SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT




RULE 4606 WOOD PRODUCTS COATING OPERATIONS (Adopted December 19, 1991; Amended May 21, 1992; Amended December 17, 1992; Amended June 20, 1996; Amended December 19, 1996; Amended December 17, 1998 )

1.0 Purpose

The purpose of this rule is to limit VOC emissions from wood products coating operations and to provide the administrative requirements for recording and measuring emissions.

2.0 Applicability

The provisions of this rule shall apply to the application of coatings to and surface preparation of wood products, including furniture, cabinets, and custom replica furniture.

3.0 Definitions

3.1 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.

3.2 Binder: non-volatile polymeric organic material (resin) in coatings which binds the pigment and additive particles together to form a surface film in coating applications.

3.3 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.

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

3.5 Crackle Lacquer: a clear or pigmented topcoat intended to dry to produce a cracked or crazed appearance.

3.6 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.

3.7 Detailing or Touch-up Gun: small air spray equipment that is operated at no greater than five (5) cfm air flow and no greater than 50 psig of air atomizing pressure and is used to repair or touch-up portions of wood products. Detailing and touch-up guns include air brushes.

3.8 Dip Coat: to dip an object into a vat of coating material and drain off any excess coating.

3.9 Electrostatic Application: method of spray application of coatings where an electrostatic potential is created between the part to be coated and the paint particles.

3.10 Faux Finish: a finish intended to simulate a surface other than wood, including, but not limited to, stone, sand, slate, marble, metal, metal flake, or leather.

3.11 Filler: a material whose primary function is to fill voids.

3.12 Flow Coating: a coating application system where paint flows over the part and the excess coating drains into a collection system.

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

Where:
Ws = weight of volatile compounds in grams
Ww = weight of water in grams
Wec = weight of exempt compounds in grams
Vm = volume of material in liters
Vw = volume of water in liters
Vec = volume of exempt compounds in liters

3.14 Grams of VOC per liter of Material: the weight of VOC per volume of material, and can be calculated by the following equation:

Grams of VOC per Liter of Material =

Where:
Ws = weight of volatile compounds in grams
Ww = weight of water in grams
Wec = weight of exempt compounds in grams
Vm = volume of material in liters

3.15 High-Solids Stain: a stain containing more than one (1) pound of solids per gallon of material, and can include wiping stains, glazes, and opaque stains. High-solids stains are formulated to enhance wood grain and change wood color, but not to conceal surface grain.

3.16 High-Volume, Low-Pressure (HVLP) Spray: equipment used to apply coatings by means of a spray gun which is designed and intended to be operated and which is operated between 0.1 and 10 psig of air atomizing pressure, measured dynamically at the center of the air cap and at the air horns.

3.17 Imitation Wood Grain: a hand applied finish that simulates the appearance of a specific natural wood grain.

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

3.19 Leaf Finish: a finish used in conjunction with metal leaf or foil.

3.20 Low-Solids Stain: a stain containing one (1) pound or less, of solids per gallon of material, and can include semi-transparent stains, toners, and wash coats. Low-solids stains are formulated to enhance wood grain and change wood color, but not to conceal surface grain.

3.21 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.

3.22 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.

3.23 Pigmented Coating: an opaque coating which contains binders and colored pigments and is formulated to hide the wood surface, either as an undercoat or topcoat.

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

3.25 Roll Coater: a series of mechanical rollers that forms a thin coating film on the surface of the rollers. The coating is applied to a substrate by moving the substrate underneath the rollers.

3.26 Sanding Sealer: a coating containing binders, which seals the wood prior to application of the subsequent coatings.

3.27 Simulated Wood Material: any material, such as plastic, glass, metal, etc., that is made to give a wood-like appearance or is processed like a wood product.

3.28 Strippable Booth Coating: a coating that is applied to a booth wall to provide a protective film to receive overspray during finishing operations and that is subsequently peeled off and disposed. Strippable booth coatings are intended to reduce or eliminate the need to use organic solvents to clean booth walls.

3.29 Stripper: a liquid used to remove cured coatings, cured inks, and/or cured adhesives.

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

3.31 Touch-up: that portion of the coating operation which is incidental to the main coating process but necessary to cover minor imperfections or to achieve coverage as required.

3.32 Volatile Organic Compound (VOC): defined in Rule 1020 (Definitions).

3.33 Wash Coat: a coating, containing binders, which penetrates into and seals wood, prevents undesired staining, and seals in wood pitch. Wash coats with greater than one (1) pound of solids per gallon of coating shall be considered sanding sealers.

3.34 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.

3.35 Wood Product Coating Operation: a stationary source that performs a combination of coating application steps which may include the use of spray guns, flash-off areas, spray booths, ovens, conveyors, touch-up areas, and/or other equipment operated for the purpose of applying coatings to wood products.


