen, the facility shall maintain
data that demonstrates the correlation between the viscosity of the
finishing material and the VOC and VHAP content, as applicable, of the
finishing material; and

		(d)	The Department or EPA will determine compliance either by
reviewing the records specified in Paragraphs (a), (b) and (c) of this
subsection or by conducting a performance test according to the
specifications in Subsections 35.8.1 and 35.8.2.  If the VOC or VHAP
content of a coating determined by a performance test using the
procedures specified in Subsections 35.8.1 and 35.8.2 is greater than
that indicated on a CPDS or by the facility's formulation or viscosity
data, the performance test results shall govern.

	35.6.2	Compliance Using Averaging

		(a)	To demonstrate compliance with the VOC emission limitations in
Subsection 35.3.1 for a particular coating category through the use of
averaging, the owner or operator of a facility shall, each week:

Calculate the average VOC content for all coatings in that category used
at the facility using Equation 1:

	n	       n

= (∑  ViCi ) /  (  Vi			Equation 1

	i=I	       i=I

		Where:	EVOC = the average VOC content of coatings in a particular
coating category, in lb VOC/gal coating, as applied;

				C   =  the VOC content of a coating in the coating category, in lb
VOC/gal coating minus water and exempt compounds, as applied;

				i   =  subscript denoting an individual coating;

				V   =  the volume of coating, in gallons, as applied, of a
particular coating in the coating category used during the weekly
averaging period;

			(2)	Demonstrate that the value calculated for EVOC is no greater than
0.9 times the emission limitation, in lbs VOC/gallon coating minus water
and exempt compounds, as applied, for that coating category, as listed
in Table 2.

		(b)	To demonstrate compliance with the VHAP emission limitations in
Subsections 35.3.2 and 35.3.3 through the use of averaging, the owner or
operator of a facility shall, each month:

			(1)	Calculate the average VHAP content for all finishing materials
used at the facility using Equation 2:

		              n	             n               n

		EVHAP = (  (  MiC1  +  (  SiWi ) /  (  Mi            		Equation 2

		             i=1	    i=1             i=1 

		Where:	EVHAP = the average VHAP content of finishing materials, in lb
VHAP/lb solids; 

				C    = the VHAP content of a coating, in lb VHAP/lb solids, as
applied;

				i    = subscript denoting an individual coating; 

				M    = the mass of solids, in pounds, in a particular finishing
material used during the monthly averaging period;

				S    = the VHAP content of a solvent, expressed as a weight
fraction, added to finishing materials; and

				W    = the amount of solvent, in pounds, added to finishing
materials during the monthly averaging period.  

			(2)	Demonstrate that the value calculated for EVHAP is no greater
than 1.0 if the facility is complying with Subsection 35.3.2 and is no
greater than 0.8 if the facility is complying with Subsection 35.3.3.

	35.6.3	Initial Compliance Using Control Equipment

		(a)	The owner or operator of a facility which uses control equipment
to comply with the VOC emission limitations in Table 2 or the VHAP
limitations in Subsections 35.3.3 and/or 35.4.3 shall conduct an initial
performance test to measure the capture and control efficiency of the
control system using the procedures specified in Subsection 35.8.3 by
June 4, 1996.  Initial performance tests for control equipment which is
being used to comply with the VHAP emission limitations in Subsections
35.3.2 and/or 35.4.2 or the VOC emissions limitations for sealers and
clear topcoats in Paragraph 35.3.1(b) shall be conducted by September 8,
1998.

		(b)	Initial compliance with VOC emission limitations for finishing
materials through the use of a control system shall be determined as
follows:

			(1)	Calculate the overall control efficiency needed (Rn) for each
finishing material which will be controlled by the control equipment
using the following equation:

		Rn = [(C - EL)/C](100)       				Equation 3

		Where:	Rn = the overall efficiency of the control system needed,
expressed as a percentage.

				C = the VOC content of a coating, in lb VOC/lb solids, as applied;

				EL = the emission limitation required for the coating, from Table 2,
in lb VOC/lb solids.

			(2)	Document that the value of C used in Equation 3 was calculated
from the VOC and solids content of the as-applied finishing material.

			(3)	Demonstrate, for all applicable coatings, that the value of Rn
calculated using Equation 3 is less than or equal to the actual overall
control efficiency (Ra) calculated by substituting the capture
efficiency (N) and control efficiency (F) of the control system measured
in the initial performance test into Equation 4.

