SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
RULE 1136 - WOOD PRODUCTS COATINGS
(Adopted September 16, 1983) (Amended August 5, 1988)(Amended May 5, 1989) (Amended March 2, 1990)(Amended June
28, 1990)(Amended November 2, 1990) (Amended December 7, 1990)(Amended August 2, 1991)(Amended April 8, 1994) (Amended
August 12, 1994)(Amended September 8, 1995)(Amended June 14, 1996)
(a) Purpose and Applicability
The purpose of Rule 1136 is to reduce volatile organic compounds (VOC) emissions from the application of coatings
or strippers to, and surface preparation of, any wood products, including furniture, cabinets, shutters, frames
and toys. This rule shall not apply to residential noncommercial operations.
(b) Definitions
For the purposes of this rule, the following definitions shall apply:
Capture Efficiency = [Wc/We] x 100
Where:
Wc = weight of VOC entering control device
We = weight of VOC emitted
Control Device Efficiency = [(Wc-Wa)/Wc] x 100
Where:
Wc = weight of VOC entering control device
Wa = weight of VOC discharged from the control device
(A) Repeated scrubbing with industrial grade detergents, cleaners, or abrasive scouring agents; or
(B) Frequent exposure to water, to outdoor weather, or to ultraviolet radiation.
Grams of VOC per Liter of Coating, Ws - Ww - Wes
Less Water and Less Exempt Compounds = ---------------
Vm - Vw - Ves
Where:
Ws = weight of volatile compounds in grams
Ww = weight of water in grams
Wes = weight of exempt compounds in grams
Vm = volume of material in liters
Vw = volume of water in liters
Ves = volume of exempt compounds in liters For coatings that contain
reactive diluents, the VOC content of the coating is determined after curing. The grams of VOC per liter of coating
shall be calculated by the following equation:
Grams of VOC per Liter of Coating, W s - Ww - Wes
Less Water and Less Exempt Compounds = ---------------
Vm - Vw - Ves
Where:
Ws = weight of volatile compounds, in grams, emitted into the atmosphere during curing
Ww = weight of water, in grams, emitted into the atmosphere during curing
Wes = weight of exempt compounds, in grams, emitted into the atmosphere during curing
Vm = volume of the material, in liters, prior to reaction
Vw = volume of water, in liters, emitted into the atmosphere during curing
Ves = volume of exempt compounds, in liters, emitted into the atmosphere during curing
Ws - Ww - Wes
Grams of VOC per Liter of Material = ---------------
Vm
Where:
Ws = weight of volatile compounds in grams
Ww = weight of water in grams
Wes = weight of exempt compounds in grams
Vm = volume of material in liters
C.E. = [(Wc-Wa)/We] x 100
C.E. = [(Capture Efficiency) x (Control Device Efficiency)]/100
Where:
Wc = weight of VOC entering control device
Wa = Weight of VOC discharged from the control device
We = weight of VOC emitted
Ws - Ww - Wes
Pounds of VOC per Pound of Solids = ----------------
Wr Where: Ws = weight of volatile compounds in pounds Ww = weight of water in
pounds Wes = weight of exempt compounds in pounds Wr = weight of coating solids in pounds
For coatings that contain reactive diluents, the VOC content of the coating is determined after curing. The pounds of VOC per pound of coating solids shall be calculated by the following equation:
Ws - Ww - Wes
Pounds of VOC per Pound of Solids = -------------------
Wr
Where:
Ws = weight of volatile compounds, in pounds, emitted into the atmosphere during curing
Ww = weight of water, in pounds, emitted into the atmosphere during curing
Wes = weight of exempt compounds, in pounds, emitted into the atmosphere during curing
Wr = weight of coating solids, in pounds, prior to reaction
VOC Composite Partial Pressure is calculated as follows:

Where:
Wi = Weight of the "i"th VOC compound, in grams (g)
Ww = Weight of water, in grams (g)
We = Weight of exempt compound, in grams (g)
MWi = Molecular weight of the "i"th VOC compound, in g/g-mole
MWw = Molecular weight of water, in g/g-mole
MWe = Molecular weight of exempt compound, in g/g-mole
PPc = VOC composite partial pressure at 20oC, in mm Hg
VPi = Vapor pressure of the "i"th VOC compound at 20oC, in mm Hg
(A) to prevent undesired staining,
(B) to control penetration,
(C) to provide a barrier when paper laminates are applied to the wood product,
(D) to seal glazes,
(E) to improve adhesion of a waterborne topcoat.
