STATE OF CALIFORNIA 

ENVIRONMENTAL PROTECTION AGENCY 

AIR RESOURCES BOARD 

P. 0 . Box 2815 

Sacramento, California 95812 

August 12, 2005 

Transmittal 

of 

ARB Staff Rule Review Comments 

To: Ms. Karla Sanders, 

Air Quality Compliance Coordinator 

Feather River Air Quality Management District 

Telephone Number: (530) 634-7659 

e-mail: ksanders@fraqmd.gov 

From: Alex Krichevsky, (916) 324-6222 

e-mail: akrichev@arb.ca.gov 

The following draft rule which is scheduled for a public workshop to be held by your 

District staff on August 18, 2005, was received by us on July 6, 2005, for our review: 

Rule 3.20 Wood Products Coating 

We have reviewed the draft and have the comments on the following page. We believe 

that our comments are important to the effectiveness and enforceability of Rule 3.20. 

On July 20, 2005, Mr. James McCormack of our Stationary Source Enforcement 

Section, Stationary Source Enforcement Branch, Stationary Source Division discussed 

our comments with you. 

If you have any questions about our comments, please contact Mr. Carl Brown, 

Manager of the Stationary Source Enforcement Section, at (916) 323-8417. 

Rule review comments are on the following page 
Date: August 12. 2005 

Air Resources Board Staff Comments on 

Feather River Air Quality Management District 

Rule 3.20 

Rule 3.20 Wood Products Coating 

1. Section D.?.a: The first sentence of Section D.?.d states, "A person wanting to use 

emissions averaging to achieve compliance with this rule shall submit an 

Emissions Averaging Plan ("Plan") for approval by the Air Pollution Control Officer." 

We agree with the statement but belie..ve the Emissions Averaging Plan's 

abbreviation "Plan" will be confused with the abbreviation "O&M Plan" for 

Operating and Maintenance Plan used in Section E.6. The source will further 

abbreviate "O&M Plan" to "Plan" in possibly verbal and written communications 

with the District. This will cause confusion. One possible way to eliminate the 

possible confusion is to use the abbreviation "EA Plan" for the Emissions 

Averaging Plan. If the source says they submitted the "Plan", the District can ask 

which one. 

To improve clarity of this rule we recommend that the abbreviation for the 

Emissions Averaging Plan be changed to ("EA Plan"). 

2. Section F: This section partially deals with record keeping. 

The operator is required to take and record certain data for record keeping 

purposes. However, there is no requirement to sign and date the record. A 

signature and a date would attest to its authenticity. If an operator was on vacation 

when the data was taken, then an inspector could write a violation. This would 

also significantly reduce the possibility of creating the log all at once at a later time. 

If the records are to be signed by multiple operators, then it's unlikely that several 

operators would sign a bogus log. Also, management would be hesitant to try 

generating a log with multiple operators because it would only take one disgruntled 

worker to blow the whistle. 

To improve the enforceability of this rule we recommend that the operator sign and 

date the data entry
STATE OF CALIFORNIA 

ENVIRONMENTAL PROTECTION AGENCY 

AIR RESOURCES BOARD 

P. 0 . Box 2815 

Sacramento, California 95812 

March 22, 2006 

ARB Staff Rule Review Results 

To: Karla Sanders, 

Air Pollution Control Specialist 

Feather River Air Quality Management District 

Telephone Number: (530) 

e-mail: ksanders@fraqmd.gov 

From: Alex Krichevsky, (916) 324-6222 

e-mail: akrichev@arb.ca.gov 

The following rule, which was adopted at a public hearing held by your District Board on 

December 5, 2005, was received by us on January 24, 2006, for our review: 

Rule 3.20 State Wood Products Coating 

The Air Resources Board staff has reviewed the rule and, based on the information 

available to us at this time, we have no comments. 

The rule was examined by the Stationary Source Division , and the Enforcement 

Division. 

If you have any questions, please contact me by e-mail or at the telephone number 

above. 
08/30/05 Wood Coatings: Rule 3.20 Workshop 

Workshop Minutes 

-Introduction 

APCO Dave Valier called for the workshop to begin. 

-Briefly explained the reason for rule adoption 

-Reason: To be consistent within the Sacramento Valley Air Basin 

-Reason: State Implementation Plan (SIP) 

-Deadline for comments is September 30, 2005 

-Comments accepted by email 

-Rule Presentation 

Matt Baldwin presented the rule for adoption 

-Introduction of Wood Coating Rules 

-Background Information -Reasons and Regulation 

-Wood Coatings 

-Wood Coating Operation -Wood Coating Application 

Q 1. Are all the methods refer (under Coating Application) the only method allowed to be 

used? What about vacuum coating application? 

Al. Include question in comments. Method not stated in the staff report. 