		Ra = (F x N)(100)						Equation 4

		(c)	Initial compliance with VHAP emission limitations for finishing
materials through the use of a control system shall be determined as
follows:

			(1)	Calculate the overall control efficiency needed, Rn, so that the
value of Eac in Equation 5 is no greater than 1.0 if complying with
Subsection 35.3.2 and so that the value of Eac in Equation 5 is no
greater than 0.8 if complying with Subsection 35.3.3;

		Rn = (100)(Ebc - Eac)/Ebc 	      				Equation 5

		Where:	Rn = the overall efficiency of the control system needed,
expressed as a percentage;

				Eac = emissions from an emission point or a set of emission points
after control equipment is in operation, in lb VHAP/lb solids; and

				Ebc = emissions from an emission point or set of emission points
before controls, calculated as EVHAP in Equation 2.

			(2)	Demonstrate that the value of Rn calculated using Equation 5 is
less than or equal to the actual overall control efficiency (Ra)
calculated using the capture efficiency (N) and control efficiency (F)
of the control system measured in the initial performance test and
Equation 4.

		(d)	Initial compliance with VHAP emission limitations for gluing
materials through the use of a control system shall be determined as
follows:

			(1)	Calculate the overall control efficiency of the control system
needed (Rn) so that the value of Gac in Equation 6 is no greater than
1.0 if complying with Subsection 35.4.2 and 0.2 if complying with
Subsection 35.4.3;

		Rn = (100)(Gbc - Gac)/Gbc)       				Equation 6

		Where:	Rn = the overall efficiency of the control system needed,
expressed as a percentage;

				Gac = emissions from the gluing operation after control equipment,
in lb VHAP/lb solids; and

				Gbc = emissions from the gluing operation before controls, in lb
VHAP/lb solids.

			(2)	Demonstrate that the value of Rn calculated using Equation 6 is
less than or equal to the actual overall control efficiency (Ra)
calculated using the capture efficiency (N) and control efficiency (F)
of the control system measured in the initial performance test and
Equation 4.

	35.6.4	Continuous Compliance Using Control Equipment

		(a)	The owners or operator of a facility that is complying with the
emission limitations in this regulation through the use of a control
system shall demonstrate continuous compliance by installing,
calibrating, maintaining, and operating appropriate monitoring equipment
according to manufacturers' specifications.

		(b)	The monitoring equipment installed pursuant to Paragraph (a) of
this subsection shall measure operating parameters which indicate
ongoing compliance with the control efficiency requirements in this
regulation.

		(c)	Where a thermal incinerator is used, the operating parameter to be
monitored shall be minimum combustion temperature, and a temperature
monitoring device equipped with a continuous recorder shall be installed
in the firebox or in the ductwork immediately downstream of the firebox
in a position before any substantial heat exchange occurs.

		(d)	Where a catalytic incinerator equipped with a fixed catalyst bed
is used, the operating parameter to be monitored shall be the minimum
gas temperature upstream and downstream of the catalyst bed and
temperature monitoring devices equipped with continuous recorders shall
be installed in the gas stream immediately before and after the catalyst
bed.

		(e)	Where a catalytic incinerator equipped with a fluidized catalyst
bed is used, the operating parameters to be monitored shall be the
minimum gas temperature upstream of the catalyst bed and the pressure
drop across the catalyst bed, and temperature monitoring devices
equipped with continuous recorders shall be installed in the gas stream
immediately before the bed.  In addition, a pressure monitoring device
shall be installed to determine the pressure drop across the catalyst
bed.  A constant pressure drop, as measured monthly at a constant flow
rate, shall be maintained.

		(f)	Where a carbon adsorber is used, the operating parameters to be
monitored 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 Department and the EPA to establish other operating
parameters.  One of the following devices is required to monitor these
parameters:

			(1)	An integrating regeneration stream flow monitoring device having
an accuracy of +10 percent, capable of recording the total regeneration
stream mass flow for each regeneration cycle; and a carbon bed
temperature monitoring device having an accuracy of +1 percent of the
temperature being monitored expressed in degrees Celsius or +0.5o C,
whichever is greater, capable of recording the carbon bed temperature
after each regeneration and within 15 minutes of completing any cooling
cycle;

			(2)	An organic monitoring device, equipped with a continuous
recorder, to indicate the concentration level of organic compounds
exiting the carbon adsorber; or

			(3)	Another monitoring device that has been approved by the
Department and the EPA.

		(g)	A facility using a control device not listed in this section to
comply with this regulation shall submit to the Office of Air Resources
a description of the device, test data verifying the performance of the
device, and appropriate operating parameter values that will be
monitored to demonstrate continuous compliance with the standard. 
Compliance using this device is subject to the approval of the
Department and the EPA.

		(h)	Operating parameter values indicating compliance shall be
calculated as the arithmetic average of the maximum or minimum value of
those parameters, as appropriate, measured during the three test runs of
the initial performance test, provided that the initial performance test
demonstrated compliance.