(c) Requirements
(A) A person or facility shall not apply any coating to a wood product which has a VOC content, including any VOC-containing material added to the original coating supplied by the manufacturer, which exceeds the applicable limit specified below:
(i) VOC LIMITS
Grams Per Liter (lb/gal) of Coating, [lbs VOC/lb of solids],
Less Water and Less Exempt Compounds
COATING Current Limit On and After
7/1/97
I or IIOn and After
7/1/2005Clear Sealers 680 (5.7) [3.36] 550 (4.6) [1.39] 680 (5.7) [3.36] 275 (2.3) [0.36] Clear Topcoat 680 (5.7) [2.99] 550 (4.6) [1.37] 275 (2.3) [0.35] 275 (2.3) [0.35] Pigmented Primers, Sealers & Undercoats 600 (5.0) [1.08] 550 (4.6) [1.06] 600 (5.0) [1.08] 275 (2.3) [0.21] Pigmented Topcoats 600 (5.0) [1.38] 550 (4.6) [1.10] 275 (2.3) [0.25] 275 (2.3) [0.25] Effective July 1, 1997, a person or facility shall use coatings on a wood product that comply with either all VOC limits in column I or all VOC limits in column II. A person or facility that applies a primer, sealer or undercoat, but not a topcoat, to a wood product, shall be subject to column I for that wood product.
(ii) Notwithstanding the requirements of clause (c)(1)(A)(i), a person or facility that applies a topcoat and a primer, sealer or undercoat to a shutter may, until July 1, 2005, choose to comply with the VOC limits specified below for that shutter:
VOC LIMITS
Grams Per Liter, (lb/gal) of Coating, [lbs VOC/lb of solids],
Less Water and Less Exempt Compounds
| COATING | |
| Clear Sealers |
275 (2.3) [0.36] |
| Clear Topcoat |
680 (5.7) [2.99] |
| Pigmented Primers, Sealers & Undercoats |
275 (2.3) [0.33] |
| Pigmented Topcoats |
600 (5.0) [1.38] |
(iii)
VOC LIMITS
Grams Per Liter, (lb/gal) of Coating, [lbs VOC/lb of solids],
Less Water and Less Exempt Compounds
COATING Current Limit On and After
7/1/97On and After
7/1/2005Barrier Coat - Plastic Components 800 (6.7) [6.3] 760 (6.3) [3.9] 275 (2.3) [0.28] Composite Wood Edge Filler 680 (5.7) [2.34] 550 (4.6) [1.15] 275 (2.3) [0.31] Extreme Performance Coatings 420 (3.5) [0.51] 420 (3.5) [0.51] 275 (2.3) [0.33] Fillers 500 (4.2) [0.66] 500 (4.2) [0.66] 275 (2.3) [0.18] High-Solid Stains 700 (5.8) [2.84] 550 (4.6) [1.23] 350 (2.9) [0.42] Inks 500 (4.2) [0.96] 500 (4.2) [0.96] 500 (4.2) [0.96] Mold-Seal Coatings 750 (6.3) [4.2] 750 (6.3) [4.2] 750 (6.3) [4.2] Multi-Colored Coatings 685 (5.7) [2.6] 685 (5.7) [2.6] 275 (2.3) [0.33] VOC LIMITS
Grams Per Liter (lb/gal) of Material
COATING Current Limit On and After
7/1/97On and After
7/1/2005Low-Solids Barrier Coat - Plastic Components 800 (6.7) 760 (6.3) 120 (1.0) Low-Solid Stains, Toners, and Washcoats 800 (6.7) 480 (4.0) 120 (1.0)
Any coating subject to this rule that meets any of the three VOC limit formats (grams per liter, lb/gal, or lbs VOC/lb of solids) is in compliance with this subparagraph.
(B) A person shall not use a stripper on wood products unless:
(i) it contains less than 350 grams of VOC per liter of material; or
(ii) the VOC composite vapor pressure is 2 mm Hg
(0.04 psia) or less at 20oC (68oF).
(C) Owners and/or operators may comply with provisions of paragraph (c)(1)(A) and (B) by using an approved air pollution control system, consisting of collection and control devices, which reduces VOC emissions from the application of wood product coatings or strippers by an equivalent or greater amount than the limits specified in subparagraphs (c)(1)(A) and (B), with the written approval of the Executive Officer. The minimum required overall control efficiency of an emission control system at which an equivalent or greater level of VOC reduction will be achieved shall be calculated by the following equation:
(VOCLWc) 1 - (VOCLWn Max/ Dn Max)
C. E. = [ 1 - {----------- x -------------------------} ] x 100
(VOCLWn Max) 1 - (VOCLWc/Dc)
Where: C.E. = Control Efficiency, percent
VOCLWc = VOC Limit of Rule 1136, less water and less exempt compounds, pursuant to subparagraph (c)(1)(A).
VOCLWn Max = Maximum VOC content of non-compliant coating used in conjunction with a control device, less water and less exempt compounds.
Dn Max = Density of solvent, reducer, or thinner contained in the non-compliant coating, containing the maximum VOC content of the multicomponent coating.
Dc = Density of corresponding solvent, reducer, or thinner used in the compliant coating system = 880 g/L.
