PLAAPCD RULE 236 WOOD PRODUCTS COATING OPERATIONS
LAST REVISED 02/09/95
                                  
                                  
                                  Adopted 11-03-94
                                  Revised 02-09-95

                                       CONTENTS

            100   GENERAL

                  101   APPLICABILITY
                  102   EXEMPTIONS

            200   DEFINITIONS

                  201   AEROSOL-SPRAY COATING
                  202   AIR ASSISTED AIRLESS SPRAY
                  203   AIRLESS SPRAY
                  204   BINDERS
                  205   CLEAR TOPCOAT
                  206   COATING
                  207   CRACKLE LACQUER
                  208   CUSTOM REPLICA FURNITURE
                  209   DETAILING OR TOUCH-UP GUNS
                  210   DIP COAT
                  211   ELECTROSTATIC APPLICATION
                  212   FAUX FINISH
                  213   FILLER
                  214   FLOW COATING
                  215   GRAMS OF VOC PER LITER OF COATING APPLIED, 
                        EXCLUDING WATER AND EXEMPT COMPOUNDS
                  216   GRAMS OF VOC PER LITER OF MATERIAL
                  217   HIGH-SOLIDS
                  218   HIGH-VOLUME-LOW-PRESSURE (HVLP) SPRAY
                  219   IMITATION WOOD GRAIN
                  220   INKS
                  221   LEAF FINISH
                  222   LOW-SOLIDS
                  223   MOLD-SEAL COATING
                  224   MULTI-COLORED COATING
                  225   OPAQUE STAINS
                  226   PIGMENTED COATINGS
                  227   REPAIR
                  228   ROLL COATER
                  229   SANDING SEALER
                  230   SEMITRANSPARENT STAIN
                  231   SIMULATED WOOD MATERIALS
                  232   STRIPPER
                  233   TONER
                  234   TOUCH-UP
                  235   WASH COAT
                  236   WOOD PRODUCTS
                  237   WOOD PRODUCT COATING OPERATIONS
            
            300   STANDARDS

                  301   LIMITS
                  302   CONTROL REQUIREMENTS
                  303   APPLICATION EQUIPMENT REQUIREMENTS
                  304   EVAPORATIVE LOSS MINIMIZTION
                  305   PROHIBITION OF SPECIFICATION

            400   ADMINISTRATIVE REQUIREMENTS

                  401   RECORDKEEPING
                  402   TEST METHODS
                  403   LABELING REQUIREMENTS
                  404   COMPLIANCE SCHEDULE
            
            100   GENERAL

                  101   APPLICABILITY:  The provisions of this rule shall 
                        apply to the application of coating to, and surface 
                        preparation of wood products, including furniture, 
                        cabinets, and custom replica furniture.  This rule 
                        shall not apply to residential noncommercial 
                        operations.  The provisions of this rule apply only 
                        to facilities located in the Sacramento Valley Air 
                        Basin portion of Placer County, as defined by 
                        California Code of Regulations, Title 17,
                        Division 3, Chapter 1, Subchapter 1.5, Article 1, 
                        Section 60106.

                  102   EXEMPTIONS

                        102.1 The provisions of the rule shall not apply to:

                                    a.    Aerosol-spray coatings for touch up 
                                          and repair.

                                    b.    Wood products coating application 
                                          operations that use a total of less 
                                          than 20 gallons of coating per year.

                                    c.    The application of coatings by 
                                          template in order to add designs, 
                                          letters, or numbers to wood
                                          products.

                                    d.    The application of coatings to 
                                          wooden musical instruments.

                                    e.    Residential noncommercial 
                                          operations.

                        102.2 ARCHITECTURAL COATINGS: The provisions of this 
                        rule shall not apply to the application of coatings 
                        to stationary structures and their appurtenances 
                        subject to the provisions of Rule 218 (Architectural 
                        Coatings).

                        102.3 REFINISHING, REPLACEMENT, AND CUSTOM REPLICA 
                        FURNITURE OPERATIONS: The provisions of Sections 301, 
                        302, and 303 shall not apply to any refinishing 
                        operation necessary for preservation, to return the 
                        wood product to original condition, to replace 
                        missing furniture to produce a matching set, or to 
                        produce custom replica furniture, provided records 
                        are maintained as specified in Section 401.