		(i)	The capture or control device shall be operated so that the
average of all values for a monitored parameter recorded during each
operating day is in compliance with the operating parameter value
calculated according to the procedures in Paragraph (h) of this
subsection.

35.7	Recordkeeping and Reporting

	35.7.1	The owner or operator of a facility subject to this regulation
shall maintain the following records for a period of five years:

		(a)	A certified product data sheet (CPDS) for each finishing material,
thinner, adhesive, and strippable booth coating subject to the emission
limitations in this regulation;

		(b)	As applicable, the VOC content in lb VOC/gallon of coating, as
applied and the VHAP content, in lb VHAP/lb of solids, as applied, of
each coating subject to the emission limitations in this regulation, and
copies of calculations documenting how the as-applied values were
determined.  The VOC content of strippable booth coatings shall be
expressed in units of lb VOC/lb solids, as applied.

		(c)	The amount and type of each coating and thinner used at the
facility each month.

		(d)	If viscosity measurements are used to track VOC and/or VHAP
concentrations: 

			(1)	Records of dates and amounts of solvent and finishing material
added to the continuous coater reservoir;

			(2)	Records of dates and results of viscosity measurements; and

			(3)	Data demonstrating that viscosity is an appropriate parameter for
demonstrating compliance.

	35.7.2	The owner or operator of a facility using weekly averaging to
comply with the VOC emissions limitations in Subsection 35.3.1 or
monthly averaging to comply with the VHAP emissions limitations in
Subsection 35.3.2 or 35.2.3 shall maintain the calculations of EVOC and
EVHAP required in Subsection 35.6.2 for a period of 5 years.

	35.7.3	The owner or operator of a source using control equipment to
comply with the emissions limitations in this regulation shall maintain
the following records for a period of five years:

		(a)	Copies of calculations of EVHAP from Equation 2 and Rn from
Equation 3, 5 and 6, as applicable;

		(b)	Records of the daily average value of each continuously monitored
operating parameter for each operating day.  If all recorded values for
a monitored parameter during an operating day 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

		(c)	Records of the pressure drop across the catalyst bed for
facilities complying with the emission limitations using a catalytic
incinerator with a fluidized catalyst bed.

	35.7.4	The owner or operator of a facility subject to this regulation
shall maintain onsite the work practice implementation plan and for five
years shall maintain onsite all records associated with fulfilling the
requirements of that plan, as specified in Section 35.5, including, but
not limited to:

		(a)	Records demonstrating that the operator training program is in
place;

		(b)	Records maintained in accordance with the equipment leak
inspection and maintenance plan and startup, shutdown, and malfunction
plan;

		(c)	Records associated with the cleaning solvent accounting system;

		(d)	Records associated with the limitation 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
reporting period;

		(e)	Records associated with the formulation assessment plan;

		(f)	Records showing the VOC content of compounds used for cleaning
booth components, except for solvent used to clean conveyors, continuous
coaters and their enclosures, and/or metal filters;

		(g)	A copy of logs and other documentation developed to demonstrate
that the provisions of the work practice implementation plan are
followed; and 

		(h)	A copy of the compliance certifications, and periodic reports
submitted in accordance with the requirements of this regulation.

	35.7.5	Initial Notifications

		(a)	The owner or operator of a facility subject to this regulation
which was constructed before December 7, 1995 and which is a major
source of HAP shall submit a Initial Notification to the Division by
September 2, 1996 or within 30 days of becoming a major source of HAP,
whichever is later.  Initial Notifications for facilities constructed
before December 7, 1995 shall include the following information:

			(1)	The name and address of the owner or operator;

			(2)	The address (i.e., physical location) of the facility;

			(3)	An identification of the relevant standard, or other requirement,
that is the basis of the notification and the facility's compliance
date;

			(4)	A brief description of the nature, size, design, and method of
operation of the facility, including its operating design capacity and
an identification of each point of emission for each HAP, or, if a
definitive identification is not yet possible, a preliminary
identification of each point of emission for each HAP; 

			(5)	An estimate of the amount of each HAP used and emitted annually
from the facility; and

			(6)	The number of hours per day and days per week that the facility
operates.

		(b)	The owner or operator of a facility subject to this regulation
which was constructed or reconstructed on or after December 7, 1995 and
which is a major source of HAP shall submit an Initial Notification in
conjunction with its construction permit application.  A facility
constructed or reconstructed on or after December 7, 1995 which
subsequently becomes a major source of HAP shall submit an Initial
Notification within 30 days of becoming a major source of HAP.  Initial
Notifications for facilities constructed on or after December 7, 1995
shall include the following information:

			(1)	The date when construction or reconstruction began or is
scheduled to begin;

			(2)	The anticipated date of startup of the source; and

			(3)	The information listed in paragraphs (a)(1) through (a)(6) of
this subsection.