(D) Emissions Averaging Provisions
(i) Owners or operators may comply with the provisions of subparagraph (c)(1)(A) by using an averaging approach for all or a portion of the coatings used at the facility, provided all requirements of this subparagraph are met. The owner or operator shall demonstrate that actual emissions from the coatings being averaged are less than or equal to 90 percent of the allowable emissions, on a daily basis, using the following inequality:
Where:
VOCi = VOC content limit of coating “i” (pounds (lb) of VOC/gallon of material for low solids coatings; and lb VOC/lb of solids for all other coatings), as required by subparagraph (c)(1)(A);
Ui = Usage of coating “i” (gallons of material for low-solids coatings; and lb of solids for all other coatings); and
ERi = Actual VOC content of coating “i”, as applied (lb of VOC/gallon of material for low-solids materials; and lb VOC/lb of solids for all other coatings).
The 0.9 multiplier above is not applicable after June 30, 2005, or to facilities with a potential to emit less than 10 tons of VOC per year. Any wood product coating not included in the emission averaging shall comply with the VOC limits in subparagraph (c)(1)(A).
(ii) Emissions Averaging Plan (Plan)
Owners or operators shall submit a Plan, pursuant to Rule 221 - Plans, to the Executive Officer to participate in emissions averaging. The plan may not be implemented until it is approved in writing by the Executive Officer. Submittal of the Plan does not provide an exemption from the rule requirements. The Plan shall include, at a minimum:
(I) A description of the wood product coatings to be included in the averaging program; and
(II) A description of the quantification and recordkeeping procedures for coating usage; coating VOC and solids content; VOC emissions; and calculations to show daily compliance with clause (c)(1)(D)(i).
(A) electrostatic application; or
(B) flow coat; or
(C) dip coat; or
(D) high-volume, low-pressure (HVLP) spray; or
(E) paint brush; or
(F) hand roller; or
(G) roll coater; or
(H) such other coating application methods as are demonstrated to the Executive Officer to be capable of achieving at least 65 percent transfer efficiency, and for which written approval of the Executive Officer has been obtained.
(d) Recordkeeping Requirements
Records shall be maintained pursuant to Rule 109 or pursuant to an approved Emissions Averaging Plan, whichever
is applicable. If compliance with the VOC limits in subparagraph (c)(1)(A) is based on the pounds of VOC per pound
of solids format, then the operator shall keep a record of the VOC content of the coating in pounds of VOC per
pound of solids in addition to complying with the requirements of Rule 109.
(e) Prohibition of Specifications
A person shall not specify the use in the District of any coating to be applied to any wood products subject to
the provisions of this rule that does not meet the limits and/or requirements of this rule. The requirements of
this paragraph shall apply to all written or oral contracts.
(f) Test Methods
(A) United States Environmental Protection Agency (USEPA) Reference Method 24 (Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coating, Code of Federal Regulations Title 40, Appendix A), or Method 304 (Determination of Volatile Organic Compounds (VOCs) in Various Materials) in the South Coast Air Quality Management District (SCAQMD) "Laboratory Methods of Analysis for Enforcement Samples" manual.
(B) The exempt compounds' content shall be determined by:
(i) Methods 302 (Distillation of Solvents from Paints, Coatings and Inks) and 303 (Determination of Exempt Compounds) in the SCAQMD "Laboratory Methods of Analysis for Enforcement Samples" manual.
(ii) The following classes of compounds: cyclic, branched, or linear, completely fluorinated alkanes; cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations; and sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine, will be analyzed as exempt compounds for compliance with subdivision (c), only at such time as manufacturers specify which individual compounds are used in the coating formulations and identify the test methods, which, prior to such analysis, have been approved by the USEPA and the SCAQMD, that can be used to quantify the amounts of each exempt compound.
(A) Applicable USEPA Methods 204, 204A, 204B, 204C, 204E, and/or 204F; or
(B) The SCAQMD “Protocol for Determination of Volatile Organic Compounds (VOC) Capture Efficiency”; or
(C) Any other method approved by the USEPA, the California Air Resources Board, and the SCAQMD Executive Officer.
(g) Continuous Monitors
(h) Rule 442 Applicability
Any coating, coating operation, or facility which is exempt from all or a portion of the VOC limits of this rule
shall comply with the provisions of Rule 442 unless compliance with the limits specified in this rule is achieved.
(i) Alternative Emission Control Plan
An owner or operator may achieve compliance with paragraph (c)(1) by means of an Alternative Emission Control Plan
pursuant to Rule 108.
(j) Progress Reports
Owners or operators shall submit a progress report to the Executive Officer by January 1, 2003. The Progress Report
shall include at a minimum:
(k) Air Quality Management Plan (AQMP) Technology Assessment Audit
The Executive Officer shall audit Rule 1136 by July 1, 2003 to assess the feasibility of the final VOC limits and
whether new technology could provide additional reductions to meet the District’s AQMP objectives.
(l) Exemptions
(A) any spray equipment that uses only coatings that comply with the July 1, 2005 VOC limits; or
(B) any spray equipment, except conventional air spray, that uses only coatings that contain 550 grams, or less, of VOC per liter of coating, less water and less exempt compounds.
(A) the coating is not applied from April 1 to October 31 of any year; and
(B) the coating contains acetone and no more than 550 grams of VOC per liter of coating, less water and exempt compounds, prior to the addition of VOC.