                        102.4 SPECIFIC FINISHES: The provisions of Sections 
                        301 and 303 shall not apply to coatings used to 
                        produce the following finishes, provided records are 
                        maintained as specified in
                              Section 401.1:

                                    a.    Crackle lacquers.
                                    b.    Faux finishes.
                                    c.    Imitation wood grain.
                                    d.    Leaf Finishes.

                        102.5 Any coating, finish, wood products 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 the Rule 219 
                        (Organic Sovlents) unless compliance with the limits 
                        specified in this rule is achieved.
            
            200   DEFINITIONS

                  201   AEROSOL-SPRAY COATING: a coating which is sold in a 
                  hand-held, pressurized, non-refillable container of 16 
                  ounces or less and which is expelled from the container 
                  in a finely divided spray when a valve on the container 
                  is depressed.

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

                  203   AIRLESS SPRAY: equipment used to apply coatings by 
                  use of fluid pressure without atomizing air, including 
                  heated airless spray.

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

                  205   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.

                  206   COATING: a material which is applied to a surface 
                  and which forms a film in order to beautify and/or protect 
                  such surface.

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

                  208   CUSTOM REPLICA FURNITURE: furniture individually 
                  produced for a specific client using methods of 
                  construction including materials, joinery, and finishes 
                  authentic to the period and in keeping with the style of 
                  furniture.

                  209   DETAILING OR TOUCH-UP GUNS: small air spray equipment, 
                  including air brushes, that operate at no greater than five 
                  (5) cfm air flow and no greater than 50 psig air pressure 
                  and are used to repair or touch-up portions of wood 
                  products.

                  210   DIP COAT: to dip an object into a vat of coating 
                  material and drain off any excess coating.

                  211   ELECTROSTATIC APPLICATION: method of spray 
                  application of coatings where an electrostatic potential 
                  is created between the part to be coated and the paint 
                  particles.

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

                  213   FILLER: a material whose primary function is to fill 
                  voids.

                  214   FLOW COATING: a coating application system where 
                  paint flows over the part and the excess coating drains 
                  back into the collection system.
                  
                  215   GRAMS OF VOC PER LITER OF COATING APPLIED, EXCLUDING 
                  WATER AND EXEMPT COMPOUNDS: the weight of VOC per combined 
                  volume of VOC and coating solids and can be calculated by 
                  the following equation:

                        Grams of VOC per Liter of Coating Applied Excluding 
                        Water and Exempt Compounds =


                  216   GRAMS OF VOC PER LITER OF MATERIAL: the weight of VOC 
                        per volume of material and can be calculated by 
                        the following equation:

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

                  218   HIGH-VOLUME-LOW-PRESSURE (HVLP) SPRAY: equipment used 
                        to apply coatings by means of a gun which operates 
                        between 0.1 and 10 psig air pressure.

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

                  220   INKS: a fluid that contains dyes and/or colorants 
                        and is used to make markings but not to protect 
                        surfaces.

                  221   LEAF FINISH: a finish used in conjunction with metal 
                        leaf or foil.

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

                  223   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.

                  224   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.

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

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

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

                  228   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.

                  229   SANDING SEALER: a coating containing binders, which 
                        seals the wood prior to application of the 
                        subsequent coatings.

                  230   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.

                  231   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.

                  232   STRIPPER: an organic compound which contains no more 
                        than five (5) percent solids by weight, and is 
                        applied to wood products, furniture or cabinets to 
                        remove coating and residue.

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

                  234   TOUCH-UP: that portion of the coating operation which 
                        in incidental to the main coating process but 
                        necessary to cover minor imperfections or to achieve 
                        coverage as required.

                  235   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 sanding sealers.

                  236   WOOD PRODUCTS: 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.

                  237   WOOD PRODUCT COATING 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   LIMITS: A person or facility shall not apply any 
                        coating to a wood product which has a VOC content, 
                        as applied, which exceeds the applicable limit 
                        specified below:


                                     VOC LIMITS
            Grams Per Liter of Coatings, Less Water and Exempt Compounds
----------------------------------------------------------------------------
                  | April 1, 1995    |October 1, 1995   |  April 1, 1996   |
---------------------------------------------------------------------------
Clear Topcoat    |680 g/l |  5.7    |550 g/l |  4.6    |275 g/l |  2.3    |
                 |        | lb/gal  |        | lb/gal  |        | lb/gal  |
----------------------------------------------------------------------------
Filler           | 500    |  4.2    | 500    |  4.2    | 275    |  4.2    |
----------------------------------------------------------------------------
High-Solids      | 700    |  5.8    | 700    |  5.8    | 240    |  2.0    |
Coatings         |        |         |        |         |        |         |
----------------------------------------------------------------------------
Inks             | 500    |  4.2    | 500    |  4.2    | 500    |  4.2    |
----------------------------------------------------------------------------
Mold-Seal        | 750    |  6.3    | 750    |  6.3    | 750    |  6.3    |
Coating          |        |         |        |         |        |         |
----------------------------------------------------------------------------
Multi-Colored    | 685    |  5.7    | 275    |  2.3    | 275    |  2.3    |
Coating          |        |         |        |         |        |         |
----------------------------------------------------------------------------
Pigmented        | 600    |  5.0    | 275    |  2.3    | 275    |  2.3    |
Coating          |        |         |        |         |        |         |
----------------------------------------------------------------------------
Sanding Sealer   | 740    |  6.2    | 550    |  4.6    | 240    |  2.0    |
----------------------------------------------------------------------------

                                   VOC LIMITS
                           Grams Per Liter of Material
----------------------------------------------------------------------------
                 |April 1, 1995     |October 1, 1995   |April 1, 1996     |
----------------------------------------------------------------------------
Low-Solids       |800 g/l |  6.7    |480 g/l |  4.0    |120 g/l |  1.0    |
Coatings         |        | lb/gal  |        | lb/gal  |        | lb/gal  |
----------------------------------------------------------------------------
Strippers        | 350    |  2.9    | 350    |  2.9    | 350    |  2.9    |
----------------------------------------------------------------------------


                  302   CONTROL REQUIREMENTS: The requirements of Section 301 
                        shall not apply to any person who installs and 
                        operates air pollution control equipment with a with 
                        an overall capture and control efficiency of at least 
                        85 percent on a mass basis as determined in 
                        Section 402.  The control equipment shall be under 
                        District permit.  In no case shall compliance through 
                        the use of this section result in VOC emissions in 
                        excess of the VOC emissions which would result
                        from compliance with Section 301.

                  303   APPLICATION EQUIPMENT REQUIREMENTS: Effective 
                        April 1, 1995, 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 proper 
                        operating procedures, and by the use of 
                        one of the following methods:

                        303.1 Electrostatic application;

                        303.2 High volume, low pressure (HVLP) spray;

                        303.3 Hand roller;

                        303.4 Flow coat;

                        303.5 Roll coater;

                        303.6 Dip coat;

                        303.7 Paint brush;

                        303.8 Detailing or touch-up guns;

                        303.9 Or until October 1, 1995, use air assisted 
                        airless spray and coatings that meet the VOC limits 
                        in Section 301.

                  304   EVAPORATIVE LOSS MINIMIZATION: Effective 
                        April 1, 1995, a person shall:

                        304.1 Only use solvents with a VOC content of less 
                        than 200 grams VOC per liter of material 
                        (1.67 lbs/gal) for cleanup and/or surface 
                        preparation, excluding cleaning of coating 
                        application equipment;

                        304.2 Use closed containers for the storage or 
                        disposal of solvent-laden cloth or paper used for 
                        surface preparation and cleanup.  Containers shall 
                        be nonabsorbent;

                        304.3 Store fresh or spent solvents in closed 
                        containers;

                        304.4 Not leave containers of stripper, coating, 
                        adhesive, catalyst or thinner open to the atmosphere 
                        when not in use;

                        304.5 Not use VOC-containing materials for the 
                        cleanup of equipment used in wood products coating 
                        operations unless:

                              a.    An enclosed system or equipment 
                              demonstrated, in accordance with Section 402.3, 
                              to be equally effective is used for cleaning. 
                              An enclosed system must totally enclose spray 
                              guns, cups, nozzles, bowls, and other parts 
                              during washing, rinsing and draining procedures;
                              or

                              b.    The cleaning solvent is flushed through 
                              the equipment in a contained manner that will 
                              not allow evaporation into the atmosphere.

                  305   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.

