SJVAPCD RULE 4606 WOOD PRODUCTS COATING OPERATIONS
LAST REVISED 6/20/96

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

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 the emissions. 

2.0  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.

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  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.

     3.3  Airless Spray:  equipment used to apply coatings by use
          of fluid pressure without atomizing air, including heated
          airless spray.

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

     3.5  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.

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

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

     3.8  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.

     3.9  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.

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

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

     3.12 Faux Finish:  a finish intended to simulate a surface
          other than wood, including stone, sand, slate, marble,
          metal, metal flake or leather.

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

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

     3.15 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  =      Ws - Ww - Wec
                                             Vm - Vw - Vec
          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

     3.16 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 =    Ws - Ww - Wec
                                                       Vm

          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

     3.17 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.

     3.18 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.

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

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

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

     3.22 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.

     3.23 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.

     3.24 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.

     3.25 Opaque Stains:  stains, not classified as semitransparent
          stains, which contain pigments which give character to
          wood.

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

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

     3.28 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.

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

     3.30 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.

     3.31 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.

     3.32 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.

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

     3.34 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.

     3.35 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.

     3.36 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.

     3.37 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.

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 application 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, 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
          6.1.2.

     4.4  Specific Finishes:  The provisions of Sections 5.1 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 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 4661 (Organic Sovlents) unless compliance
          with the limits specified in this rule is achieved.

     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).

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 Per Liter of Coating, Less Water and Exempt Compounds

                       Effective          Effective        Effective 
                        11/1/92            7/1/94           1/1/97

                      g/l   lb/gal       g/l   lb/gal     g/l   lb/gal

Clear Topcoat         680    5.7         550    4.6       275    2.3 
Filler                500    4.2         500    4.2       275    2.3
High-Solids Coatings  700    5.8         700    5.8       240    2.0
Inks                  500    4.2         500    4.2       500    4.2
Mold-Seal Coating     750    6.3         750    6.3       750    6.3
Multi-Colored Coating 685    5.7         275    2.3       275    2.3
Pigmented Coating     600    5.0         275    2.3       275    2.3
Sand Sealer           740    6.2         550    4.6       240    2.0


                                    VOC LIMITS
                           Grams Per Liter of Material

                       Effective          Effective        Effective 
                        11/1/92            7/1/94           7/1/96

                      g/l   lb/gal       g/l   lb/gal     g/l   lb/gal

Low-Solids Coating    800    6.7         480    4.0       120    1.0 
Strippers             350    2.9         350    2.9       350    2.9


     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 a with an overall capture and control 
          efficiency of at least 85 percent on a mass basis as determined 
          in 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.

     5.3  Application Equipment Requirements:  Effective February 1, 1992, 
          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     Electrostatic application;
          5.3.2     High volume, low pressure (HVLP) spray;
          5.3.3     Hand roller;
          5.3.4     Flow coat;
          5.3.5     Roll coater;
          5.3.6     Dip coat; 
          5.3.7     Paint brush;
          5.3.8     Detailing or touch-up guns;
          5.3.9     Or until July 1, 1994, use air assisted airless spray 
                    and coatings that meet the January 1, 1997 limits in 
                    Section 5.1.

     5.4  Evaporative Loss Minimization:  Effective February 1, 1992, 
          a person shall:

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

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

          5.4.3     Store fresh or spent solvents in closed containers;

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

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

                    5.4.5.1   an enclosed system or equipment demonstrated, 
                              in accordance with Section 6.2.3, 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

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

     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 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.

6.0  Administrative Requirements

     6.1  Recordkeeping 

          6.1.1     Any person subject to Section 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 in use 
                              which provides all of the data necessary to 
                              evaluate compliance, including the following 
                              information, as applicable:

                              6.1.1.1.1  coating, catalyst, or reducer.
                              6.1.1.1.2  manufacturer's recommended mix 
                                         ratio of components
                              6.1.1.1.3  VOC content of coating, as applied.

                    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.

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

          6.1.2     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:

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

                              6.1.2.1.1  coating, catalyst, or reducer.
                              6.1.2.1.2  manufacturer's recommended mix 
                                         ratio of components.
                              6.1.2.1.3  VOC contents.

                    6.1.2.2   maintain records that provide the following 
                              information such that daily usages can be 
                              determined. 

                              6.1.2.2.1  amount of coating, catalyst, and 
                                         reducer.
                              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.

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

     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", dated October 3, 1989.

          6.2.4     Capture efficiency shall be determined using methods 
                    in 55 Federal Register (FR) 26865 (June 29, 1990) as 
                    described under (a)(4)(iii) - Capture System
                    Efficiency Test Protocols and Appendix B - Volatile 
                    Organic Material Measurement Techniques for Capture 
                    Efficiency.  The procedure described under 
                    (a)(4)(iii)(2) of the above referenced FR shall be 
                    modified as follows:  If a stationary source owner or 
                    operator uses a control device designed to collect and 
                    recover VOC (e.g., a carbon adsorber), an explicit 
                    measurement of capture efficiency is not necessary if 
                    the conditions described in 55 FR 26865 are met.  
                    The overall emission reduction efficiency shall be 
                    determined each day by directly comparing the input 
                    liquid VOC to the recovered liquid VOC.  The procedure 
                    for use in this situation is specified in 40 CFR 
                    60.433 with additional modifications described in 
                    55 FR 26865.
 
     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, 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 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 a statement of 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 date 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 date 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.