MOJAVE DESERT AIR QUALITY MANAGEMENT DISTRICT
 
 
 
RULE 1114
WOOD PRODUCTS COATING OPERATIONS
(Adopted: March 2, 1992; Amended: February 22, 1995)

(A) General

  1. Purpose
  2. (a) The purpose of this Rule is to limit the emission of volatile organic compounds from the coating operation of wood products.

  3. Applicability
  4. (a) This Rule applies to wood product coating operations within the Mojave Desert Air Quality Management District.
     
     

(B) Definitions

For the purposes of this rule, the following definitions shall apply:

  1. "Adhesive" is any substance that is capable of bonding surfaces together by attachment.
  2. "Aerosol-Spray Coating" is a coating which is sold in a hand-held, pressurized, non-refillable container of sixteen (16) ounces or less and which is expelled from the container in a finely divided spray when a valve on the container is depressed.
  3. "Binders" are non-volatile polymeric organic materials (resins) which form the surface film in coating applications.
  4. "Clear Topcoat" means a coating which contains resins and binders but not opaque pigments and which is specifically formulated to form a transparent or translucent solid protective film.
  5. "Coating" is any coating applied on any wood stock including, but not limited to, water repellent preservative, semitransparent stains, opaque stains, filler, clear topcoat; which is applied to a surface and which forms a film in order to beautify and/or protect such surface.
  6. "Coating Line" means automatic coating application equipment, printing equipment, flash-off area, ovens, conveyors, and other equipment operating in an uninterrupted series for the purpose of applying coatings, to wood flat stock.
  7. "Dip Coat" is to dip an object into a vat of coating material and drain off any excess coating.
  8. "Exempt Compounds" are any of the following compounds which have been determined to be non-precursors of ozone:
  9. (a) Group I

      chlorodifluoromethane (HCFC-22)

      dichlorotrifluoroethane (HCFC-123)

      tetrafluoroethane (HFC-134a)

      dichlorofluoroethane (HCFC-141b)

      chlorodifluoroethane (HCFC-142b)

      trifluoromethane (HFC-23)

      2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)

      pentafluoroethane (HFC-125)

      1,1,2,2-tetrafluoroethane (HFC-134)

      1,1,1-trifluoroethane (HFC-143a)

      1,1-difluoroethane (HFC-152a)

      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

      sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine

    (b) Group II
      methylene chloride

      1,1,1-trichloroethane (methyl chloroform)

      trichlorotrifluoroethane (CFC-113)

      dichlorodifluoromethane (CFC-12)

      trichlorofluoromethane (CFC-11)

      dichlorotetrafluoroethane (CFC-114)

      chloropentafluoroethane (CFC-115)

  10. "Flow Coat" is to coat an object by flowing a stream of coating over an object and draining off any excess coating.
  11. "Grams of VOC Per Liter of Coating Less Water and Less Exempt Compounds" is the weight of VOC per combined volume of VOC and coating solids and can be calculated by the following equation:
  12. Grams of VOC per Liter of Coating Less Water and Less Exempt Compounds: 

        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

  13. "Grams of VOC Per Liter of Material" is the weight of VOC per volume of material and can be calculated by the following equation:
  14. Grams of VOC per Liter of Material: 

        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

  15. "High-Solids Stains" are stains containing more than 1 pound of solids per gallon by weight and can include wiping stains, glazes, and opaque stains.
  16. "High-Volume Low-Pressure (HVLP) Spray" is to spray a coating by means of a gun that operates between 0.1 and 10.0 psig air pressure, not to exceed 10 psig, measured at the air cap of the coating application system, and a permanent liquid coating pressure of not more than 50 psig.
  17. "Ink" is a fluid that contains dyes and/or colorants and is used to make markings but not to protect surfaces.
  18. "Low-Solids Stains" are stains containing 1 pound of solids per gallon, or less, by weight.
  19. "Mold-Seal Coating" is 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.
  20. "Opaque Stains" are all stains not classified as semitransparent stains.
  21. "Panel" is a flat piece of wood or wood products, usually rectangular, and used inside homes and mobile homes for wall decorations.
  22. "Pigmented Coatings" are opaque coatings which contain binders and colored pigments which are formulated to hide the wood surface, either as an undercoat or topcoat.
  23. "Reactive Diluent" is a liquid which is a VOC during application and one in which, through chemical reaction such as polymerization, 20 percent or more of the VOC becomes an integral part of a finished coating. 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:
  24. Grams of VOC/Liter of Coating Less Water and Less Exempt Compounds = 

