ATTACHMENT E

AIR POLLUTION CONTROL DISTRICT

COUNTY OF SAN DIEGO

PROPOSED AMENDMED RULE 67.11 – WOOD PRODUCTS COATING

OPERATIONS, AND THE REPEAL OF RULE 67.11.1 – LARGE

COATING OPERATIONS FOR WOOD PRODUCTS

WORKSHOP REPORT

A workshop notice was mailed to all companies and government agencies in San Diego 

County that may be subject to proposed amended Rule 67.11 – Wood Products Coating 

Operations. Notices were also mailed to all Economic Development Corporations and 

Chambers of Commerce in San Diego County, the U.S. Environmental Protection Agency 

(EPA), the California Air Resources Board (ARB), and other interested parties.

The workshop was held on March 30, 2011, and was attended by 11 people. Written 

comments were also received before and after the workshop. The workshop comments and 

Air Pollution Control District (District) responses are as follows:

1. WORKSHOP COMMENT

The District should consider amending the definition of “Conversion Varnish” in 

Subsection (c)(8) to include the topcoat, as well as the accompanying sealer. To ensure 

optimum adhesion and coating performance, the conversion varnish wood coating finishing 

system requires a two coating system, the catalyzed sealer and catalyzed topcoat.

DISTRICT RESPONSE

The District agrees. The definition of “Conversion Varnish” has been amended to include the 

conversion varnish sealer that is applied as part of the conversion varnish wood coating 

finishing system.

2. WORKSHOP COMMENT

Vinyl sealers impart moisture resistance to finish systems and are frequently used as sealers. 

They will not be able to comply with the lower VOC content limit of 275 g/L in proposed 

amended Rule 67.11. The District should add an additional coating category for “Vinyl 

Sealers,” with a VOC content limit of 550 g/L.

DISTRICT RESPONSE

The District recognizes that a higher VOC content vinyl sealer or other coating may be 

needed in some instances to achieve a desired finish. Therefore, an exemption has been added 
Workshop Report

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to the proposed amended rule to allow any wood coating operation to use not more than 20 

gallons of non-compliant coatings per consecutive 12-months, provided that the total amount 

of non-compliant coatings used at a stationary source does not exceed 20 gallons per 

consecutive 12-months.

3. WORKSHOP COMMENT

When a coating is used outside of its intended category, what VOC content limit should that 

coating follow?

DISTRICT RESPONSE

A coating being used outside of the manufacturers’ specification will be evaluated by the 

function it is expected to accomplish. For example, a coating being used as a sealer must 

comply with the 275 g/L VOC content limit for sealers.

4. WORKSHOP COMMENT

The District should not reduce the VOC content limit from 700 g/L to 480 g/L for low-solids 

stains, toners or washcoats that are being applied to refinished wood products.

DISTRICT RESPONSE

The District agrees. There are 9 facilities that are refinishing wood products with a total 

usage of approximately 800 gallons of all coatings per year. The estimated annual emissions 

from all wood coating refinishing facilities subject to Rule 67.11 in San Diego County are 

0.75 tons per year. Therefore, the actual emission reductions achieved by lowering the VOC 

content limit for low-solids stains, toners or washcoats from 700 g/L to 480 g/L would be 

negligible. 

5. WRITTEN COMMENT

Proposed amended Rule 67.11, Subsection (b)(1)(i), exempts coatings applied using a nonrefillable aerosol spray container from complying with the provisions of Section (d). Does 

this exemption also apply to solvent cleaners applied using a non-refillable handheld aerosol 

spray container? 

DISTRICT RESPONSE

No. Subsection (b)(1)(i) only exempts coatings applied from a non-refillable handheld 

aerosol spray container. All solvent cleaners must comply with the VOC content limit 

requirement of 25 g/L of material specified in Subsection (d)(4).
Workshop Report

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6. WRITTEN COMMENT

Are dimethyl carbonate and propylene carbonate exempt in San Diego County?

