PLAAPCD RULE 238 FACTORY COATING OF FLAT WOOD PANELING
LAST REVISED 06/08/95



          RULE 238 FACTORY COATING OF FLAT WOOD PANELING

                        Adopted 11-03-94
                  (Revised 02-09-95, 06-08-95)

CONTENTS


100  GENERAL

     101  DESCRIPTION
     102  APPLICABILITY
     103  EXEMPTION, FURNITURE AND CABINET COMPONENTS
     104  EXEMPTION, ARCHITECTURAL COATINGS
     105  EXEMPTION, GENERAL

200  DEFINITIONS

     201  HARDBOARD
     202  HARDWOOD PLYWOOD
     203  NATURAL FINISH HARDWOOD PLYWOOD PANELS
     204  PRINTED INTERIOR PANELS
     205  THIN PARTICLEBOARD
     206  TILEBOARD
     207  ADHESIVE
     208  COATING
     209  INK
     210  PANEL
     211  WOOD FLAT STOCK
     212  VOLATILE ORGANIC COMPOUND (VOC)
     213  NON-HEAT-SET INK

300  STANDARDS

     301  EMISSION LIMITS
     302  APPLICATION EQUIPMENT REQUIREMENTS

400  ADMINISTRATIVE REQUIREMENTS

     401  COATING LIST
     402  MONITORING AND RECORDS
     403  DURATION OF RECORDS
               404  MANUAL OF PROCEDURES                     This Page Intentionally Left Blank100  GENERAL

     101  DESCRIPTION: The purpose of this Rule is to limit the emission of
          volatile organic compounds (VOC) from the application of coatings and
          adhesives to flatwood panels and wood flat stock including but not
          limited to the following:

          101.1          Printed interior panels made of hardwood plywood
                         and thin particle board
          101.2          Natural finish hardwood plywood
          101.3          Hardwood paneling
          101.4          Baseboard
          101.5          Wood flat stock
          101.6          Veneers, doors, door skins, and wood flat product
                         skins
          101.7          Tileboard and wallboard
          101.8          Exterior siding

          Any coating which is determined to be exempt from the provisions of
          this Rule shall be subject to the provisions of Rule 219, ORGANIC
          SOLVENTS, if not already subject to another Rule of Regulation 2,
          PROHIBITIONS.

     102  APPLICABILITY: 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.

     103  EXEMPTION, FURNITURE AND CABINET COMPONENTS: This Rule shall
          not apply to the surface coating of flat wood stock intended to 
          be used as a furniture or cabinet component, subject to Rule 236, 
          WOOD PRODUCTS COATINGS.

     104  EXEMPTION, ARCHITECTURAL COATINGS: The provisions of this Rule
          shall not apply to the application of coatings to stationary 
          structures and their appurtenances. Such coating is subject to 
          Regulation 218, ARCHITECTURAL COATINGS.

     105  EXEMPTION, GENERAL:

          The provisions of the rule shall not apply to:

          105.1     Aerosol-spray coatings for touch up and repair. 

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

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

          105.4     The application of coatings to wooden musical
                    instruments.

          105.5     Residential noncommercial operations.

200  DEFINITIONS

     201  HARDBOARD: A panel manufactured primarily from inter-felted ligno-
          cellulosic fibers which are consolidated under heat and pressure
          in a hot press.

     202  HARDWOOD PLYWOOD: Plywood whose surface layer is a veneer of
          hardwood.     
                    
     203  NATURAL FINISH HARDWOOD PLYWOOD PANELS: Panels whose original
          grain pattern is enhanced by essentially transparent finishes
          frequently supplemented by fillers and toners.

     204  PRINTED INTERIOR PANELS: Panels whose grain or natural surface is
          obscured by fillers and basecoats upon which a simulated grain or
          decorative pattern is printed. Thin

     205  THIN PARTICLEBOARD: A manufactured board 1/4 inch or less in thick-
          ness made of individual wood particles which have been coated with
          a binder and formed into flat sheets by pressure.

     206  TILEBOARD: Paneling that has a colored waterproof surface coating.

     207  ADHESIVE: Any substance that is applied for the primary purpose of
          bonding surfaces together.

     208  COATING: Any coating applied on any wood flat stock including but not
          limited to water repellant preservative, semitransparent stains,
          opaque stains, filler, or clear top coat.

     209  INK: Any fluid or viscous composition used in printing impressing or
          transferring an image onto a panel.

     210  PANEL: A flat piece of wood or wood product usually rectangular and
          used inside homes and mobile homes for wall decorations.

     211  WOOD FLAT STOCK: Panels containing wood including but not limited
          to redwood stocks, plywood panels, particle boards, composition
          hardboards, and any other panels containing solid wood or wood
          product.