 
  1. "Rate Per Day" is the amount applied between 12:00 a.m. and 11:59 p.m. on the same calendar day.
  2. "Rate Per Calendar Year" is the amount applied between 12:00 a.m. January 1 and 11:59 p.m. December 31.
  3. "Repair Coating" is a coating used to re-coat portions of a product which has sustained mechanical damage to the coating following normal painting operations.
  4. "Roll Coater" is 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.
  5. "Sealer" is a coating, containing binders, which seals the wood prior to application of the subsequent coatings.
  6. "Semitransparent Stains" are coatings which are formulated to change the color of a surface but not conceal the surface.
  7. "Simulated Wood Materials" are materials, such as plastic, glass, metal, that are made to give a wood-like appearance or are processed like a wood product.
  8. "Stencil Coating" is 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.
  9. "Stripper" is a liquid used to remove cured coatings, cured inks and/or cured adhesives.
  10. "Toner" is a wash coat which contains binders and dyes or pigments to add tint to a coated surface.
  11. "Touch-up Coating" is a coating used to cover minor coating imperfections appearing after the main coating operation.
  12. "Transfer Efficiency" is the ratio of the weight of coating solids deposited on an object to the total weight of coating solids used in a coating application step, expressed as a percentage.
  13. "Volatile Organic Compound (VOC)" Is any volatile compound of carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and exempt compounds.
  14. "Wash Coat" is a coating that contains no more than 1.0 pounds of solids per gallon, by weight, which is used to seal wood surfaces, prevent undesired staining, and control penetration.
  15. "Water Repellent Preservative" is a penetrating coating designed to protect bare wood from mildew, decay, insect attack, and water staining.
  16. "Wood Flat Stock" is defined as panels containing wood including, but not limited to, redwood stocks, plywood panels, particle boards, composition hard boards, and any other panels containing solid wood or wood product.
  17. "Wood Products" are those surface coated room furnishings which include cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, and any other coated object made of solid wood and/or wood composition and/or made of simulated wood material used in combination with solid wood or wood composition.
  18. "Wood Product Coating Application Operations" are 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.
(C) Requirements
  1. VOC Content of Coatings & Adhesives
  2. (a) Any owners and/or operators of wood products coating operations 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, unless emissions to the atmosphere are controlled by air pollution abatement equipment with an overall capture and abatement efficiency of at least 85 percent (as determined pursuant to subparagraph (G)(2)(d)).

 
LIMITS 
Grams of VOC Per Liter of Coating, 
Less Water and Less Exempt Compounds
Coating 
On and After 9/1/92
On and After 1/1/96
On and After 1/1/97
(g/l) (lb/gal) (g/l) (lb/gal) (g/l) (lb/gal)
Clear Topcoats
containing Group II exempt compounds 550 (4.6) 275 (2.3) 275 (2.3)
not containing Group II exempt compounds 680* (5.7)* 275 (2.3) 275 (2.3)
Fillers 500 (4.2) 500 (4.2) 275 (2.3)
High-Solid Stains 700 (5.8) 700 (5.8) 240 (2.0)
Inks 500 (4.2) 500 (4.2) 500 (4.2)
Mold-Seal Coatings 750 (6.3) 750 (6.3) 750 (6.3)
Multi-Colored Coatings 685 (5.7) 275 (2.3) 275 (2.3)
Pigmented Coatings 600 (5.0) 275 (2.3) 275 (2.3)
Sealers
containing Group II exempt compounds 550 (4.6)  550 (4.6)  240 (2.0)
not containing Group II exempt compounds 680* (5.7)*  680 (5.7) 240 (2.0)
Strippers 800 (6.7) 350 (2.9) 350 (2.9)
Adhesives 250 (2.1) 250 (2.1) 250 (2.1)
 
