PLACER COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 236 - WOOD PRODUCTS COATING OPERATIONS
(Adopted 11-03-94; Amended 2-09-95, 4-10-97, 8-14-97)

100 GENERAL

101 PURPOSE: To establish limits on the emission of volatile organic compounds (VOC) from coatings and strippers used on wood products, and from products used in surface preparation and cleanup.

102 APPLICABILITY:

103 EXEMPTIONS:

200 DEFINITIONS

201 AEROSOL-SPRAY COATING: A coating which is sold in a hand-held, pressurized, non-refillable container of 1 liter (1.1 quarts) or less, and which is expelled from the container in a finely divided spray when a valve on the container is depressed.

202 AFFECTED POLLUTANT: Volatile organic compounds (VOC), as defined in Section 249.

203 AIR ASSISTED AIRLESS SPRAY: Equipment used to apply coatings that uses fluid pressure to atomize coating and air pressure between 0.1 and 20 psig to adjust the spray pattern.

204 BINDERS: Non-volatile polymeric organic materials (resins) which form surface film in coating applications.

205 CAPTURE EFFICIENCY: Expressed in percent, capture efficiency is the ratio of the weight of the VOC in the effluent stream entering a control device to the weight of the VOC emitted from wood product coating operations, both measured simultaneously in accordance with Section 503.4, and calculated by the following equation:

206 CLEANUP MATERIAL: A VOC-containing material used to clean application equipment used in wood products coating operations.

207 CLEAR TOPCOAT: The final coating which contains binders, but not opaque pigments, and is specifically formulated to form a transparent or translucent solid protective film.

208 CLOSED CONTAINER: A container which has a cover where the cover meets with the main body of the container without any gaps between the cover and the main body of the container.

209 COATING: A material which is applied to a surface and which forms a film in order to beautify and/or protect such surface. "Coating" includes, but is not limited to, materials such as topcoats, stains, sealers, fillers, conversion varnish, pigmented coating, multicolored coating, moldseal coating, washcoat, and toner.

210 CONTROL DEVICE EFFICIENCY: Expressed in percent, control device efficiency is the ratio of the weight of the VOC removed by the control device from the effluent stream entering the control device to the weight of VOC in the effluent stream entering the control device, both measured simultaneously in accordance with Section 503.5, and calculated by the following equation:

211 CONVERSION VARNISH: A coating comprised of a homogeneous (alkyd-amino resin) liquid which, when acid catalyzed and applied, hardens upon exposure to air or heat, by evaporation and polymerization, to form a continuous film that imparts protective or decorative properties to wood surfaces. When used as a self sealing system or as a pigmented coating, conversion varnish shall not be subject to the July 1, 2005 VOC limit for Sealers or for Pigmented Coatings, as specified in section 302.

212 CRACKLE LACQUER: A clear or pigmented topcoat intended to produce a cracked or crazed appearance when dry.

213 DETAILING OR TOUCH-UP GUN: Small air spray equipment, including air brushes, that operates at no greater than five (5) cfm air flow and no greater than 50 psig air pressure and is used to repair or touch-up portions of wood products.

214 DIP COAT: A coating which is applied by dipping an object into a vat of coating material and allowing any excess coating material to drain off.

215 ELECTROSTATIC APPLICATION: The electrical charging of atomized coating droplets for deposition by electrostatic attraction.

216 EMISSIONS UNIT: An identifiable operation or piece of process equipment such as an article, machine, or other contrivance which controls, emits, may emit, or results in the emissions of any affected pollutant directly or as fugitive emissions

217 EMISSION CONTROL SYSTEM: A system for reducing emissions of VOC from coating operations. It consists of

  1. equipment which captures drying oven exhaust and fugitive emissions from the line and transports them to the control device, and
  2. a VOC control device which destroys the VOC or otherwise limits the emission of VOC to the atmosphere. The capture efficiency and the control device efficiency are calculated in accordance with Sections 205 and 210, respectively.

The Emission Control System Efficiency is calculated by the following equation:

218 ENCLOSED GUN CLEANER:

219 EXEMPT COMPOUNDS: For the purposes of this rule, Exempt Compounds are as described in Rule 102, Definitions.

220 FAUX FINISH: A finish intended to simulate a surface other than wood, including stone, sand, slate, marble, metal, metal flake or leather.

221 FILLER: A preparation used to fill in cracks, grains, etc., of wood before applying a coating.

222 FLOW COATING: A coating application system where paint flows over the part and the excess coating drains back into the collection system.