		(c)	A facility subject to this regulation which was constructed or
reconstructed after December 7, 1995 shall notify the Division of the
actual date of startup of the facility by April 6, 1996 or within
15 calendar days after the startup date, whichever is later.

	35.7.6	Initial Compliance Certification

		(a)	The owner or operator of a facility subject to the VHAP emission
limitations in this regulation shall submit an Initial Compliance
Certification for VHAP to the Division. Initial Compliance
Certifications for VHAP for facilities which began operation on or after
December 6, 1994 shall be submitted by May 6, 1996 or 60 days after
beginning operation, whichever is later.  Initial Compliance
Certifications for VHAP for facilities which began operation before
December 6, 1994 shall be submitted by May 6, 1998.  The owner or
operator of a facility that, due to an increase in emissions, becomes a
major source of HAP after the effective date of the regulation, shall
submit an Initial Compliance Certification to the Division no more than
60 days after becoming a major source of HAP.  

		(b)	The owner or operator of a facility subject to the VOC emission
limitations in this regulation shall submit an Initial Compliance
Certification for VOC to the Division.  Initial Compliance
Certifications for VOC shall be submitted by May 6, 1998.

		(c)	Initial Compliance Certifications shall include the following
information:

			(1)	For a facility that is complying with emission limitations
through the use of compliant materials, Initial Compliance
Certifications shall state that each topcoat, filler, stain, toner, ink,
multi-colored coating, pigmented coating, sealer, washcoat, enamel,
basecoat, thinner, adhesive and strippable booth coating is in
compliance with applicable emissions limitations in this regulation and
identify the method used to determine compliance.

			(2)	For a facility monitoring viscosity to demonstrate compliance
with emission limitations, the initial compliance report shall state
that viscosity is an appropriate parameter for demonstrating compliance,
that viscosity is being measured in accordance with the specifications
in Paragraph 35.6.1(b)(2) and that viscosity measurements demonstrate
that the VHAP and VOC content of the material in the coaters is in
compliance with applicable emission limitations.

			(3)	For a facility using weekly averaging to comply with the VOC
emission limitations in Subsection 35.3.1 or monthly averaging to comply
with the VHAP emission limitations in Subsection 35.3.2 or 35.2.3, the
Initial Compliance Certification shall state that EVOC and EVHAP, as
calculated using Equation 1 and Equation 2, respectively, are no greater
than the applicable emission limitations specified in Subsection 35.6.2.

			(4)	For a facility using a control system to comply with the emission
limitations in this regulation, the Initial Compliance Certification
shall identify each control device installed, including the
identification number, permit number, installation date and equipment
controlled.  In addition, the following information must be submitted no
more than 60 days after completing the initial performance test of the
control system:

				(i)	The results of the initial performance test of the control
system;

				(ii)	The overall control efficiency needed (Rn), calculated using
Equation 3 for VOC emissions from finishing operations, Equation 5 for
VHAP emissions from finishing operations, and Equation 6 for VHAP
emissions from gluing operations, as applicable;

				(iii)	The actual overall control efficiency (Ra) calculated using
the results of the initial performance test and Equation 4; and

				(iv)	A plan for monitoring operating parameters which identifies the
operating parameter values which indicate ongoing compliance, calculated
as specified in Paragraph 35.6.4(h), discusses why those parameters are
appropriate indicators of compliance, and specifies the frequency that
those parameters will be monitored.

			(5)	Initial Compliance Certifications shall state that a work
practice implementation plan has been developed and procedures have been
established for implementing the provisions of that plan.

			(6)	Initial Compliance Certifications shall be signed by a
responsible official of the company that owns or operates the facility.

	35.7.7	Periodic Reports

	The owner or operator of a facility subject to this regulation shall
submit periodic reports to the Office of Air Resources according to the
following specifications:

		(a)	Periodic reports shall be submitted semi-annually by 1 February of
each year for the reporting period of 1 July through 31 December of the
previous year and by 1 September for the reporting period of January 1
through June 30, which include the following:

			(1)	The amount and type of VOC and VHAP in each coating used at the
facility during the reporting period, 

			(2)	A compliance certification, as specified in Paragraphs (b)
through (g) of this subsection, and

			(3)	Documentation of progress made during the reporting period toward
reducing the VOC and VHAP content of coatings used at the facility.

		(b)	If the facility is using compliant coatings to comply with the
emission limitations in Sections 35.3 and 35.4 of this regulation,
periodic reports shall state that the VOC and VHAP content of each
topcoat, filler, stain, toner, ink, multi-colored coating, pigmented
coating, sealer, washcoat, enamel, basecoat, thinner, adhesive and
strippable booth coating used each day at the facility was in compliance
with applicable limitations in those sections throughout the reporting
period, or should identify periods of noncompliance and the reasons for
noncompliance.