4.0 Exemptions

4.1 The provisions of the rule shall not apply to:

4.1.1 Aerosol-spray coatings for touch up and repair.
4.1.2 Wood products coating operations that use a total of less than 20 gallons of coating per year.
4.1.3 The application of coatings by template in order to add designs, letters, or numbers to wood products.
4.1.4 The application of coatings to wooden musical instruments.
4.1.5 Residential noncommercial operations.

4.2 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 4601 (Architectural Coatings).

4.3 Refinishing, Replacement, and Custom Replica Furniture Operations: The provisions of Sections 5.1, 5.2, and 5.3 shall not apply to any refinishing operation necessary for preservation, for returning the wood product to original condition, for replacing missing furniture to complete a matching set, or for producing custom replica furniture, provided records are maintained as specified in Section 6.1.2.

4.4 Specific Finishes: The provisions of Sections 5.1, 5.2, and 5.3 shall not apply to coatings used to produce the following finishes, provided records are maintained as specified in Section 6.1.1:

4.4.1 Crackle lacquers.
4.4.2 Faux finishes.
4.4.3 Imitation wood grain.
4.4.4 Leaf Finishes.

4.5 Any source which is subject to Section 5.4 of this rule shall be exempt from otherwise applicable portions of Rule 4661 (Organic Solvents).

4.6 For existing facilities, if an incineration device is added or modified for the sole purpose of complying with the requirements of this rule, such a device shall be exempt from the Best Available Control Technology and the Offset requirements of Rule 2201 (New and Modified Stationary Source Review Rule) provided that:

4.6.1 The proposed project will not result in an increase in capacity utilization of the unit being controlled.
4.6.2 The facility operator demonstrates to the satisfaction of the APCO that the proposed project is environmentally beneficial and will not cause or contribute to any violation of a national ambient air quality standard (NAAQS), prevention of significant deterioration (PSD) increment, or air quality related value (AQRV) in a class I area.


5.0 Requirements

5.1 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 of VOC per Liter of Coating, Excluding Water and Exempt Compounds

VOC LIMITS
Grams of VOC per Liter of Material

5.2 Control Requirements: The requirements of Section 5.1 shall not apply to any person who installs and operates air pollution control equipment with an overall capture and control efficiency of at least 85 percent on a mass basis as determined in accordance with Section 6.2. 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 5.1. The minimum required control efficiency of an emission control system at which an equivalent or greater level of VOC reduction will be achieved shall be calculated by using the following equation:

Where:
CE = Control Efficiency, percent
VOCLWc = VOC Limit, less water and less exempt compounds
VOCLWn,Max = Maximum VOC content of noncompliant coating used in conjunction with a control device, less water and less exempt compounds
Dn,Max = Density of solvent, reducer, or thinner contained in the noncompliant coating, containing the maximum VOC content of the multi-component coating
Dc = Density of corresponding solvent, reducer, or thinner used in the compliant coating system.

5.3 Application Equipment Requirements

5.3.1 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:

5.3.1.1 Electrostatic application;
5.3.1.2 High-volume, low-pressure (HVLP) spray;
5.3.1.3 Hand roller;
5.3.1.4 Flow coat;
5.3.1.5 Roll coater;
5.3.1.6 Dip coat;
5.3.1.7 Paint brush;
5.3.1.8 Detailing or touch-up guns; or
5.3.1.9 Such other coating application methods which are demonstrated to the APCO to be capable of achieving at least 65 percent transfer efficiency as determined in accordance with Section 6.2.5. Prior written approval from the APCO shall be obtained for each alternative method used.

5.3.2 Any person or facility using High-Volume Low-Pressure (HVLP) spray equipment to meet the requirements of this rule shall demonstrate that the spray equipment meets HVLP standards. Such demonstration shall be either in the form of manufacturer's published technical material, a measurement using a certified air pressure tip gauge, or permanent markings placed on the gun by the manufacturer which denote the maximum inlet air pressure in psig at which the gun will operate within the parameters specified in Section 3.16.

5.4 Evaporative Loss Minimization
A person or facility shall:

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

5.4.2 Use closed containers for the storage and/or disposal of solvent-laden cloth or paper. Containers shall be nonabsorbent and shall remain closed at all times except when depositing or removing the solvent-laden cloth and paper;

5.4.3 Store fresh or spent solvents in closed containers;

5.4.4 Keep containers of stripper, coating, adhesive, catalyst, or closed when not in use; and

5.4.5 Not use VOC-containing materials for the cleanup of spray equipment unless an enclosed system or equipment proven to be equally effective is used for cleaning as demonstrated, in accordance with Section 6.2.3. An enclosed system must totally enclose spray guns, cups, nozzles, bowls, and other parts during washing, rinsing, and draining procedures. Solvents used for cleanup of coating application equipment shall not exceed a VOC content of 950 g/l (7.9 lb/gal) and a VOC composite vapor pressure of 35 mmHg at a temperature of 68°F (20°C).

