PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

RULE 236

WOOD PRODUCTS COATING OPERATIONS

PROPOSED RULE AMENDMENTS

October 14, 2010
Staff Report – Proposed Revision to Rule 236

October 14, 2010

Page 2

BACKGROUND

Rule 236, WOOD PRODUCTS COATING OPERATIONS, limits the volatile organic compound 

(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 with 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 State and 

Federal ozone standards.

This Staff Report addresses amendments that are proposed to Rule 236.

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 requirements.

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

Specific changes to the Rule include:

Section 100. General

Section 102.1 Applicability, Geographic. The Rule has been expanded to apply to the 

entire District, 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 302.1 and Section 306. Emissions Averaging Compliance Option. The provision 

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

and Federal compliance procedures.

Section 302 and Section 306. Solvent Requirements for Surface Preparation 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 coatings which do not meet 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 coatings which do not meet the requirements of this Rule may not be sold 

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

 

Section 500. Monitoring and Records

Section 503. Test Methods. Reference was added to numerous additional test methods, 

and minor changes were made to the references of methods in the current Rule.
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 State 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 effectiveness 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 

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

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

District permits, is expected to be insignificant.

3. Environmental Review and Compliance

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 replacement 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 adverse 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 amendment 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 236 satisfies the Districts objective 

to reduce VOCs 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 and 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 rule.

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

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

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

contradictory to, existing statutes, court 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 the District in 

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

by reference.

SUMMARY

Rule 236, WOOD PRODUCTS COATING OPERATIONS, has been amended to be consistent 

with our District rules and to meet our requirement to meet ozone ambient air quality standards.

Attachment 1: Proposed Rule 236 Amendments.
ATTACHMENT #1

Amended Rule 236, Wood Product Coating