EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT

RULE 237 - WOOD PRODUCTS COATINGS
(Adopted: June 27, 1995)

237.1 GENERAL

  1. PURPOSE: To limit the emission of volatile organic compounds from wood products coatings operations.
  2. APPLICABILITY: This rule applies to all sources applying 75.7 liters (20 gallons) or more, per month (singly or in any combination) of coatings, inks, stains, and/or strippers in wood product coating operations for the purpose of manufacture of wood products, including furniture and other coated objects made of solid wood and/or wood composition, and/or simulated wood material.
  3. EXEMPTION - GENERAL: The provisions of this rule shall not apply to:
    1. Businesses using less than 75.7 liters (20 gallons) per month (singly or in any combination) of wood product coatings and/or strippers.
    2. Noncommercial operations as defined in Section 237.2 X. of this rule.
    3. Wood products coatings that are sold in non-refillable aerosol-spray containers.
    4. Coating operations for the purpose of manufacturing a finished wood panel intended for attachment to the inside walls of buildings, including, but not limited to, homes and office buildings, mobile homes, trailers, prefabricated buildings and similar structures; or a finished exterior wood siding intended for use in construction.
    5. Coating of architectural components or structures, not coated in a shop environment.

237.2 DEFINITIONS
 

  1. AEROSOL-SPRAY CONTAINER: Any hand-held, pressurized, non-refillable container of 1 liter (1.1 quarts) or less, where the contents are released when a valve on the container is depressed.
  2. AIR-ASSISTED AIRLESS SPRAY: Paint spray application system using fluid pressure to atomize the paint and lower air pressure to adjust the shape of the fan pattern.
  3. BINDERS: Non-volatile polymeric organic materials (resins) which form the surface film in coating applications.
  4. CLEAR TOPCOAT: A final coating which contains binders, but not opaque pigments, and is specifically formulated to form a transparent or translucent solid protective film.
  5. CLOSED CONTAINER: A container which has a cover, and where the cover meets with the main body of the container without any gaps between the cover and the main body of the container.
  6. 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, multicolored coating, moldseal coating, washcoat, and toner.
  7. CONVERSION VARNISH: A coating comprised of a homogeneous, transparent or translucent (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.
  8. 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.
  9. ELECTROSTATIC APPLICATION: The electrical charging of atomized coating droplets for deposition by electrostatic attraction.
  10. ENCLOSED GUN CLEANER:
    1. A device that is used for the cleaning of spray guns, pots and hoses, that has an enclosed solvent container, is not open to the ambient air when in use, and has a mechanism to force the cleanup material through the gun while the cleaner is in operation; or
    2. A device that is used for the cleaning of spray guns, pots and hoses, that has an enclosed solvent container, uses non-atomized solvent flow to flush the spray equipment and collects and returns the discharged solvent to the enclosed container.
  11. EXEMPT COMPOUNDS: The following compounds are exempt from the definition of VOC in Section 237.2 LL:
    1. ethane,
    2. Carbon dioxide,
    3. Carbon monoxide,
    4. Carbonic acid,
    5. Metallic carbides or carbonates,
    6. Ammonium carbonate,
    7. 1,1,1-trichloroethane,
    8. Methylene chloride,
    9. Trichlorofluoromethane (CFC 11),
    10. Dichlorodifluoromethane (CFC 12),
    11. Chlorodifluoromethane (HCFC 22),
    12. Trifluoromethane (CFC 23),
    13. Trichlorotrifluoroethane (CFC 113),
    14. . Dichlorotetrafluoroethane (CFC 114),
    15. Chloropentafluoroethane (CFC 115),
    16. Dichlorotrifluoroethane (HCFC-123),
    17. Chlorotetrafluoroethane (HCFC-124),
    18. Pentafluoroethane (HFC-125),
    19. 1,1,2,2-tetrafluoroethane (HFC 134),
    20. 1,1,1,2-tetrafluoroethane (HFC 134a),
    21. Dichlorofluoroethane (HCFC-141b),
    22. Chlorodifluoroethane (HCFC-142b),
    23. Trifluoroethane (HFC-143a),
    24. Difluoroethane (HFC-152a),
    25. Parachlorobenzotriflouride (PCBTF)
    26. Volatile cyclic and linear methyl siloxanes (VMS)
    27. The following four classes of perfluorocarbon compounds:
      1. Cyclic, branched or linear, completely fluorinated alkanes.
      2. Cyclic, branched, or linear, completely fluorinated ethers, with no unsaturations.
      3. Cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations.
      4. Sulfur containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine.
  12. FILLER: A preparation used to fill in cracks, grains, etc., of wood before applying a coating.
  13. FLOW COAT: A coating which is applied by flowing a stream of coating over an object and allowing any excess coating material to drain off.
  14. GRAMS OF VOC PER VOLUME 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:
  1. GRAMS OF VOC PER VOLUME OF MATERIAL: The volume of material is defined as the volume of the original material, plus any VOC-containing material added to the original material. The original material is the material before any VOC-containing material such as solvent is added for purposes of mixing or thinning. The VOC content shall exclude any colorant added to a tint base. The weight of VOC per total volume of material shall be calculated by the following equation:
  2. HAND APPLICATION METHODS: The application of coatings by nonmechanical hand-held equipment, including but not limited to, paint brushes, hand-rollers, trowels, spatulas, rags and sponges.
  3. HIGH-SOLIDS STAIN: Stains containing more than 454 grams (1 pound) of solids per 3.785 liters (1 gallon), by weight, and including wiping stains, glazes, and opaque stains.
  4. HIGH-VOLUME, LOW-PRESSURE (HVLP): Spray coating application equipment with air pressure between 0.1 and 10.0 pounds per square inch gauge (psig) and air volume greater than 15.5 cfm per spray gun and which operates at a maximum fluid delivery pressure of 60 psig.
  5. INK: A fluid that contains dyes and/or colorants and is used to make markings, but not to protect surfaces.
  6. LOW-SOLIDS STAINS: Stains containing 454 grams (1 pound) of solids per 3.785 liters (1 gallon) or less, by weight.
  7. 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.
  8. MULTI-COLORED COATING: A coating which exhibits more than one color when applied, and which is packaged in a single container and applied in a single coat.
  9. NEW WOOD PRODUCT: A wood product or simulated wood product which has not been previously coated and from which cured coatings have not been removed. A wood product or simulated wood product from which uncured coatings have been removed to repair flaws in initial coatings applications is a new wood product.
  10. NONCOMMERCIAL OPERATION: Any business or public agency which is not a major stationary source of emissions as defined in Rule 522 TITLE V - FEDERAL OPERATING PERMIT PROGRAM, and in which the coating of wood products is clearly incidental to the main business or public agency operation.
  11. PIGMENTED COATINGS: Opaque coatings which contain binders and colored pigments which are formulated to hide the wood surface, either as an undercoat or topcoat.
  12. RATE PER CALENDAR YEAR: The amount of coating applied between 12:00 a.m. January 1 and 11:59 p.m. December 31, of the same calendar year.
  13. RATE PER DAY: The amount of coating applied between 12:00 a.m. and 11:59 p.m. on the same calendar day.
  14. REFINISHING OPERATION: The steps necessary to remove cured coatings and to repair, preserve, or restore a wood product.
  15. REPAIR COATING: A coating used to recoat portions of a product which has sustained mechanical damage to the coating following normal coating operations.
  16. ROLL COATER: A series of mechanical rollers that forms a thin coating film on the surface of the roller, which is applied to a substrate by moving the substrate underneath the roller.
  17. SEALER: A coating, containing binders, which seals the wood prior to application of subsequent coatings.
  18. 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.
  19. STATIONARY SOURCE: Any building, structure, facility, or installation which emits or may emit any affected pollutant directly or as a fugitive emission.
    1. "Building, structure, facility, or installation" includes all pollutant emitting sources activities which:
      1. Belong to the same industrial grouping; and
      2. Are located on one property or two or more contiguous properties; and
      3. Are under the same common ownership, operation, or control, or which are owned or operated by entities which are under common control.
    2. Pollutant emitting activities shall be considered as part of the same industrial grouping if:
      1. They belong to the same two-digit standard industrial classification code; or
      2. They are part of a common production process. (Common production process includes industrial processes, manufacturing processes, and any connected processes involving a common material).
  20. 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.
  21. STRIPPER: A liquid used to remove cured coatings, cured inks, and/or cured adhesives.
  22. TONER: A wash coat which contains binders and dyes or pigments to add tint to a coated surface.
  23. TOUCH-UP COATING: A coating used to cover minor coating imperfections appearing after the main coating operation.
  24. VOLATILE ORGANIC COMPOUND (VOC): Compounds which contain at least one atom of carbon, except for the compounds listed in Section 237.2 K.
  25. VOLATILE ORGANIC COMPOUND COMPOSITE PARTIAL VAPOR PRESSURE: The sum of the partial pressures of compounds defined as VOCs. VOC composite partial vapor pressure for determination of compliance with Section 237.3 D. shall be calculated by the following equation:
  26. WASH COAT: A coating that is used to seal wood surfaces, preventing undesired staining and control penetration. For the purpose of this rule, wash coats shall be considered low-solids coatings and shall contain less than 454 grams (1 pound) of solids per 3.785 liters (1 gallon), by weight.  Wash coats with greater than 454 grams (1 pound) of solids per 3.785 liters (1 gallon), by weight, shall be considered sanding sealers.
  27. WOOD PANEL: Any piece of wood, wood composition, or simulated wood, which is solid or laminated, and which is larger than 10 square feet in size, and which is not subsequently cut into smaller pieces.
  28. WOOD PRODUCTS: Surface-coated products which include cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, and any other coated objects made of solid wood, and/or wood composition, and/or made of simulated wood material used in combination with solid wood or wood composition.
  29. 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 materials.