     212  EXEMPT COMPOUNDS - For the purposes of this rule, exempt compounds
          are the following:
          212.1          Methane
          212.2          Carbon dioxide
          212.3          Carbon monoxide
          212.4          Carbonic acid
          212.5          Metallic carbides or carbonates
          212.6          Ammonium carbonate
          212.7          1,1,1-trichloroethane
          212.8          Methylene chloride
          212.9          2,2-dichloro-1,1,1-trifluoroethane (HCFC-123)
          212.10    2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
          212.11    Trichlorofluoromethane (CFC-11)
          212.12    Dichlorodifluoromethane (CFC-12)
          212.13    1,1,1-trichloro-2,2,2-trifluoroethane (CFC-113)
          212.14    1-chloro-1,1-difluoro-2-chloro-2,2-difluoroethane
                    (CFC-114)
          212.15    Chloropentafluoroethane (CFC-115)
          212.16    Pentafluoroethane (HFC-125)
          212.17    1,1,2,2-tetrafluoroethane (HFC-134)
          212.18    Tetrafluoroethane (HFC-134a)
          212.19    1,1-dichloro-1-fluoroethane (HCFC-141b)
          212.20    1-chloro-1,1-difluoroethane (HCFC-142b)
          212.21    1,1,1-trifluoroethane (HFC-143a)
          212.22    Chlorodifluoromethane (HCFC-22)
          212.23    Trifluoromethane (HFC-23)
          212.24    Difluoroethane (HFC-152a)
          212.25    The following four classes of perfluorocarbon compounds:
                         a.   Cyclic, branched, or linear, completely
                              fluorinated alkanes.
                         b.   Cyclic, branched, or linear, completely
                              fluorinated ethers with no unsaturations.
                         c.   Cyclic, branched, or linear, completely
                              fluorinated tertiary amines with no
                              unsaturations.
                         d.   Sulfur-containing perfluorocarbons with no
                              unsaturations and with sulfur bonds only to
                              carbon and fluorine.
        Perfluorocarbon compounds will 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.

     213  NON-HEAT-SET INK: An ink which dries by oxidation and absorption
          into the substrate without the use of heat from dryers or ovens.

300  STANDARDS

     301  EMISSION LIMITS: A person shall not apply to any wood flat stock
          or wood panel any coating in excess of the following limits,
          (expressed as grams of VOC per liter of coating used, excluding
          water) alternatively an emission control system with the overall
          efficiency of the system (capture efficiency multiplied by control
          efficiency) shall not be less than 90 percent by weight in reducing
          emissions of organic compounds and meets the requirements of Regula-
          tion 5 Rule 501, GENERAL PERMIT REQUIREMENTS:


Wood Flat Stock Coating        250 g/l        (2.1 lbs/gal)

Adhesive                       250 g/l        (2.1 lbs/gal)

Inks                           250 g/l        (2.1 lbs/gal)


   302  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: 

          302.1     Electrostatic application;
          302.2     High volume, low pressure (HVLP) spray;
          302.3     Hand roller;
          302.4     Flow coat;
          302.5     Roll coater;
          302.6     Dip coat;
          302.7     Paint brush;
          302.8     Detailing or touch-up guns;
          302.9     Or until October 1, 1995, use air assisted airless spray
                    and coatings that meet the VOC limits in Section 301.

400  ADMINISTRATIVE REQUIREMENTS

     401  COATING LIST: Any Person subject to Section 301 shall maintain a
          current list of coatings and adhesives in use which provides all of the
          data necessary to evaluate compliance.          
          401.1     All solvent, including waste solvent and waste solvent
                    residues, shall be stored in closed containers at all
                    times.  The containers shall have a label indicating the
                    name of the solvent/material they contain.

          401.2     If distillation recovery of waste solvent is performed,
                    solvent residues shall not contain more than 10 percent
                    solvent by volume after distillation.

          401.3     Waste solvent and waste solvent residues, shall be
                    disposed of by one of the following methods:
               a.   A commercial waste solvent reclamation service licensed by
                    the State of California.
               b.   At a facility that is federally or state licensed to
                    treat, store, or dispose of such waste.
               c.   Recycling in conformance with Section 25143.2 of the
                    California Health and Safety Code.

     402  MONITORING AND RECORDS

          402.1     RECORDS: Any person subject to this Rule shall maintain
                    records on a daily basis that provide the following
                    information as applicable:

               a.   Coating and mix ratio of components in the coating or
                    adhesive used 
               b.   Quantity of each coating or adhesive applied
               c.   Description of substrate coated
               d.   Oven or cure temperature
               e.   Type and amount of solvent used for cleanup and surface
                    preparation
     
     403  DURATION OF RECORDS:   All records maintained pursuant to this rule 
          shall be retained for at least two years from date of entry, with
          the exception that sources subject to the requirements of Rule 507,
          FEDERAL OPERATING PERMIT PROGRAM, shall retain records at least five 
          years.  Records shall be made available for inspection by the Air
          Pollution Control Officer upon request.

     404  MANUAL OF PROCEDURES

          404.1     ANALYSIS OF SAMPLES: Samples of volatile organic
                    compounds as defined in the Rule shall be analyzed as
                    prescribed in the EPA Method 24. Samples of volatile
                    organic compounds in non-heat set inks as defined in this
                    Rule shall be analyzed as Prescribed in EPA Method 24.

          404.2     DETERMINATION OF EMISSIONS: Emissions of precursor
                    organic compounds as specified in Sections 301 shall be
                    measured as prescribed in EPA Method 25.

     405  TEST METHODS

          405.1     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.          
          
          405.2     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.

          405.3     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.

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