223 HIGH-SOLIDS: A coating containing more than one (1) pound of solids per gallon of coating, by weight and which can include wiping stains, glazes, and opaque stains.

224 HIGH-VOLUME-LOW-PRESSURE (HVLP) SPRAY: Equipment used to apply coatings by means of a spray gun which is designed to be operated and which is operated between 0.1 and 10 psig air pressure measured dynamically at the center of the air cap and at the air horns.

225 IMITATION WOOD GRAIN: A hand applied finish that simulates the appearance of a specific natural wood grain.

226 INK: A fluid that contains dyes and/or colorants and is used to make markings but not to protect surfaces.

227 LEAF FINISH: A finish used in conjunction with metal leaf or foil.

228 LOW-SOLIDS COATING: A coating containing one (1) pound of solids per gallon of coating or less, by weight and which can include semi-transparent stains, toners, and washcoats.

229 LOW-VOLUME, LOW-PRESSURE (LVLP) EQUIPMENT: Spray coating application equipment with air pressure between 0.1 and 10.0 psig and air volume less than 15.5 cfm per spray gun and which operates at a maximum fluid delivery pressure of 50 psig.

230 MOLD-SEAL COATING: The initial coating applied to a new mold or repaired mold to provide a smooth surface which, when coated with a mold release coating, prevents products from sticking to the mold.

231 MULTI-COLORED COATING: A coating which exhibits more than one (1) color when applied and which is packaged in a single container and applied in a single coat.

232 NEW WOOD PRODUCT: A wood product which has not been previously coated or a wood product from which uncured coatings have been removed to repair flaws in initial coatings applications.

233 NON-SHOP ARCHITECTURAL COATING OPERATIONS: The commercial application of coatings to stationary structures and/or their appurtenances, to mobile homes, to pavements, or to curbs, and not conducted inside, or on the premises of, a factory or shop building facility.

234 OPAQUE STAINS: Stains not classified as semitransparent stains, which contain pigments which give character to wood.

235 PIGMENTED COATINGS: Opaque coatings which contain binders and colored pigments which are formulated to hide the wood surface, either as an undercoat or topcoat.

236 REACTIVE DILUENT: A liquid component of a coating which is a VOC during application, and one in which, through chemical or physical reactions, such as polymerization, becomes an integral part of a finished coating.

237 REFINISHING OPERATION: The steps necessary to remove cured coatings and to repair, preserve, or restore a wood product.

238 REPAIR: Recoating portions of previously coated product to cover mechanical damage to the coating following normal painting operations.

239 ROLL COATER: A series of mechanical rollers that forms a thin coating film on the surface of roller, which is applied to a substrate by moving the substrate underneath the roller.

240 SEALER: A coating containing binders, which seals the wood prior to application of the subsequent coatings.

241 SEMITRANSPARENT STAIN: A stain containing dyes and/or semi-transparent pigments which are formulated to enhance wood grain and change surface color but not to conceal surface grain, and include sap stain and non-grain raising stains. Semitransparent stains with greater than one (1) pound of solids per gallon of coating shall be considered opaque stains.

242 SIMULATED WOOD MATERIALS: Materials, such as plastic, glass, metal, etc., that are made to give a wood-like appearance or are processed like a wood product.

243 STENCIL COATING: An ink or a pigmented coating which is rolled or brushed onto a template or stamp in order to add identifying letters and/or numbers to wood products.

244 STRIPPER: A liquid used to remove cured coatings, cured inks, and/or cured adhesives.

245 SURFACE PREPARATION MATERIAL: A VOC-containing material applied to the surface of any wood product, prior to the application of coatings, to clean the wood product or to promote the adhesion of subsequent coatings.

246 TONER: A wash coat which contains binders and dyes or pigments to add tint to a coated surface.

247 TOUCH-UP: A coating used to cover minor coating imperfections appearing after the main coating operation.

248 VOC COMPOSITE PARTIAL VAPOR PRESSURE: VOC composite partial vapor pressure for determination of compliance with Section 304 shall be calculated by the following equation:

249 VOLATILE ORGANIC COMPOUND (VOC): Any chemical compound containing at least atom of carbon, except for the Exempt Compounds listed in Rule 102, Definitions.