5.4.6 Limit VOC emissions from cleaning operations when using a strippable booth coating. A strippable booth coating shall not exceed a VOC content of 450 g/l (3.8 lb/gal) as applied, excluding water and exempt compounds.

5.5 Prohibition of Specification: No person shall require for use or specify the application of any coating subject to the provisions of this rule if such use or application would result in a violation of the provisions of this rule. This prohibition shall apply to all written or oral contracts under the terms of which any coating which is subject to the provisions of this rule is to be applied to any wood product at any physical location within the District.

6.0 Administrative Requirements

6.1 Recordkeeping
All records required to be maintained under this Section shall be retained on site for a period of at least 24 months and shall be made available for inspection by the APCO.

6.1.1 Any person subject to Sections 5.1, 5.2, or 5.3, and users of coatings exempt by Section 4.4, shall comply with the following requirements:

6.1.1.1 maintain a current list of coatings and solvents in use which provides all of the data necessary to evaluate compliance, including the following information, as applicable:

6.1.1.1.1 identify coatings, catalysts, reducers, and solvents.
6.1.1.1.2 manufacturer's recommended mix ratio of components.
6.1.1.1.3 VOC content of coatings, as applied.
6.1.1.1.4 VOC content of solvents.

6.1.1.2 maintain records on a daily basis that provide the following information, as applicable:

6.1.1.2.1 coating and mix ratio of components in the coating used.
6.1.1.2.2 quantity of each coating applied.
6.1.1.2.3 identification of coating category.
6.1.1.2.4 type and amount of solvent used for cleanup and surface preparation.

6.1.2 Refinishing, Replacement and Custom Replica Furniture Operations: Any person claiming exemption under Section 4.3 shall comply with the following requirements:

6.1.2.1 maintain a current list of coatings in use which provides the following information:

6.1.2.1.1 coating, catalyst, and reducer.
6.1.2.1.2 manufacturer's recommended mix ratio of components.
6.1.2.1.3 VOC content of each component.

6.1.2.2 maintain records that provide the following information such that daily usage can be determined:

6.1.2.2.1 amount of coating, catalyst, and reducer used.
6.1.2.2.2 type and amount of solvent used for cleanup and surface preparation.
6.1.2.2.3 type and amount of stripper used.
6.1.2.2.4 each type of wood product coated. Wood product types are as follows:

6.1.2.2.4.1 refinishing.
6.1.2.2.4.2 replacement.
6.1.2.2.4.3 custom replica furniture.

6.1.3 Recordkeeping for Emission Control Systems: Any person using an emission control system as a means of complying with the provisions in Section 5.2 shall maintain daily records of key system operating parameters which will demonstrate continuous operation and compliance of the emission control system during periods of emission producing activities. Key system operating parameters are those necessary to ensure compliance with VOC limits. The parameters may include, but are not limited to, temperatures, pressures, and flow rates.


6.2 Test Methods

6.2.1 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.

6.2.2 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.

6.2.3 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", October 3, 1989.

6.2.4 Capture efficiency shall be determined according to EPA's technical document, "Guidelines for Determining Capture Efficiency", January 9, 1995.

6.2.5 The transfer efficiency of alternative coating application methods shall be determined in accordance with the SCAQMD method "Spray Equipment Transfer Efficiency Test Procedure for Equipment User", May 24, 1989.


6.3 Labeling Requirements

6.3.1 VOC Content: Each container or accompanying data sheet of any coating subject to this rule and manufactured after December 19, 1992, shall display the maximum VOC content of the coating, as applied after any thinning as recommended by the manufacturer. VOC content shall be displayed as grams of VOC per liter (or pounds of VOC per gallon) 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 6.2.
6.3.2 Thinning Recommendations: Each container or accompanying data sheet of any coating subject to this rule and manufactured after December 19, 1992, shall display the manufacturer's recommendation regarding thinning of the coating. This requirement shall not apply to the thinning of coatings with water.


7.0 Compliance Schedule

7.1 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:

7.1.1 Within six (6) months from the date that the exemption was lost, submit a complete application for an Authority to Construct or Permit to Operate, as applicable.
7.1.2 Within 12 months from the date that the exemption was lost, be in full compliance with the requirements of this rule.

7.2 The owner or operator of any wood products coating operations which is subject to the requirements of this rule and which is installed or constructed on or after December 19, 1991, shall be in full compliance with the applicable requirements of this Rule at the time of initial operation.