UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

Technical Support Document 

for 

EPA’s Direct Final Rulemaking 

for the 

California State Implementation Plan 

Placer County Air Pollution Control District, Rule 236, Wood Products and 

Coating Operations 

Prepared by: Nicole Law 

Reviewed by: Andrew Steckel 

October 2011 
−2−

RULE IDENTIFICATION - 

Agency: Placer County Air Pollution Control District (PCAPCD) 

SIP Approved Rule: Rule 236 – Wood Products Coating Operations 

Adopted – February 9, 1995; Submitted – May 24, 

1995 

EPA Approved – April 30, 1996 (61 FR 18962) 

Subject of this TSD: Rule 236 – Wood Products Coating Operations 

Amended – October 14, 2010; Submitted – April 5, 

2011 

RULE SUMMARY PCAPCD Rule 236, Wood Products Coating Operations, is a 

rule designed to limit volatile organic compound (VOC) emissions from coatings 

and strippers used on wood products. Products used in surface preparation and 

cleanup are also controlled by this rule and have VOC emission limits associated 

with those categories. The rule describes related administrative requirements for 

recording and measuring emissions. Changes from the approved SIP rule 

include: 

1. Added a “purpose” section to the rule to specify the purpose of the rule. 

2. Added a “severability” section to the rule. 

3. Added two new exemptions to the rule. The first exempts factory 

application onto panels and siding because those operations are subject 

to another district rule. The second new exemption addresses tints 

applied to stains in quantities of less than a pint on any operating day. 

Such coatings are exempt from all requirements except recordkeeping. 

4. Removed the refinishing, replacement, and custom replica furniture 

operations exemption. These operations now have VOC limits to comply 

with as well as application equipment requirements. 

5. Revised the low usage complete exemption from 20 gallons of coating per 

year to 55 gallons of coating per year, requiring recordkeeping. 

6. Revised the exemption for specific finishes such as crackle lacquers, faux 

finishes, imitation wood grain, and leaf finishes to be exempt from VOC 

limits but not application equipment requirements. 

7. Added, removed, and edited a number of the defined terms. 

a. Added the following terms: affected pollutant, capture efficiency, 

cleanup material, closed container, control device efficiency, 

conversion varnish, emissions unit, emission control system, 

enclosed gun cleaner, exempt compounds, low-volume, lowpressure (LVLP) equipment, new wood product, non-shop 

architectural coating operations, reactive diluents, refinishing 

operation, sealer, stain, stencil coating, surface preparation 

material, tint, VOC composite partial vapor pressure, volatile 

organic compound (VOC), VOC content, and wood panel. 

b. Removed the following terms: airless spray, grams of VOC per liter 

of coating applied, grams of VOC per liter of material, sanding 

sealer, and evaporative loss minimization. 
−3−

c. Edited the following terms: coating, electrostatic application, filler, 

high-solids, high volume low pressure (HVLP) spray, low-solids 

coating, stripper, and touch-up. 

8. Application equipment such as low volume low-pressure spray equipment, 

air assisted airless (for touch-up and repair only), and electrostatic 

application equipment were added as acceptable application methods. 

9. VOC limits are divided into two tables. The first is for coating of new wood 

products and the second is for (formerly exempt) coatings to refinish 

repair, preserve or restore. 

10. The surface preparation and cleanup solvents VOC limit has been lowered 

from 200g/L to 25 g/L. 

11. The emission control system requirements have been revised. Instead of 

requiring at least an 85% capture and control efficiency on a mass basis, 

the capture and control device is now required to achieve an equivalent or 

greater emission reduction amount than the limits specified. 

Accompanying this requirement is an equation on how to calculate such 

an efficiency. New requirements to keep continuous monitoring of 

combustion and exhaust gas temperature have been added. Also, an 

operation and maintenance plan is required when facilities choose to use 

an emission control system as an alternative control. 

12. The former section “evaporative loss minimization” has been renamed 

“requirements for surface preparation and cleanup materials” and mainly 

contains work practice requirements. 

13. New sections such as “prohibition of possession” and “prohibition of sale 

or manufacture” have been added. 

14. Recordkeeping frequency has been reduced from a daily basis to monthly 

basis for coating materials that comply with VOC limits. Materials and 

coating which exceed the VOC limits need to have daily records. 

Similarly, tints used to color stains used in quantities of less than one pint 

per operating day are required to have daily usage records. 

15. Added recordkeeping requirements for emission control systems. Monthly 

usage recording is required for the type and volume of coatings and daily 

recording is required of key operating and maintenance procedures of 

emission control systems. 

16. The retention period for records has been extended from 24 months to 3 

years. 

17. Added several more test methods, as well as language indicating a 

violation can be determined by any one test method. 