250 VOC CONTENT PER LITER OF COATING, LESS WATER AND EXEMPT COMPOUNDS: The weight of VOC per combined volume of VOC and coating solids, shall be calculated by the following equation:

251 VOC CONTENT PER LITER OF MATERIAL: The weight (in grams) of VOC per liter of wood products coating material is expressed as Grams VOC per Liter of Material, and shall be calculated using the following:

252 VOC CONTENT PER POUND OF COATING SOLIDS: Pounds of VOC per pound of coating solids is the weight of VOC per weight of coating solids in any given coating material, and shall be calculated by the test method found in Section 503.1 and the following equation:

253 WASH COAT: A coating, containing binders, which penetrates into and seals wood, prevents undesired staining, and seals in wood pitch. Washcoats with greater than one (1) pound of solids per gallon of coating shall be considered sealers.

254 WOOD PANEL: Any piece of wood, or wood composition, which is solid or laminated, and which is larger than 10 square feet in size, and which is not subsequently cut into smaller pieces.

255 WOOD PRODUCTS: Surface-coated objects such as cabinets (kitchen, bath and vanity), tables, chairs, beds, sofas, shutters, doors, trim, containers, tools, ladders, art objects, and any other objects made of solid wood and/or wood composition and/or of simulated wood material used in combination with solid wood or wood composition.

256 WOOD PRODUCT COATING APPLICATION OPERATIONS: A combination of coating application steps which may include use of spray guns, flash-off areas, spray booths, ovens, conveyors, and/or other equipment operated for the purpose of applying coating to wood products.
 

300 STANDARDS

301 APPLICATION EQUIPMENT REQUIREMENTS: A person subject to the provisions of this rule shall not apply any wood product coating to any wood products, unless one of the following application methods is used:

  1. Hand application methods, such as brush or roller
  2. Roll coater
  3. Dip coat
  4. Flowcoat
  5. High Volume Low Pressure spray equipment
  6. Low Volume Low Pressure spray equipment
  7. Air assisted airless, for touch-up and repair only
  8. Electrostatic application equipment
  9. Any other equivalent method which has been approved in writing by the Air Pollution Control Officer and the U.S. Environmental Protection Agency

302 LIMITS FOR VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS: Except as provided in Sections 103, 305, and 306 no person shall apply any coatings to a new wood product, or use VOC-containing solvents, if such materials have a VOC content exceeding the applicable limits specified in the following table. The VOC content of coatings, except low-solid stains, toners, washcoats and solvents, shall be determined in accordance with Sections 250 and 503.1. The VOC content of low-solid stains, toners washcoats and solvents, shall be determined in accordance with Sections 251 and 503.1.

LIMITS FOR VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS
 

 

 
 
 
SPECIFIC MATERIAL

VOC LIMITS

Grams VOC Per Liter of Coating 
Less Water and Exempt Compounds, as defined in Section 250
(Pounds VOC Per Pound of Solids, which applies only if Emission Averaging is used, as defined in Section 252)

BEFORE JULY 1, 2005

EFFECTIVE JULY 1, 2005

Clear Topcoats

550 (1.37)

275 (0.35)

Conversion Varnish

550 (1.37)

550 (1.20) *

FIller

500 (0.66)

275 (0.18)

High-Solid Stain

550 (1.23)

350 (0.42)

Inks

500 (0.96)

500 (0.96)

Mold-Seal Coating

750 (4.20)

750 (4.20)

Multi-colored Coating

685 (2.60)

275 (0.33)

Pigmented Coating

550 (1.10)

275 (0.25) *

Sealer

550 (1.39)

275 (0.36) *

 

VOC LIMITS

Grams VOC per Liter of Material, as defined in Section 251
(Pounds VOC per Pound of Solids, which applies
only if Emission Averaging is used, as defined in Section 252)
Low Solid Stains, Toners and Washcoats

BEFORE JULY 1, 2005

EFFECTIVE JULY 1, 2005

480 (4.0)

120 (1.00)

 

VOC LIMITS

Grams VOC Per Liter of Material
(Pounds Per Gallon)
Surface Prep and Clean-up Solvents Containing VOC's

BEFORE JULY 1, 2005

EFFECTIVE JULY 1, 2005

200 (1.67)

200 (1.67)

 

303 LIMITS FOR VOC CONTENT OF COATINGS FOR REFINISHING, REPAIRING, PRESERVING, OR RESTORING WOOD PRODUCTS: Except as provided in Sections 103, 305, and 306 no person shall apply any coatings to refinish, repair, preserve, or restore a wood product, or use VOC-containing solvents, if such materials have a VOC content exceeding the applicable limits specified in the following table. The VOC content of coatings, except low-solid stains, toners, and washcoats, shall be determined in accordance with Sections 250 and 503.1. The VOC content of low-solid stains, toners and washcoats and VOC-containing solvents shall be determined in accordance with Sections 251 and 503.1.