		(c)	If the facility uses viscosity to monitor compliance, the periodic
report shall state that the viscosity of the finishing material in the
reservoir was monitored according to the specifications in Paragraph
35.6.1(b)(2) and that those measurements demonstrated compliance with
applicable emission limitations throughout the reporting period, or
should identify the days of noncompliance and the reasons for
noncompliance.

		(d)	If the facility is complying with the VOC emissions limitations in
Section 35.3 using averaging, the periodic report shall include the
results of the VOC averaging calculation (Equation 1) for each week in
the reporting period and shall certify that the facility was in
compliance with the applicable emission limitations in all weeks during
that period, or identify the weeks that these limitations were exceeded
and give reasons for those exceedances.

		(e)	If the facility is complying with the VHAP emissions limitations
in Section 35.3 using averaging, the periodic report shall include the
results of the VHAP averaging calculation (Equation 2) for each month in
the reporting period and shall certify that the facility was in
compliance with the applicable emission limitations in all months during
that period, or identify the months that these limitations were exceeded
and give reasons for those exceedances.

		(f)	If the facility is complying with the emission limitations in this
regulation using a control system, the periodic report shall state that
the daily average value of each continuously monitored operating
parameter was within the acceptable range on each operating day, or
identify the days of noncompliance and the reasons for the
noncompliance.

		(g)	Periodic reports shall include a statement certifying that the
work practice implementation plan and startup, shutdown, and malfunction
plan were followed throughout the reporting period, or otherwise
identify the periods of noncompliance with the work practice standards.

		(h)	The periodic report shall be signed by a responsible official of
the company that owns or operates the facility.

		(i)	If an exceedance occurs, periodic reports must be submitted
quarterly until a request to reduce the reporting frequency has been
approved.  Submittal frequencies may be reduced to semi-annual provided
that the following conditions have been satisfied:

			(1)	The facility has demonstrated a full year of compliance without
an exceedance; and

			(2)	The owner or operator of the facility continues to comply with
the recordkeeping and monitoring requirements specified in this
regulation.

35.8	Performance Test Methods

	35.8.1	VOC and Solids Content

		(a)	VOC and solids content, by weight, of coatings shall be
demonstrated with EPA Method 24 or an alternative procedure approved by
EPA and the Department. Sampling procedures shall follow the guidelines
presented in "Standard Procedures for Collection of Coating and Ink
Samples for VOC Content Analysis by Reference Method 24 and Reference
Method 24A," EPA-340/1-91-010.

		(b)	The owner or operator of a facility that uses a finishing material
that does not release VOC reaction byproducts during the cure; for
example, if all VOC is solvent; may request permission to use batch
formulation information to demonstrate compliance.  If the VOC content
of a coating determined by an EPA Method 24 test is greater than that
indicated by the facility's formulation data, the EPA Method 24 test
shall govern.

	35.8.2	VHAP and Solids Content

		(a)	EPA Method 311 of Part 63, Appendix A, or an alternative
method, if approved by EPA and the Department, shall be used in
conjunction with formulation data to determine the VHAP content of the
liquid coating.  Formulation data shall be used to identify VHAP present
in the coating, and Method 311 or an approved alternative method shall
be used to quantify the VHAP identified through the formulation data. 
EPA method 311 shall not be used to quantify VHAP such as styrene and
formaldehyde that are emitted during the cure.

		(b)	EPA Method 24 (40 CFR part 60) shall be used to determine the
solids content by weight and the density of coatings for the purpose of
showing compliance with VHAP emission limitations.

		(c)	The owner or operator of a facility that uses a finishing material
that does not release VOC or VHAP byproducts during the cure; for
example, if all VOC and VHAP present in the coating is solvent; may
request permission to use batch formulation information to demonstrate
compliance.

		(d)	If the VOC content of a coating as determined by EPA
Method 24/311 test is higher than that indicated by a facility's
formulation data, the EPA Method 24/311 test shall govern, unless the
facility can demonstrate to the satisfaction of the Department that
formulation data are correct.

		(e)	Sampling procedures shall follow the guidelines presented in
"Standard Procedures for Collection of Coating and Ink Samples for VOC
Content Analysis by Reference Method 24 and Reference Method 24A,"
EPA-340/1-91-010.

	35.8.3	Control Equipment Efficiency

		(a)	EPA Method 18, 25, or 25A shall be used to determine the VOC
concentration of gaseous air streams.  EPA Method 18 shall be used to
determine the VHAP concentration of gaseous air streams.  The test shall
consist of three separate runs, each lasting a minimum of 30 minutes.

