SDAPCD RULE 67.11 WOOD PRODUCTS COATING OPERATIONS               
LAST REVISED 12/18/90

               
               RULE 67.11.    WOOD PRODUCTS COATING OPERATIONS
                              (Effective 3/14/89:  Rev. Effective 12/18/90)


               (a)  APPLICABILITY

               This rule is applicable to all surface coating of wood
          products including refinishing or refurbishing, in which volatile
          organic compounds (VOC) are employed.  Operations subject to this
          rule and in compliance with Section (d) of this rule shall not be
          subject to Rule 66.

               (b)  EXEMPTIONS

                    (1)  The provisions of this rule shall not apply to
               wood products coating operations at a stationary source, as
               defined in Rule 20.1, using less than a total of 500 gallons
               of coatings in every consecutive twelve-month period.  It
               shall be the responsibility of any person claiming this
               exemption to maintain daily records of coating usage.  These
               records shall be retained on site for at least three years
               and shall be made available to the District immediately upon
               request.

                    (2)  The provisions of this rule shall not apply to
               coating operations subject to District Rules 67.0 and 67.18.

               (c)  DEFINITIONS

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

                    (1)  "Application Equipment" means equipment used in
               hand application methods such as, but not limited to, paint
               brushes, hand rollers, caulking guns, trowels, spatulas,
               syringe daubers, rags and sponges, and equipment used in
               mechanically operated application methods, including, but
               not limited to spray guns, spinning disks, and pressure
               pots.

                    (2)  "Binder" means any non-volatile polymeric organic
               material, such as resin, which forms the surface film during
               coating applications.

                    (3)  "Clear Topcoat" means any final coating which
               contains binders, but not opaque pigments, and which is
               specifically formulated to form a transparent or translucent
               solid protective film.

                    (4)  "Exempt Compound" means any of the following
               compounds:  1,1,1-trichloroethane, methylene chloride,
               trichlorofluoromethane (CFC-11), dichlorodifluoromethane
               (CFC-12), trifluoromethane (FC-23), trichlorotrifluoroethane
               (CFC-113), dichlorotetrafluoroethane (CFC-114),
               chloropentafluoroethane (CFC-115), chlorodifluoromethane
               (CFC-22), dichlorotrifluoroethane (HCFC-123),
               dichlorofluoroethane (HCFC-141b), tetrafluoroethane (HFC-
               134a), and chlorodifluoroethane (HCFC-142b).

                    (5)  "Glaze Stain" means a semitransparent tinted
               coating applied on a previously coated surface to produce a
               decorative effect.

                    (6)  "High-Solids Stain" means a stain containing more
               than one pound of solids per gallon and includes wiping
               stains, glazes and opaque stains.

                    (7)  "High-Volume Low-Pressure (HVLP) Spray" means a
               coating application method using pressurized air at a
               permanent pressure between 0.1 and 10.0 psig, not to exceed
               10.0 psig, measured at the air cap of the coating
               application system, and a  permanent liquid coating pressure
               of not more than 50 psig.

                    (8)  "Low-Solids Stain" means a stain containing one
               pound of solids per gallon, or less.

                    (9)  "Multi-Colored Coating" means a coating which
               exhibits more than one color when applied and which is
               packaged in a single container and applied in a single coat.

                    (10) "Opaque Stain" means any stain which is used to
               give character or texture to wood, and which contains
               pigments not classified as semi-transparent.

                    (11) "Pigmented Coating" means any opaque coating
               containing binders and colored pigments, and formulated to
               hide the wood surfaces.

                    (12) "Sealer" means any coating which contains binders
               and which seals wood surfaces prior to the application of
               subsequent coatings.

                    (13) "Semi-transparent Stain" means a solution of
               coloring matter which contains dyes and/or semi-transparent
               pigments and which is formulated to change surface color but
               not to conceal surface grain.  These include sap stain and
               non-grain raising stain.

                    (14) "Stripper" means a liquid applied to remove a
               coating or coating residue.

                    (15) "Toner" means any coating which contains binders
               and dyes or pigments and which is used to add tint to a
               coated surface.

                    (16) "Transfer Efficiency" means the ratio of the
               weight of coating solids adhering to the part being coated
               to the weight of coating solids used in a coating operation,
               expressed as a percentage.

                    (17) "Wash Coat" means a coating that contains no more
               than 1.0 pounds of solids per gallon which is used to seal
               wood surfaces, prevents undesired staining and which
               controls penetration.

                    (18) "Wood Products" means any furnishings, including
               tables, chairs, beds, sofas, shutters and cabinets which are
               not permanently attached to stationary structures at the
               time of coating, art objects, and any other objects made of
               solid wood, wood composition, bamboo and/or rattan, or which
               are primarily fabricated with such materials.

                    (19) "Wood Products Coating Operation" means the
               application of coating materials to wood products and
               includes coating application equipment, flash-off area,
               spray booths, dip tanks, ovens, conveyors and/or other
               equipment operated for the purpose of applying and drying or
               curing wood products coating materials.