LIMITS FOR VOC CONTENT OF COATINGS TO REFINISH, REPAIR, PRESERVE OR RESTORE

SPECIFIC MATERIAL

VOC LIMITS 

Grams VOC Per Liter of Coating
Less Water and Exempt Compounds, as defined in Section 250 (Pounds VOC Per Pound of Solids [applies only if Emission Averaging is used], as defined in
Clear Topcoats

680 (2.50)

Conversion Varnish

550 (1.20) *

FIller

500 (0.96)

High-Solid Stain

700 (2.57)

Inks

500 (0.96)

Mold-Seal Coating

750 (4.20)

Multi-colored Coating

680 (2.50)

Pigmented Coating

600 (1.60) *

Sealer

680 (2.50) *

 

VOC LIMIT

Grams VOC Per Liter of Material, as defined in Section 251 (Pounds VOC Per Pound of Solids [applies only if Emission Averaging is used], as defined in Section 252) 
Low Solid Stains, Toners and Washcoats

480 (0.76)

 

VOC LIMIT

Grams VOC Per Liter of Material
(Pounds VOC Per Gallon)
Surface Prep and Clean-up Solvents Containing VOC's

200 (1.67)

304 LIMITS OF VOC CONTENT FOR STRIPPERS: A person shall not use a stripper on wood products unless:

305 EMISSION CONTROL SYSTEM:

306 EMISSIONS AVERAGING PROVISIONS:

307 REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP MATERIALS: Any person subject to this rule shall comply with the following requirements:

 

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF SPECIFICATION: No person shall require for use or specify the application of any coating subject to the provisions of this rule that does not meet the limits and requirements of this rule. The prohibition of this Section shall apply to all written or oral contracts under the terms of which any coating is to be applied to any wood product at any physical location within the District.

402 LABELING REQUIREMENTS, VOC CONTENT: Each container of any coating, surface preparation material, or cleanup material, or stripper manufactured after July 1, 1997 shall display its maximum VOC content of the coating, as applied, and after any thinning as recommended by the manufacturer, or shall have this information provided in a product data sheet supplied with the container. VOC content shall be displayed as grams of VOC per liter of coating (less water and less exempt solvent, and excluding any colorant added to tint bases), surface preparation and cleanup material, or stripper. VOC content displayed may be calculated using product formulation data, or may be determined using the test method in Section 503.1. Alternatively, containers for strippers subject to the provisions of Section 304 may display only the partial vapor pressure.

403 EMISSIONS AVERAGING PLAN:

404 OPERATION AND MAINTENANCE PLAN: A person using an emission control system pursuant to Section 305, as a means of alternate compliance with this rule, as provided in Sections 302, 303 and 304, must submit an Operation and Maintenance Plan for the emission control system to the Air Pollution Control Officer for approval. A person proposing to install a new emission control system as a means of alternate compliance with this rule shall submit in addition to an Operation and Maintenance Plan, an application for Authority to Construct, pursuant to Rule 501, General Permit Requirements. The Plan shall specify operating and maintenance procedures which will demonstrate continuous operation of the emission control system during periods of emissions-producing operations. The Plan shall also specify which records must be kept to document these operating and maintenance procedures. These records shall comply with the requirements of Sections 501 and 502. The Plan shall be implemented upon approval of the Air Pollution Control Officer.

405 FEASIBILITY AND TECHNOLOGY ASSESSMENT: By July 1, 2003, the Air Pollution Control Officer shall assess the feasibility of the July 1, 2005 VOC limits and whether new technology could provide additional emissions reductions to meet the District's Air Quality Management Plan objectives
 

500 MONITORING AND RECORDS

501 RECORDKEEPING: In addition to any applicable record keeping requirements of either Rule 502, New Source Review, Rule 507, Federal Operating Permit Program, and Rule 511, Potential to Emit, or any other District rule which may be applicable, any person subject to this rule shall maintain the following records in order to evaluate compliance:

502 RETENTION OF RECORDS: All records required by this rule shall be retained for at least three years, except for sources subject to Rule 507, Federal Operating Permit Program, which shall be retained for at least five years. Such records shall be made available to the Air Pollution Control Officer upon request.

503 TEST METHODS