237.3 STANDARDS
 

  1. APPLICATION EQUIPMENT REQUIREMENTS: A person or facility shall not apply coatings to wood products subject to the provisions of this rule, unless the coating is applied with properly operating equipment, according to manufacture's specifications, and by use of one, or more, of the following methods:
    1. Electrostatic application;
    2. Flow coat;
    3. Dip coat;
    4. HVLP spray;
    5. Hand application methods;
    6. Roll coater; or,
    7. Air-assisted airless spray, for touch-up and repair.
  1. VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS
    1. Except as provided in Section 237.1 C., no person or facility shall apply any coating, on a new wood product, which has a volatile organic compound (VOC) content, as applied, exceeding the applicable limits specified below. The VOC content of the coating shall be determined in accordance with Section 237.5 C.1.

 

 
  • VOC LIMITS (GRAMS PER LITER OF COATING) 
  • Less Water and Exempt Compounds
  • COATING
  • ON AND AFTER 1-31-96
  • ON AND AFTER 7-1-97
  • Clear Topcoats
  • 275 g/L
  • 275 g/L
  • Conversion Varnish
  • 550 g/L
  • 550 g/L
  • Filler
  • 500 g/L
  • 275 g/L
  • High-Solid Stain
  • 550 g/L
  • 240 g/L
  • Inks
  • 500 g/L
  • 500 g/L
  • Mold-Seal Coating
  • 750 g/L
  • 750 g/L
  • Multi-Colored
  • 275 g/L
  • 275 g/L
  • Pigmented Coating
  • 275 g/L
  • 275 g/L
  • Sealer
  • 680 g/L
  • 275 g/L
 
 
  • VOC LIMITS (GRAMS PER LITER OF COATING)
  • COATING
  • ON AND AFTER 1-31-96
  • ON AND AFTER 7-1-97
  • Low Solid Stains, Toners, Washcoats
  • 480 g/L
  • 120 g/L
 
    1. No person shall supply, sell, solicit, offer for sale for use within the District any wood products coating that exceeds the VOC limits for new wood products set forth in Section 237.3 B.1.
    2. In addition, no person shall manufacture, blend, or repackage any wood products coating for use within the District, on new wood products, that exceeds the VOC limits set forth in Section 237.3 B.1.
  1. VOC CONTENT OF COATINGS FOR REFINISHING, REPAIRING, PRESERVING, OR RESTORING WOOD PRODUCTS
    1. Except as provided in Section 237.1 C., no person or facility shall apply any coating, to refinish, repair, preserve, or restore a wood product, which has a volatile organic compound (VOC) content, as applied, exceeding the applicable limits specified below. The VOC content of the coating shall be determined in accordance with Section 237.5 C.1.

 

 
  • VOC LIMITS (GRAMS PER LITER OF COATING) 
  • Less Water and Exempt Compounds
  • COATING
  • ON AND AFTER 7-1-97
  • Clear Topcoats
  • 680 g/L
  • Conversion Varnish
  • 550 g/L
  • Filler
  • 500 g/L
  • High-Solid Stains
  • 700 g/L
  • Inks
  • 500 g/L
  • Mold-Seal Coating
  • 750 g/L
  • Multi-Colored Coating
  • 680 g/L
  • Pigment Coating
  • 600 g/L
  • Sealer
  • 680 g/L
 
 
  • VOC LIMITS (GRAMS PER LITER OF COATING)
  • COATING
  • ON AND AFTER 7-1-97
  • Low-Solid Stains, Toners,Washcoats
  • 480 g/L
 