                    (20) "Volatile Organic Compound" (VOC) means any
               volatile compound containing at least one atom of carbon
               excluding methane, carbon monoxide, carbon dioxide, carbonic
               acid, metallic carbides or carbonates, ammonium carbonates,
               and exempt compounds which may be emitted to the atmosphere
               during application of and/or subsequent drying or curing of
               coatings subject to this rule.  VOC limits of coatings and
               strippers are expressed in grams of VOC per liter of coating
               or stripper as applied, minus water and minus exempt com-
               pounds.  VOC limits of low-solid stains, toners, washcoats
               and cleaning materials are expressed in grams of VOC per
               liter of material.

               (d)  STANDARDS

                    (1)  Application Equipment.

                    Any person applying coatings to wood products shall use
               one of the following application methods:

                         (i)  Brush coat, or

                         (ii) Dip coat, or

                         (iii)Roller coat, or

                         (iv) Wiping, or

                         (v)  Electrostatic coat, or

                         (vi) High-volume low-pressure (HVLP) coat, or

                         (vii)Other coating application methods that are
                    demonstrated to achieve as a minimum 65 percent
                    transfer efficiency or have transfer efficiency at
                    least equal to one of the above application methods,
                    and which are operated such that the parameters under
                    which they were tested are permanent features of the
                    method, and are approved by the Air Pollution Control
                    Officer, California Air Resources Board and
                    Environmental Protection Agency.
                         The provisions of Subsection (d)(1) shall not
                    apply to coatings that are applied by the use of air
                    brushes with a coating capacity of two ounces (59.1 ml)
                    or less through a template to add designs, letters
                    and/or numbers to the wood products.

                    (2)  VOC Content of Coatings and Strippers.

                         (i)  A person shall not apply any coatings or
                    strippers subject to this rule which, as applied,
                    contain VOC in excess of the following:

                                             VOC LIMIT (grams per liter of
                                             coating or stripper, as
                                             applied, less
                         CATEGORY            water and exempt compounds)

                         Clear Topcoats                700
                         High-Solids Glaze Stains      700
                         High-Solids Non-Glaze Stains  800
                         Multi-Colored Coatings        685
                         Pigmented Coatings            700
                         Sealers                       700
                         Strippers                     800
                         Low-Solids Stains, Toners 
                           and Washcoats               800


                         (ii) On and after the following dates, a person
                    shall not apply any coatings or strippers subject to
                    this rule which contain VOC in excess of the following
                    limits:

                                             VOC LIMIT (grams per liter of
                                             coating or stripper, as
                                             applied, less
                         CATEGORY            water and exempt compounds)

                                        Effective 12/31/90  Effective 1/1/95

                     Clear Topcoats                550            275
                     High-Solids Glaze Stains      700            700
                     High-Solids Non-Glaze Stains  700            700
                     Multi-Colored Coatings        685            275
                     Pigmented Coatings            600            275
                     Sealers                       550            550
                     Strippers                     350            350
                     Any Other Coating             420            275


                         CATEGORY       VOC LIMIT (grams per liter of
                                        material as applied)

                                        Effective 12/31/90   Effective 1/1/95

                      Low-Solids Stains, 
                        Toners and Washcoats       480            480

                    (3)  Surface Preparation Materials:

                         (i)  A person shall not use VOC containing
                    materials which have a VOC content of more than 200
                    grams per liter of material for surface preparation
                    excluding cleaning of coating application equipment; or

                         (ii) A person shall not use a VOC containing
                    material which has a composite vapor pressure greater
                    than 45 mm Hg at a temperature 20C (68F) for surface
                    preparation, excluding cleaning of coating application
                    equipment.  After January 1, 1992, the VOC content of
                    such material shall not be greater than 200 grams per
                    liter regardless of the vapor pressure of the material.

                    (4)  Cleanup of Equipment

                    Effective May 1, 1991, a person shall not use VOC
               containing materials for the cleanup of equipment used in
               coating operations unless:

                         (i)  A system is used that totally encloses the
                    component parts being cleaned during the washing,
                    rinsing, and draining processes; or

                         (ii) The cleaning solvent is transferred through
                    the application equipment, without exposure to air,
                    into a container which has in place an apparatus or
                    cover which completely covers the container and has no
                    visible holes, breaks, openings or separations between
                    adjoining components of the container or container
                    cover; or

                         (iii) The cleaning solvent has a VOC content of
                    less than 200 grams per liter.

                    (5)  A person shall not sell, offer for sale, or apply
               any coating or cleaning solvent for use in wood products
               coating operations that, after December 18, 1990 was newly
               formulated to contain or reformulated to increase the
               content of methylene chloride, trichlorofluoromethane (CFC-
               11), dichlorodifluoromethane (CFC-12),
               trichlorotrifluoroethane (CFC-113),
               dichlorotetrafluoroethane (CFC-114), or
               chloropentafluoroethane (CFC-115).

