## PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT



# STAFF REPORT

RULE 2 36

WOOD PRODUCTS COATING OPERATIONS

PROPOSED RULE AMENDMENT S

October 14, 2010Staff Report

– Proposed Revision to Rule 236

October 14, 2010

Page 2

BACKGROUND

R ule 236

, WOOD PRODUCTS COATING OPERATIONS

, limits the volatile organic c ompound

(VOC) emissions from wood products coating operations in the Placer County Air Pollution

Control District (District)

. The rule was last amended by the District on August 14

, 1997

.

The District is proposing amendments to Rule 236 to be consistent w ith changes being made to

Rule 218, ARCHITECTURAL COATINGS and Rule 238, FACTORY COATING OF FLATWOOD

PANELING, and to meet our requirement for VOC emission reductions for attainment of Sta te and

Federal ozone standards.

This Staff Report addresses amendme nts that are proposed to Rule 2 36.

DISCUSSION

Review of District Rule wood products coating VOC content limits indicates they are consistent

and up to date with the best available control practices based on review of local, State, and

Federal requiremen ts.

Proposed amendments to the R ule , in underline/strikeout format, are shown in Attachment #1.

Specific changes to the R ule include:

Section 10 0

. General

Section 102. 1 Applicability , Geographic

. The R ule has been expanded to apply to the

entire Dist rict, including the Mountain Counties and Lake Tahoe Air Basins

. The Rule

previously was limited to the Sacramento Air Basin.

Section 200. Definitions

New definitions were added for tints and stains.

Section 300. Standards

Section 30 2.1 and Section 3 06

. Emissions Averaging Compliance Option

. T h e provision

for emission averaging has been deleted, as it is no longer consistent with allowable State

and Federal compliance procedures

.

Section 30 2 and Section 306

. Solvent Requirements for Surface Preparat ion and Cleanup

Materials

. The solvent cleaning VOC content limit has been changed to 25 g/l.

Section 400. Administrative Requirements

Section 402. Prohibition of Possession. A provision is added that clarifies that wood

product coating s which do not m eet the requirements of this Rule may not be possessed

in the District.

Section 403. Prohibition of Sale or Manufacture. A provision is added that clarifies that

wood product coating s which do not meet the requirements of this Rule may not be sold

of ma nufactured in the District, unless the products are for use outside of the District.

Section 500. Monitoring and Records

Section 503. Test Methods

. R eference was added to numerous additional test methods,

and minor changes wer e made to the references of methods in the cur rent R ule.Staff Report

– Proposed Revision to Rule 236

October 14, 2010

Page 3

ANALYSIS

The following Analysis and the subsequent Findings are intended to address the requirements set

forth in the Health and Safety Code relating to adoption of a new or amended District Rule, as well as

other St ate statutes referenced herein.

1. Cost

- Effectiveness of a Control Measure

California Health & Safety Code (H&S) Section 40703 requires a District to consider and

make public “the cost

- effectiveness of a control measure”. The cost eff ectiveness can not

be determined since the rule amendments will have no significant cost to comply and no

significant emission reductions.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic

impac t of any new or amended rule if air quality or emission limits are significantly affected.

The e xpected economic impact on the wood products operations, including twelve (12) with

District permits, is expected to be insignificant.

3. E nvironmental R eview and C ompliance

California Public Resources Code Section 21159 requires an environmental analysis of

the reasonably foreseeable methods of compliance should be conducted. Compliance of

the proposed rule amendment is expected to be achieved by the replaceme nt of current

coating products with compliant compounds. Application of these compliant compounds

will generally result in less VOC emissions from the coating activities. Therefore, the

proposed rule amendment will reduce emissions from sources and will not cause any

significant adver se effects on the environment. Staff has concluded that no adverse

environmental impacts will be caused by compliance with the proposed rule amendment.

According to the above conclusion, Staff finds that the proposed rule am endment is

exempt from the California Environmental Quality Act (CEQA) because ( 1) it can be seen

with certainty that there is no possibility that the activity in question may have a significant

adverse effect on the environment (CEQA Guidelines §15061(b)( 3)) and ( 2) it is as an

action by a regulatory agency for protection of the environment (Class 8 Categorical

Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity : The adoption of proposed amended Rule 2 36 satisfies the Districts objective

to reduce VOC s to achieve attainment with ambient air standards for ozone , and meets

the District’s requirements to implement “every feasible measure” and “Best Available

Retrofit Control Technology” as required under California Health and Safety Code

Sections 40919 an d 40914

.

B. Authority : California Health and Safety Code, Sections 40000, 40001, 40701, 40702,

40716 , 41010, and 41013, are provisions of law that provide the District with the authority

to adopt this proposed r ule.

C. Clarity : There is no indication, at this time, that the proposed amended R ule is written in

such a manner that persons affected by the R ule cannot easily understand them.

D. Consistency : The proposed amended Rule is in harmony with, and not in conflict with or

contradictory to, existing statutes, c ourt decisions, or state or federal regulations.Staff Report

– Proposed Revision to Rule 236

October 14, 2010

Page 4

E. Non

- duplication : The proposed amended Rule does not impose the same requirements

as an existing state or federal regulation.

F. Reference : All statutes, court decisions, and other provisions of law used by th e District in

interpreting this proposed amended Rule is incorporated into this analysis and this finding

by reference.

SUMMARY

Rule 2 36

, WOOD PRODUCTS COATING OPERATIONS , has been amended to be consistent

with our District rules and to meet our requirem ent to meet ozone ambient air quality standards

.

Attachment 1: Proposed Rule 236 Amendments.

### ATTACHMENT #1

Amended Rule 236, Wood Product Coating