DISTRICT RESPONSE

Yes. Dimethyl carbonate and propylene carbonate are exempt compounds and can be found 

listed in Table 1 (Exempt Compounds) of District Rule 2.

7. WRITTEN COMMENT

Would airless and air assisted airless spray guns meet the coating application equipment 

standard?

DISTRICT RESPONSE

No. Airless and air assisted airless spray guns have a lower transfer efficiency than the other 

application methods identified in Subsection (d)(1) of proposed amended Rule 67.11. The 

transfer efficiency of coating application equipment must be at least equal to that of one of the 

application methods identified in Subsection (d)(1).

8. WRITTEN COMMENT

The District should include a category for “Pigmented Conversion Varnish” with a VOC 

content limit of 550 g/L.

DISTRICT RESPONSE

The District disagrees. Including a separate category for pigmented conversion varnish is not 

necessary. The current definition of “Conversion Varnishes” is broadly defined to encompass 

pigmented conversion varnish sealers and topcoats.

9. WRITTEN COMMENT

Why are conversion varnishes not listed in the VOC content limits for refinished wood 

products?
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DISTRICT RESPONSE

Prior to the 1997 Rule 67.11 revision, conversion varnishes were considered topcoats with a 

VOC content limit of 680 g/L. In the 1997 rule revision, a separate new “Conversion 

Varnishes” category was added for coatings used for New Wood Products, with a more 

stringent VOC content limit of 550 g/L. The definition of topcoat was amended to exclude 

conversion varnishes. Because a conversion varnish was no longer considered a topcoat, 

conversion varnishes applied to refinished wood products would have to comply with the 

“Any Other Coatings” category at 420 g/L. That was not the District’s intent; therefore, a 

“Conversion Varnishes” category has been added for Refinished Wood Products with a VOC 

content limit of 550 g/L.

10. ARB COMMENT

The District should revise Subsection (d)(3), VOC Limits for Refinished Wood Products. The 

VOC content limit for the “Multi-Colored Coating” category should be lowered from 685 g/L 

down to 680 g/L, to be consistent with other air districts in California.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 

11. ARB COMMENT

The District should revise Subsection (d)(3), VOC Limits for Refinished Wood Products. The 

VOC content limit for the “Low-Solids Stains, Toners, or Washcoats” category should be 

lowered from 700 g/L down to 480 g/L, to be consistent with other air districts in California.

DISTRICT RESPONSE

The District disagrees. Please see District Response to Comment 4 above.

12. EPA COMMENT

The District should consider revising Subsection (c)(13), “Flow Coat”, by adding “and allow 

excess to drain off” after “object.”

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 
Workshop Report

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13. EPA COMMENT

The District should consider revising Subsection (c)(14), “Hand Application Method,” to 

include other methods that may be used but not listed in the definition.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 

14. EPA COMMENT

The District should delete Subsection (c)(19), the definition of “Low-Solids Stain.” Instead, 

refer to Rule 2 to be consistent with other definitions defined in this manner.

DISTRICT RESPONSE

The District disagrees. The definition of “low-solids stain” clarifies a coating category 

contained in the rule and used in wood coating operations. This definition should remain 

readily accessible to facilities. 

15. EPA COMMENT

The District should consider revising Subsection (c)(23), the definition of “Pigmented 

Coating”, by adding that pigmented coatings may be used either as an undercoat or topcoat.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 

16. EPA COMMENT

The District should revise Subsection (c)(25), the definition of “Roll Coat,” by adding 

language that describes a method of “moving a substrate underneath a roller applicator.”

DISTRICT RESPONSE

The District disagrees. The current definition of “Roll Coat” adequately describes the roller 

coat method used. 
Workshop Report

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17. EPA COMMENT

The District should consider revising Subsection (c)(28), the definition of “Stripping 

Material”, by adding “inks and adhesives”.

DISTRICT RESPONSE

The proposed rule has been revised by adding “adhesives” to the definition of “Stripping 

Materials.” However, “inks” are already included in the definition of “Coating,” 

Subsection (c)(6). 