EPA EVALUATION - The following criteria were used to evaluate the submitted 

rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 
−4−

2. RACT – EPA’s Control Technique Guidelines (CTGs) titled, “Control of 

Volatile Organic Compound Emissions from Wood Furniture Manufacturing 

Operations” (EPA-453/R-96-007, April 1996), and other state and local rules 

for this category were used to help evaluate the RACT requirements of CAA 

§182(b)(2). 

3. SIP Relaxation - Where previous versions of rules have been SIP approved, 

new submittals must comply with CAA §110(l) and §193 regarding SIP 

relaxations. We have evaluated this SIP revision to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of 

the Act (CAA 110(l)) or modify, in a nonattainment area, any SIP-approved 

control requirement in effect before November 15, 1990 (CAA 193). 

A review of the current submitted rule to the SIP approved version revealed four 

areas of concern. We do not consider them deficiencies, but have discussed them 

below. 

• While the complete exemption from the SIP approved rule for facilities using 

less than 20 gallons of coatings per year seems more stringent than the 55 

gallon per year exemption, it was unenforceable. The current proposed 

exemption for facilities using 55 gallons of coating per year or less requires 

facilities to comply with recordkeeping requirements. It is also consistent 

with other district rules such as Sacramento Metropolitan Air Quality 

Management District 463 Wood Products Coatings. 

• The limits for high solids coatings and sanding sealer in the 1995 SIP 

approved rule effective April 1, 1996 are both 240 grams of VOC per liter of 

coating. In the 2010 amendment, these categories have limits of 350 g/L 

and 275 g/L. Industry was never able to comply with the 1996 effective 

coating limits as is discussed in the 1996 staff report. Because of this, the 

district amended the rule to be more consistent with SMAQMD 463 and to 

address the fact that industry could not develop coatings to meet the more 

stringent requirements. 

• The SIP approved rule provided an alternative compliance option requiring 

an emission control system achieve at least an 85% capture and control 

efficiency. The proposed amendment to this removes the 85% efficiency 

and replaces it with language requiring the emission control system achieve 

an equivalent or greater amount of emission reductions than the limits 

specified in the rule. The required efficiency to achieve this equivalency is 

determined by an equation and can vary depending on the type of coatings 

used. While the amendment now allows the capture and control efficiency 

of the emission control system to vary, it still requires emission reduction. 

Further, we confirmed with district staff that there are no facilities in the 

district which use the emission control system alternative compliance option. 

• The SIP approved rule required recordkeeping on a daily basis for all 

coating materials used. The new amendment lowers the frequency to 

monthly records for compliant coating usage and keeps a daily 
−5−

recordkeeping requirement for noncompliant coatings and tints used to color 

stains. This is consistent with recommendations in EPA’s little bluebook 

allowing monthly recordkeeping for sources using only compliant materials 

and daily records for sources complying with add-on control equipment. 

As discussed above, these revisions to the rule generally follow EPA guidance and 

recommendations. We do not consider these revisions problematic relaxations 

because many were never applied requirements in the SIP rule and they are offset 

by other rule improvements, including the new 25 g/L solvent limit. 

The monitoring, recordkeeping, reporting and other requirements generally ensure 

that the submitted rule can be enforced. The rule is generally as stringent as the 

CTG and other district rules for the same category, therefore we have determined 

that it meets RACT requirements. Lastly, the submitted rule is more stringent than 

the version previously approved into the SIP, so the submitted rule does not relax 

the SIP and complies with CAA §110(l) and §193. 

RULE DEFICIENCIES – We have identified no deficiencies with Rule 326 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revision is not currently the basis for rule disapproval, but is 

recommended for the next time the rule is amended. 

• Combine and clarify sections 501.2.2 and 501.2.4 regarding recordkeeping 

for tints. Consistently require daily recordkeeping for usage of tints and/or 

tints used to color stains to stay consistent with the daily usage exemption. 

EPA ACTION - 

The submitted Rule 236 will clarify the rule and strengthens the SIP. The rule 

fulfils the relevant CAA §110 and part D requirements. EPA staff recommends 

approval of Rule 236 pursuant to CAA §110(k)(3). 

REFERENCES - 

1. PCAPCD Rule 236, Wood Products Coating Operations, as submitted on 

April 5, 2011. 

2. PCAPCD Rule 236, Wood Products Coating Operations, as approved into 

the SIP on April 30, 1996. 

3. “Control of Volatile Organic Compound Emissions from Wood Furniture 

Manufacturing Operations,” EPA-453/R-96-007, April 1996. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/199604_voc_epa453_r-96-

007_wood_furniture_manufacturing.pdf 

4. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988. 

5. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. 
−6−

6. PCAPCD Staff Report, Rule 236 Wood Products Coating Operations April 

1, 1997.