    1. No person shall supply, sell, solicit, offer for sale for use within the District any wood productscoating for refinishing, repairing, preserving, or restoring wood products that exceeds the VOC limits set forth in Section 237.3 C.1.
    2. In addition, no person shall manufacture, blend, or repackage any wood products coating, for use within the District, for refinishing, repairing, preserving, or restoring wood products, that exceeds the VOC limits set forth in Section 237.3 C.1.
  1. VOC CONTENT FOR STRIPPERS:
    1. Except as provided in Section 237.1 C., no person or facility shall apply any stripper which has a volatile organic compound (VOC) content, as applied less water and exempt compounds, of 350 grams/L or more, or has a composite partial vapor pressure of 2 mm Hg (0.04 psia) or more at 20oC (68oF), as calculated pursuant to Section 237.2 MM.
    2. No person shall supply, sell, solicit, offer for sale for use within the District, or apply any wood products stripper that exceeds the VOC limits set forth in Section 237.3 D.1.
    3. In addition, no person shall manufacture, blend, or repackage any wood products stripper, for use within the District that exceeds the VOC limits set forth in Section 237.3 D.1.
  2. EMISSION CONTROL SYSTEM REQUIREMENTS: In lieu of the applicable requirements of Sections 237.3 B., 237.3 C., and 237.3 D., emissions of VOC (excluding emissions from cleanup operations) may be controlled by an emission capture and control system which reduces VOC emissions to the atmosphere, provided that the system complies with the following:
    1. During any period of operation, the collection and control system shall have a collection efficiency of 90% and a control efficiency of 95% or greater, by weight;
    2. The collection system shall vent all drying oven exhaust to the control device and shall have one or more inlets for collection of fugitive emissions;
    3. During any period of operation of a thermal incinerator, combustion temperature shall be continuously monitored;
    4. During any period of operation of a catalytic incinerator, exhaust gas temperature shall be continuously monitored; and,
    5. Written approval for the use of such equipment is obtained from the Air Pollution Control Officer, prior to installation or use of the equipment.
  3. REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP MATERIALS: Any person using surface preparation and cleanup materials containing VOCs for wood products coating operations shall comply with all of the following requirements:
    1. Closed containers shall be used for the disposal of cloth or paper used for surface preparation, cleanup, and coating removal.
    2. A person shall not use VOC-containing materials for the cleanup of spray equipment used in wood products coating application operations, unless the spray equipment is cleaned in an enclosed system.
    3. VOC-containing materials shall be stored in containers, which are closed when not in use, and shall be disposed of in a manner that the VOCs are not emitted into the atmosphere.
    4. A person shall not perform surface preparation or cleanup with a material containing VOC in excess of 200 grams per liter (1.67 pounds per gallon).
  4. PROHIBITION OF SPECIFICATIONS: No person shall specify the use in the District of any coating, stripper, or surface preparation and cleanup material, to be applied to any wood products that are subject to the provisions of this rule, that does not meet the limits and requirements of this rule.

237.4 ADMINISTRATIVE REQUIREMENTS

  1. OPERATION AND MAINTENANCE PLAN:
    Any person using an approved emission control device pursuant to Section 237.3 E. as a means of complying with this rule shall submit, with the application for Authority to Construct, pursuant to Rule 501 - GENERAL PERMIT REQUIREMENTS, an Operation and Maintenance Plan for the emission control device to the Air Pollution Control Officer for approval. The Plan shall specify operation and maintenance procedures which will demonstrate continuous operation of the emission control device during periods of emissions-producing operations. The Plan shall also specify which records must be kept to document these operations and maintenance procedures. These records shall comply with the requirements of Section 237.5 A. The Plan shall be implemented upon approval of the Air Pollution Control Officer.
  2. LABELING REQUIREMENTS: VOC CONTENT:
    Each container of any coating subject to this rule and manufactured on or after January 31, 1996 shall display the maximum VOC content of the coating, as applied, and after any thinning as recommended by the manufacturer. VOC content shall be displayed as grams of VOC per liter of coating (less water and exempt solvent, and excluding any colorant added to tint bases). VOC content displayed may be calculated using product formulation data, or may be determined using the test method in Section 237.5 C.1.

237.5 MONITORING AND RECORDS:
 

  1. USAGE RECORDS:
    1. Any source within the District that is subject to this rule shall provide all of the data necessary to evaluate compliance including, but not be l