                    (6)  After December 18, 1990 a person shall not
               manufacture, sell, offer for sale, or supply any coating or
               cleaning material for use in wood products coating
               operations unless the coating or cleaning material container
               displays the content of methylene chloride, trichlo-
               rofluoromethane (CFC-11), dichlorodifluoromethane (CFC-12),
               trichlorotrifluoroethane (CFC-113),
               dichlorotetrafluoroethane (CFC-114), or
               chloropentafluoroethane (CFC-115).

               (e)  CONTROL EQUIPMENT

                    (1)  Any person subject to this rule can comply with
               the provisions of Subsection (d)(2) by using air pollution
               control equipment which has been approved in writing by the
               Air Pollution Control Officer provided that the VOC
               emissions from such operations are reduced such that:

                         (i)  The air pollution control equipment has been
                    installed in accordance with an Authority to Construct:

                         (ii) The control device reduces VOC emissions, by
                    at least 95 percent by weight; and

                         (iii) The emission collection system which captures
                    and transports emissions to the air pollution control
                    device collects at least 90 percent by weight of the
                    emissions generated by the coating operation, including
                    all VOC emissions from applied coatings.

                    (2)  A person electing to comply with the provisions of
               Subsection (d)(2) by using air pollution control equipment
               shall submit to the Air Pollution Control Officer for
               approval an Operation and Maintenance Plan for the VOC air
               pollution control device and emission collection system.
               Such plan shall:

                         (i)  Identify all key system operating parameters.
                    Key system operating parameters are those necessary to
                    ensure compliance with Subsections (e)(1)(ii) and
                    (e)(1)(iii) of this section.

                         (ii) Include proposed inspection schedules,
                    anticipated ongoing maintenance, and proposed
                    recordkeeping practices regarding the key system
                    operating parameters.

                    (3)  The Operation and Maintenance Plan must be
               submitted to the Air Pollution Control Officer and receive
               approval prior to operation of the air pollution control
               equipment.  A person subject to the requirements of this
               section shall implement the plan on the approval of the Air
               Pollution Control Officer.

               (f)  RECORDKEEPING

               Effective December 18, 1990, any person applying coatings
          and/or solvents to wood products shall maintain records in
          accordance with the following requirements:
                    
                    (1)  Maintain a current list of coatings, strippers,
               thinners, surface preparation and cleaning materials in use
               which provides data necessary to evaluate compliance,
               including, but not limited to:

                         (i)  Type and/or category of coating, stripper,
                    thinner, surface preparation or cleaning material used;

                         (ii) Mix ratio of components; and

                         (iii) VOC content of each coating, stripper,
                    thinner, surface preparation and cleaning material, as
                    applied.

                    (2)  Maintain daily records showing amount of each
               coating, stripper, thinner, cleaning and surface preparation
               material used.

                    These records shall be retained for at least three
               years and shall be made available to the District
               immediately upon request.

                    (3)  Maintain records of content of methylene chloride,
               trichlorofluoromethane (CFC-11), dichlorodifluoromethane
               (CFC-12), trichlorotrifluoroethane (CFC-113),
               dichlorotetrafluoroethane (CFC-114), or
               chloropentafluoroethane (CFC-115) in any coating or cleaning
               material used.

               (g)  TEST METHODS

               Measurements of VOC content subject to Section (d) of this
          rule shall be conducted and reported in accordance with  EPA Test
          Method 24 (40 CFR 60, Appendix A) as it exists on December 18,
          1990, and ASTM Test Method D-4457-85 for determination of
          dichloro-methane and 1,1,1-trichloroethane in paints and coatings
          by direct injection into a gas chromatograph.  Measurements of
          VOC content of multicomponent coatings shall be performed in
          accordance with ASTM Test Method D-2369-87 with minor
          modifications outlined in the Federal Register 55 FR 36546,
          published on September 5, 1990.

               Calculations of the VOC content of coatings and strippers
          less water and less exempt compounds shall be performed in
          accordance with  ASTM Standard Practice D 3960-87 for determining
          VOC content of paints and related coatings.

               Measurements of VOC emissions subject to Section (e) of this
          rule shall be conducted in accordance with EPA Methods 18 and 25
          (40 CFR 60, Appendix A) as they exist on December 18, 1990 and
          with EPA Guidelines for Determination of Capture Efficiency.

               Measurements of transfer efficiency pursuant to Subsection
          (d)(1)(vii) of this rule shall be conducted in accordance with
          the current version of the South Coast Air Quality Management
          District's "Spray Equipment Transfer Efficiency Test Procedure
          for Equipment User".
               
               Total absolute vapor pressure of VOC containing compounds
          pursuant to Subsection (d)(3)(ii) of this rule shall be
          calculated using the District's "Procedure for Estimating the
          Vapor Pressure of a Solvent Mixture", as it exists on December
          18, 1990.  If the vapor pressure of the liquid mixture is in
          excess of the limit specified in Subsection (d)(3)(ii), the vapor
          pressure shall be determined in accordance with ASTM Test Method
          D 2879-83, Vapor Pressure-Temperature Relationship and Initial
          Decomposition Temperature of Liquids by Isoteniscope.