Grams of VOC Per Liter of Material
Item 
On and After 
9/1/92
On and After 
1/1/97
(g/l) (lb/gal) (g/l) (lb/gal)
containing Group II exempt compounds 480 (4.0) 120 (1.0)
not containing Group II exempt compounds 800* (6.7)* 120 (1.0)
 

* Effective on or after February 22, 1995

  1. Transfer Efficiency
  2. (a) On and after September 1, 1992, any person 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 manufacturer's suggested guidelines, and by the use of one of the following methods:

      (i) Flow Coat, or

      (ii) Dip Coat, or

      (iii) High-Volume Low-Pressure (HVLP) spray, or

      (iv) Paint brush, or

      (v) Hand roller, or

      (vi) Roll Coater, or

      (vii) Such other coating application methods as are demonstrated to the Air Pollution Control Officer to be capable of achieving at least 65 percent transfer efficiency and for which written approval of the Air Pollution Control Officer has been obtained.
       
       

  3. Clean-up Solvent and Equipment Cleaning
  4. (a) The requirements of this Section shall apply to any person using solvent for surface preparation and cleanup.

      (i) A person shall not use an organic compound for surface preparation, except strippers, with a VOC content in excess of 200 grams of VOC per liter of material (1.67 pounds per gallon).

      (ii) A person shall use closed, nonabsorbent containers for the storage or disposal of cloth or paper used for solvent surface preparation and cleanup.

      (iii) A person shall store fresh or spent solvent in closed containers.

      (iv) A person shall not use organic compounds for the cleanup of spray equipment including paint lines unless an enclosed system is used for cleanup. The system must enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing and draining procedures. Equipment used shall minimize the evaporation of organic compounds to the atmosphere.

  5. Prohibition of Specifications
  6. (a) Any 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 requirements of this rule. The requirements of this paragraph shall apply to all written or oral contracts.

  7. Continuous Monitors
  8. (a) Each coating operation subject to subparagraph (C)(1)(a) shall have a continuous monitor, as approved by the Air Pollution Control Officer, for any add-on control device used to meet the control requirement.

    (b) Records of the monitoring devices pursuant to subparagraph (F)(1) and other data necessary to demonstrate compliance with the control requirements shall be maintained on the premises and made accessible for a period of two years to the Air Pollution Control Officer in a form and manner as specified by the Air Pollution Control Officer.

    (c) Compliance with subparagraph (C)(1)(a) shall be determined by source testing and/or evaluating continuous monitor data.

    (d) Each monitoring device used pursuant to subparagraph (F)(1) shall be calibrated in a manner approved by the Air Pollution Control Officer; and maintained in optimum working order.

  9. Compliance Statement Requirement
  10. (a) The manufacturer of coatings subject to this rule shall include a designation of VOC as supplied on data sheets; including coating components, expressed in grams per liter or pounds per gallon, excluding water and exempt solvents.

  11. Increased Use of Methylene Chloride and 1,1,1-Trichloroethane: Effective February 22, 1995, a person shall not increase the use of the Group II exempt compounds methylene chloride and/or 1,1,1-trichloroethane to meet the VOC content standards of this Rule.

  12.  
     
(D) Exemptions
  1. The provisions of subparagraphs (C)(1)(a) and (C)(2)(a) of this rule shall not apply to:
  2. (a) Aerosol-spray coatings for touch up and repair.