		(b)	EPA Method 1 or 1A shall be used for sample and velocity
traverses.

		(c)	EPA Method 2, 2A, 2C, or 2D shall be used to measure velocity and
volumetric flow rates.

		(d)	EPA Method 3 shall be used to analyze exhaust gases.

		(e)	EPA Method 4 shall be used to measure the moisture content of
stack gas when required.

		(f)	EPA Methods 2, 2A, 2C, 2D, 3, and 4 shall be performed, as
applicable, at least twice during each test run.

		(g)	VOC and VHAP control systems must be constructed so that
volumetric flow rates and VOC and/or total VHAP concentrations, as
applicable, can be determined by the test methods specified in
Paragraphs (a) through (f) of this subsection, as applicable.

		(h)	Capture efficiency shall be measured using measures approved by
the EPA.

		(i)	Testing shall be performed while all affected emission points are
connected and operating at maximum production rate.

		(j)	The efficiency (F) of the control device shall be determined using
Equation 7:

n                       p

Σ  Qbi  Cbi  - Σ  Qaj  Caj

i=I                  j=I

 	F  = ___________________________________ Equation 7

N

Σ  Qbi   Cbi

	where:  	F = control device efficiency, expressed as a fraction.

			Cbi = the concentration of VOC or VHAP, as applicable, in gas stream
(i) entering the emission control device, in parts per million by
volume.

			Caj = the concentration of VOC or VHAP, as applicable, in gas stream
(j) exiting the emission control device, in parts per million by volume.

			Qaj = the volumetric flow rate of gas stream (j) exiting the emission
control device, in dry standard cubic meters per hour.

			Qbi = the volumetric flow rate of gas stream (i) entering the
emission control device, in dry standard cubic meters per hour.

	(k)  Determine the efficiency (N) of the capture system using Equation
8:

           n

           Σ  Qdi  Cdi  

 	N  = _______________________________ Equation 8

                                                n                       
    P

      Σ  Qdi  Cdi   +      Σ Qfk   Cfk

	where:	N = the capture system efficiency, expressed as a fraction.

			Cdi = the concentration of VOC or VHAP, as applicable, in gas stream
(i) entering the emission control device from the affected emission
point(s), in parts per million by volume.

			Cfk = the concentration of VOC or VHAP, as applicable, in each
uncontrolled gas stream (k) emitted directly to the atmosphere from the
affected emission point(s), in parts per million by volume.

			Qdi = the volumetric flow rate of gas stream (i) entering the
emission control device from the affected emission point(s), in dry
standard cubic meters per hour.

			Qfk = the volumetric flow rate of each uncontrolled gas stream (k)
emitted directly to the atmosphere from the affected emission point(s),
in dry standard cubic meters per hour.

		(l)	If all effected emissions points are surrounded by a permanent
enclosure that is demonstrated to be total by procedures acceptable to
the Department and the EPA, the control device capture efficiency, N, is
equal to 1.

General Provisions

Purpose

The purpose of this regulation is to limit emissions of volatile organic
compounds and hazardous air pollutants from wood products manufacturing
operations.

Authority

These regulations are authorized pursuant to R.I. Gen. Laws §
42-17.1-2(s) and 23-23, as amended, and have been promulgated pursuant
to the procedures set forth in the R.I. Administrative Procedures Act,
R.I. Gen. Laws Chapter 42-35

Application

The terms and provisions of this regulation shall be liberally construed
to permit the Department to effectuate the purposes of state law, goals
and policies.

Severability

If any provision of this regulation or the application thereof to any
person or circumstance, is held invalid by a court of competent
jurisdiction, the validity of the remainder of the regulation shall not
be affected thereby.

Effective Date

The foregoing regulation, "Control of Volatile Organic Compounds and
Volatile Hazardous Air Pollutants from Wood Products Manufacturing
Operations”, as amended, after due notice, is hereby adopted and filed
with the Secretary of State this ___29th__ day of ___June____, 2007_ to
become effective twenty (20) days thereafter, in accordance with the
provisions of Chapters 23-23, 42-35, 42-17.1, 42-17.6, of the General
Laws of Rhode Island of 1956, as amended.

W. Michael Sullivan, PhD., Director

Department of Environmental Management

Notice Given on:	February 21, 2007

Public Hearing held:        March 23, 2007

Filing Date:	June 29, 2007

			Effective Date:  July 19, 2007

	TABLE 1.  LIST OF VOLATILE HAZARDOUS AIR POLLUTANTS

 PRIVATE  Chemical name	CAS No.