-Control Technology 

-Emerging Technologies -Business Affected -Summary of Requirements 

-Exemptions 

New Wood product 

Refinished Wood Product 

Q2. Where are the primers in the Refinished wood product standard? 

A2. Primers are considered clear topcoats. 

Q3. Where does our finishing fit in the process? 

A3. Please submit written comments. 

Q4. Why are there different VOC for different finishing? 

A4

Some finishes are specialized and not used as extensively as others

Their impact is 
Q6. District is adopting rule to be consistent with other district but what if rule is not 

reasonable for our district? A6. We adopting rule because we are required to reduce emission. Adopting this rule is 

an agreement stated in our State Implementation Plan (SIP). 

Q7. Why are the new standard given only one year? 

A 7. The district felt this was sufficient notice. Other districts that adopted the standards 

required the facilities meet the standard by July 1, 2005. 

Q8. How are the exemption affected; Architectural Rule? 

A8. Architectural applications are not affected by this rule. They are already covered by 

rule 3.15. 

Q9. What is the Architectural Rule? 

A9. The Architectural Rule covers architectural coatings not applied in shop. 

QlO. There are 44 to 45 companies affected, was Unity Forest one ofthose affected? If 

Unity Forrest is exempted, what would we need to do? 

A 10. The district would need to look at the specific permit to ultimately determine 

applicability. If applicable, the facility would need to modify the permit to ensure 

compliance with the rule. 

Q 11. Other type of Coatings? 

All. 

Q12. Exemptions B.3- wood panel for building exterior? 

A 12. The district will look for clarification. Please submit the comments in writing. 

Q 13. Is Unity forest Exempt for roll coating, and decorative coating? 

A 13. Roll coating is covered in the rules as an acceptable method. 

Q 14. Define more terms? 

A 14. The District will solicit written comments for more definitions. 

Q15. In "wood panel", define "panel"? 

A 15. The District will solicit written comments for more definitions 

Q16. "Coating for architectural in shop environment." Define shop environment? 

A 16

Shop environment is defined in Rule 3

15 
-Emission Reduction 

Q 18. Estimated or Mandated? (Emission reduction) 

A 18. Estimated. 

Q 19. Why are the district's emission reduction so high (compared with other districts)? 

Are there more wood coaters in our district? 

A19. Yes 

Q20. Number of Employer to Employee? 

A20. The District will solicit written comments. 

Q21. How do you know the impact if you don't know the number of companies to the 

number of employee? 

A21. The District will solicit written comments. 

Q22. What is the "Sell thru provision"? 

A22. This would allow currently stocked coatings to be used through a certain date. 

Q23. How many affected business do Shasta AQMD? 

A23. Please refer to staff report. 

Q24. FRAQMD has more producers? 

A24. Please refer to staff report. 

Q25. Would the impact on employment be greater than as predicted elsewhere because 

the district's economy has the highest employment, but the lowest capital? 

A25. The district does not believe it would. Most facilities are already in compliance 

with the provisions due to surrounding districts adopting the rule. 

Q26. Is some of the pollution from mobile sources? 

A26. Yes. About 70% comes from motor vehicle. 

Q2 7. How are we to account for the growth of our company if besides using 1000 lbs of 

whatever, we would need to use 2000 lbs of whatever? 

A27. The District will solicit written comments. 

Q28. How would this rule affect the company if the company could potentially use more 

gallons of material? 

A28

The District will solicit written comments
Q30. Sunsweet has applied for ERCs and has given xx% reduction. With this rule, will 

this reduction hurt our operation? 

A30. No. 

Q31. "Successful implementation elsewhere." Define successful? What does it mean by 

successful? 

A31. The District will solicit written comments. 

Q32. If the company is in compliance with the new limits, what effect will the rule have 

on the company? 

A32. The rule will be incorporated into the permit, but the actual operations will not be 

affected. More recordkeeping may be required. 

Q33. If we are exempt, do we need to apply for an exemption? 

A33. Possibly. This will be determined on,a case-by-case basis. 

Q34. How do we go through the permitting process? Do we need to apply? 

A34. Possibly. This will be determined on a case-by-case basis 

Q35. If we are exempt from rule, do we still need a permit? 

A35. Possibly. This will be determined on a case-by-case basis 

Q36. Can we comment on exemptions? 

A36. The District will solicit written comments. 

Q37. Who are the targeted sources to be permitted? 

A37. Facilities using wood products and not exempted by the rule. 

Q38. VOC and NOx are the precursor for O-Zone. How would NOx be affected by this 

rule? 

A38. This rule mainly restricts VOC. This rule does not regulate on NOx. 

Q39. Why is acetone exempt? 

A3 9. EPA found acetone to have a minimal impact on the formation of ground level 

ozone. 

End of Workshop.