    (b) Facilities that use a total of less than one gallon of coating, including any VOC-containing materials added to the original coating as supplied by the manufacturer, subject to this rule, in any one day, or; surface coating operations that emit not more than 3 pounds of VOCs per day and not more than 200 pounds of VOCs per calendar year.

    (c) Laminating of fiberglass, metal, or plastic sheets to wood panels.

    (d) The application of coatings to musical instruments.

  3. The January 1, 1996 and January 1, 1997 limits which are set forth in subsection (C)(1)(a) shall not apply to:
  4. (a) wood products coating operations which emit not more than 3 pounds of VOC per hour, before add-on controls; or

    (b) wood products coating operations which emit not more than 15 pounds of VOC per day, before add-on controls; or

    (c) facilities that do not exceed 10 tons per year theoretical potential emissions. "Theoretical potential emissions" is defined as the greater of design capacity or maximum production (based on 8760 hours/year) before add-on controls.

  5. For the purposes of claiming an exemption pursuant to subsections (D)(2)(a) or (D)(2)(b), hourly or daily emissions shall be considered from January 1, 1996 forward.
  6. Once a facility exceeds 3 pounds of VOC per hour, or 15 pounds of VOC per day, respectively, it will remain subject to the January 1, 1996 and January 1, 1997 limits even if its emissions later fall below the applicability threshold.
  7. Any facility classified as exempt or claiming to be exempt under this section (D), shall meet the record keeping requirements of this rule so as to be able to certify the exemption status.

  8.  
     
(E) Administrative Requirements
  1. Rule 442 Applicability
  2. (a) 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 are achieved.
     
     

(F) Monitoring and Records
  1. Coating Records
  2. (a) Any person subject to Sections (C)(1)(a), (C)(3)(a)(i), or (D)(1)(b) shall comply with the following requirements:

      (i) The person shall maintain and have available during an inspection, a current list of coatings in use which provides all of the coating data necessary to evaluate compliance, including the following information, as applicable:
      1. coating, catalyst, and reducer used.
      2. mix ratio of components used.
      3. VOC content of coating as applied.
      4. quantity of Group II exempt compounds used.
      (ii) The person shall maintain records on a daily basis including:
      1. coating and mix ratio of components used in the coating; and
      2. quantity of each coating applied.
      (iii) The person shall maintain records on a daily basis showing the type and amount of solvent used for cleanup, surface preparation, and paint removal.

      (iv) Such records shall be retained and available for inspection by the Air Pollution Control Officer for the previous 24 month period.
       
       

(G) Test Methods
  1. A violation of the limits contained in this Rule as determined by any one of these test methods shall constitute a violation of this Rule.
  2. The following specified test methods shall be used to determine compliance with the provisions of this Rule.
  3. (a) Determination of VOC Content: Samples of coatings and solvent as specified in Section (C)(1)(a) shall be analyzed as prescribed by EPA Reference Method 24 for VOC content (without correction for exempt compounds) and ASTM D4457-85, or ARB Method 432 for determination of emissions of exempt compounds. Perfluorocarbon compounds shall be assumed to be absent from a product or process unless a manufacturer or facility operator identifies the specific individual compounds (from the broad classes of perfluorocarbon compounds) and the amounts present in the product or process and provides a validated test method which can be used to quantify the specific compounds.

    (b) Determination of Emissions: Emissions of volatile organic compounds as specified in Section (C)(1)(a) shall be measured as prescribed by EPA Reference Method 25 for determination of VOC emissions (without correction for exempt compounds) and EPA Method 18, or ARB Method 422 for measuring emission of exempt compounds.

    (c) Determination of Transfer Efficiency: Transfer efficiency as required by Section (C)(2)(a) shall be determined by South Coast Air Quality Management District Spray Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989.

    (d) Determination of Overall Abatement Efficiency: Overall abatement efficiency is the product of capture efficiency as determined by procedures described in 55 FR 26865, 29 June, 1990, and abatement device efficiency.