Acetaldehyde	75070

Acetamide 	60355

Acetonitrile 	75058

Acetophenone 	98862

2-Acetylaminofluorine 	53963

Acrolein 	107028

Acrylamide 	79061

Acrylic acid 	79107

Acrylonitrile 	107131

Allyl chloride 	107051

4-Aminobiphenyl 	92671

Aniline 	62533

o-Anisidine 	90040

Benzene 	71432

Benzidine 	92875

Benzotrichloride 	98077

Benzyl chloride 	100447

Biphenyl 	92524

Bis(2-ethylhexyl)phthalate (DEHP) 	117817

Bis(chloromethyl)ether 	542881

Bromoform 	75252

1,3-Butadiene 	106990

Caprolactam 	105602

Carbon disulfide 	75150

Carbon tetrachloride 	56235

Carbonyl sulfide 	463581

Catechol 	120809

Chloroacetic acid 	79118

2-Chloroacetophenone 	532274

Chlorobenzene 	108907

Chloroform 	67663

Chloromethyl methyl ether 	107302

Chloroprene 	126998

Cresols (isomers and mixture) 	1319773

o-Cresol 	95487

m-Cresol 	108394

p-Cresol 	106445

Cumene 	98828

2,4-D (2,4-Dichlorophenoxyacetic acid, including

	salts and esters) 	94757

DDE (1,1-Dichloro-2,2-bis(p-chlorophenyl)ethylene) 	72559

Diazomethane 	334883

Dibenzofuran 	132649

1,2-Dibromo-3-chloropropane 	96128

Dibutylphthalate 	84742

1,4-Dichlorobenzene 	106467

3,3'-Dichlorobenzidine 	91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 	111444