            400   ADMINISTRATIVE REQUIREMENTS

                  401   RECORDKEEPING

                        401.1 Any person subject to Section 301, 302, or 303 
                        and users of coatings exempt by Section 102.4, shall 
                        comply with the following requirements:

                              a. Maintain a current list of coatings in use 
                              which provides all of the data necessary to 
                              evaluate compliance, including the following 
                              information, as applicable:
                                    1. Coating, catalyst, or reducer.

                                    2. Manufacturer's recommended mix ratio 
                                       of components

                                    3. VOC content of coating, as applied.

                              b.    Maintain records on a daily basis that 
                                    provide the following information, as 
                                    applicable:

                                    1. Coating and mix ratio of components in 
                                       the coating used.

                                    2. Quantity of each coating applied.

                                    3. Identification of coating category.

                                    4. Type and amount of solvent used for 
                                       cleanup and surface preparation.

                              c.    Such records shall be retained and 
                                    available for inspection by the APCO for 
                                    the previous 24 month period.

                        401.2 Refinishing, Replacement and Custom Replica 
                        Furniture  Operations: Any person refinishing wood 
                        products or furniture, replacing missing furniture to 
                        produce a matching set, or producing custom replica 
                        furniture shall comply with the following 
                        requirements:

                              a.    Maintain a current list of coatings in use 
                                    which provides the following:

                                    1. Coating, catalyst, or reducer.

                                    2. Manufacturer's recommended mix ratio of
                                       components.

                                    3. VOC contents of coatings as apllied.

                              b.    Maintain records that provide the 
                                     following information such that daily 
                                     usages can be determined.

                                    1. Amount of coating, catalyst, and 
                                       reducer.

                                    2. Type and amount of solvent used for 
                                       cleanup and surface preparation.

                                    3. Type and amount of stripper used.

                                    4. Each type of wood product coated. Wood 
                                       product types are as follows:

                                          (A)   Refinishing.

                                          (B)   Replacement.

                                          (C)   Custom replica furniture.
                        
                        401.3 Such records shall be retained and available 
                        for inspection by the APCO for the previous 24 
                        month period.

                  402   TEST METHODS

                        402.1 ANALYSIS OF SAMPLES: Samples of VOC as 
                        specified in this rule shall be analyzed by EPA 
                        Method 24 and exempt halogenated compounds shall 
                        be analyzed by ARB Method 432.

                        402.2 DETERMINATION OF EMISSIONS: Emissions of VOC 
                        shall be measured by EPA Method 25, 25a, or 25b, 
                        and exempt halogenated compounds shall be analyzed 
                        by ARB Method 422.

                        402.3 Determination of emissions of VOC from spray 
                        gun cleaning systems shall be made using South Coast 
                        Air Quality Management District "General Test Method 
                        for Determining Solvent Losses from Spray Gun 
                        Cleaning Systems", dated October 3, 1989.

                        402.4 Capture efficiency shall be determined in 
                        accordance with the U.S. EPA protocols referenced 
                        in 40 CFR 52.741(a)(4)(iii).

                  403   LABELING REQUIREMENTS

                        403.1 VOC CONTENT: Each container or accompanying 
                        data sheet of any coating subject to this rule and 
                        manufactured after April 1, 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 compounds). 
                        VOC content displayed may be calculated using product 
                        formulation data, or may be determined using the test 
                        method in Section 402.

                        403.2 THINNING RECOMMENDATIONS: Each container or 
                        accompanying data sheet of any coating subject to 
                        this rule and manufactured after December 19, 1992 
                        shall display a statement of the manufacturer's 
                        recommendation regarding thinning of the coating. 
                        This requirement shall not apply to the thinning of 
                        coatings with water.

                  404   COMPLIANCE SCHEDULE

                        404.1 The owner/operator of a wood products coating 
                        application operation who becomes subject to the 
                        requirements of this rule through loss of exemption 
                        shall comply with the following increments of 
                        progress:

                              a. Within six (6) months from date the 
                              exemption was lost, submit a complete 
                              application for an Authority to Construct or 
                              Permit to Operate, as applicable.

                              b. Within 12 months from date the exemption 
                              was lost, be in full compliance with the 
                              requirements of this rule.

                        404.2 The owner or operator of any wood products 
                        coating operation which is subject to the 
                        requirements of this rule and which is installed or 
                        constructed on or after April 1, 1996, shall be in 
                        full compliance with the applicable requirements of
                        this Rule at the time of initial operation.