1,3-Dichloropropene 	542756

Diethanolamine 	111422

N,N-Dimethylaniline 

Diethyl sulfate 	121697

64675

3,3'-Dimethoxybenzidine 	119904

4-Dimethylaminoazobenzene 	60117

3,3'-Dimethylbenzidine 	119937

Dimethylcarbamoyl chloride 	79447

N,N-Dimethylformamide 	68122

1,1-Dimethylhydrazine 	57147

Dimethyl phthalate 	131113

Dimethyl sulfate 	77781

4,6-Dinitro-o-cresol, and salts 

	2,4-Dinitrophenol 	51285

2,4-Dinitrotoluene 	121142

1,4-Dioxane (1,4-Diethyleneoxide) 	123911

1,2-Diphenylhydrazine 	122667

Epichlorohydrin (1-Chloro-2,3-epoxypropane)	106898

1,2-Epoxybutane 	106887

Ethyl acrylate 	140885

Ethylbenzene 	100414

Ethyl carbamate (Urethane) 	51796

Ethyl chloride (Chloroethane) 	75003

Ethylene dibromide (Dibromoethane) 	106934

Ethylene dichloride (1,2-Dichloroethane) 	107062

Ethylene glycol 	107211

Ethylene oxide 	75218

Ethylenethiourea 	96457

Ethylidene dichloride (1,1-Dichloroethane) 	75343

Formaldehyde 	50000

Glycol ethers 	0

Hexachlorobenzene 	118741

Hexachloro-1,3-butadiene 	87683

Hexachloroethane 	67721

Hexamethylene-1,6-diisocyanate 	822060

Hexamethylphosphoramide 	680319

Hexane 	110543

Hydrazine 	302012

Hydroquinone 	123319

Isophorone 	78591

Maleic anhydride 	108316

Methanol 	67561

Methyl bromide (Bromomethane) 	74839

Methyl chloride (Chloromethane) 	74873

Methyl chloroform (1,1,1-Trichloroethane) 	71556

Methyl ethyl ketone (2-Butanone) 	78933

Methylhydrazine 	60344

Methyl iodide (Iodomethane) 	74884

Methyl isobutyl ketone (Hexone) 	108101

Methyl isocyanate 	624839

Methyl methacrylate 	80626

Methyl tert-butyl ether 	1634044

4,4'-Methylenebis(2-chloroaniline) 	101144

Methylene chloride (Dichloromethane) 	75092

4,4'-Methylenediphenyl diisocyanate (MDI) 	101688

4,4'-Methylenedianiline 	101779

Naphthalene 	91203

Nitrobenzene 	98953

4-Nitrobiphenyl 	92933

4-Nitrophenol 	100027

2-Nitropropane 	79469

N-Nitroso-N-methylurea 	684935

N-Nitrosodimethylamine 	62759

N-Nitrosomorpholine 	59892

Phenol 	108952

p-Phenylenediamine 	106503

Phosgene 	75445

Phthalic anhydride 	85449

Polychlorinated biphenyls (Aroclors) 	1336363

Polycyclic Organic Matterb	0

1,3-Propane sultone 	1120714

beta-Propiolactone 	57578

Propionaldehyde 	123386

Propoxur (Baygon) 	114261

Propylene dichloride (1,2-Dichloropropane) 	78875

Propylene oxide 	75569

1,2-Propylenimine (2-Methyl aziridine) 	75558

Quinone 	106514

Styrene 	100425

Styrene oxide 	96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 	1746016

1,1,2,2-Tetrachloroethane 	79345

Tetrachloroethylene (Perchloroethylene) 	127184

Toluene 	108883

2,4-Toluenediamine 	95807

Toluene-2,4-diisocyanate 	584849

o-Toluidine 	95534

1,2,4-Trichlorobenzene 	120821

1,1,2-Trichloroethane 	79005

Trichloroethylene 	79016

2,4,5-Trichlorophenol 	95954

2,4,6-Trichlorophenol 	88062

Triethylamine 	121448

Trifluralin 	1582098

2,2,4-Trimethylpentane 	540841

Vinyl acetate 	108054

Vinyl bromide 	593602

Vinyl chloride 	75014

Vinylidene chloride (1,1-Dichloroethylene) 	75354

Xylenes (isomers and mixture) 	1330207

o-Xylene 

m-Xylene 	95476

108383

p-Xylene 	106423



aIncludes mono- and di-ethers of ethylene glycol, diethylene glycols and
triethylene glycol; R-(OCH2CH2)RR-OR where:

	 n =  1, 2, or 3,

	 R =  alkyl or aryl groups

	 R'=	R, H, or groups which, when removed, yield glycol ethers with the
structure:  R-(OCH2CH2)n - OH.  Polymers are excluded from the glycol
category.

bIncludes organic compounds with more than one benzene ring, and which
have a boiling point greater than or equal to 100(C.



TABLE 3.  POLLUTANTS EXCLUDED FROM USE IN CLEANING AND WASHOFF SOLVENTS

 PRIVATE  Chemical Name	CAS No. 

4-Aminobiphenyl	92671 

Styrene oxide	96093 

Diethyl sulfate	64675 

N-Nitrosomorpholine	59892 

Dimethyl formamide	68122 

Hexamethylphosphoramide	680319 

Acetamide	60355 

4,4'-Methylenedianiline	101779 

o-Anisidine	90040 

2,3,7,8-Tetrachlorodibenzo-p-dioxin	1746016 

Beryllium salts	-

Benzidine	92875 

N-Nitroso-N-methylurea	684935 

Bis(chloromethyl)ether	542881 

Dimethyl carbamoyl chloride	79447 

Chromium compounds (hexavalent)	-

1,2-Propylenimine (2-Methyl aziridine)	75558 

Arsenic and inorganic arsenic compounds	99999904 

Hydrazine	302012 

1,1-Dimethyl hydrazine	57147 

Beryllium compounds	7440417 

1,2-Dibromo-3-chloropropane	96128 

N-Nitrosodimethylamine	62759 

Cadmium compounds	-

Benzo (a) pyrene	50328 

Polychlorinated biphenyls (Aroclors)	1336363 

Heptachlor	76448 

3,3'-Dimethyl benzidine	119937 

Nickel subsulfide	12035722 

Acrylamide	79061 

Hexachlorobenzene	118741 

Chlordane	57749 

1,3-Propane sultone	1120714 

1,3-Butadiene	106990 

Nickel refinery dust	-

2-Acetylaminoflourine	53963

3,3'-Dichlorobenzidine	53963 

Lindane (hexachlorcyclohexane, gamma)	58899 

2,4-Toluene diamine	95807 

Dichloroethyl ether (Bis(2-chloroethyl)ether)	111444 

1,2 - Diphenylhydrazine	122667 

Toxaphene (chlorinated camphene)	8001352 

2,4-Dinitrotoluene	121142 

3,3'-Dimethoxybenzidine	119904

Formaldehyde	50000 

4,4'-Methylene bis(2-chloroaniline)

Acrylonitrile	101144 

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Methylene chloride (Dichloromethane)	75092 

Tetrachloroethylene (Perchloroethylene)	127184 

Dibenz (ah) anthracene	53703 

Chrysene	218019 

Dimethyl aminoazobenzene	60117 

Benzo (a) anthracene	56553 

Benzo (b) fluoranthene	205992 

Antimony trioxide	1309644 

2-Nitropropane	79469 

1,3-Dichloropropene	542756 

7, 12-Dimethylbenz(a)anthracene	57976 

Benz(c)acridine	225514 

Indeno(1,2,3-cd)pyrene	193395 

1,2:7,8-Dibenzopyrene	189559 



    Solvents containing these pollutants in concentrations less than
or equal to 0.1% may be used.

 

 

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	Table 1   (continued)

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