18. EPA COMMENT

The District should delete Subsection (c)(30), the definition of “Touch-up Operation.” 

Instead, refer to Rule 2 to be consistent with other definitions defined in this manner.

 

DISTRICT RESPONSE

The District disagrees. The definition of “Touch-up Operation” clarifies a type of coating 

operation that is currently used by facilities. The definition should remain readily accessible 

to facilities.

19. EPA COMMENT

The District should delete Subsection (c)(34), the definition of “VOC Content per Volume of 

Material.” Instead, refer to Rule 2 to be consistent with other definitions defined in this 

manner.

DISTRICT RESPONSE

The District disagrees. This definition was included to clarify that the VOC content of lowsolids coatings, cleaning and stripping materials should be calculated per unit of volume of 

material, unlike the VOC content of high solid coatings.

20. EPA COMMENT

In Subsection (d)(1)(vii), alternate coating application methods should be approved by the 

APCO and the EPA.
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DISTRICT RESPONSE

The District disagrees. The current language is consistent with other District rules, as well as 

with requirements of other California air districts.

21. EPA COMMENT

The heading for Subsection (d)(2) should read, ”VOC Limits for Coating for New Wood 

Products,” and for Subsection (d)(3) should read, “VOC Limits for Coating for Refinished 

Wood Products” to further clarify the subject of the two tables.

DISTRICT RESPONSE

The District has added language to clarify the headings of both subsections.

22. EPA COMMENT

The District should lower the VOC content limits in Subsection (d)(2)(i) for “High-Solids

Stains” from 350 g/L to 240 g/L, to be consistent with SJVAPCD Rule 4606. 

DISTRICT RESPONSE

The District disagrees. The proposed VOC content limit for “High-Solids Stains” at 350 g/L 

is consistent with the majority of California air districts, including SCAQMD Rule 1136. 

High-Solids Stains meeting the 350 g/L limit are readily available in Southern California.

23. EPA COMMENT

The District should lower the VOC content limits in Subsection (d)(2)(i) for “Inks” from 500 

g/L to 250 g/L, to be consistent with BAAQMD flat wood coating rule, Rule 8-23. 

DISTRICT RESPONSE

The District disagrees. The District’s 500 g/L VOC content limit for “Inks” is consistent with 

the requirements found in the majority of California air districts’ wood coating rules. 

Furthermore, the District does not have flat wood coating operations; therefore, the 

recommended limit does not apply.
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24. EPA COMMENT

The District should lower the VOC content limits in Subsection (d)(3)(ii) for Refinished 

Wood Products for “Low-Solids Stains, Toners or Washcoats” from 700 g/L to 480 g/L, to be 

consistent with SMAQMD Rule 463. 

DISTRICT RESPONSE

The District disagrees. Please see District Response to Comment 4 above.

25. EPA COMMENT

The requirement in Subsection (f)(1)(iii) to, "Maintain monthly or daily records...," is vague 

and may undermine compliance. We suggest that daily recordkeeping be required if monthly 

VOC content limits exceed those in Subsections (d)(2), (3), (4), (5) and (6), such as required 

in SMAQMD Rule 463, Section 501.2. This is stated in Subsection (f)(2)(ii), but this applies 

only to situations using control equipment. In addition, EPA's Little Blue Book (August 21, 

2001, page 11) recommends that rules which allow recordkeeping less frequently than daily 

should specify that the violations of the weekly requirement are presumed to be separate 

violations for each day within the week. 

DISTRICT RESPONSE

The District disagrees. The current language in Rule 67.11, Subsection (f)(1)(iii), is 

consistent with language in other SDAPCD rules, including those rules that were recently 

adopted into the California State Implementation Plan. Furthermore, the proposal is 

consistent with EPA's Little Blue Book (August 21, 2001, page 11, #4), which states that 

Rules that establish VOC content limits on materials (e.g., coating), but do not establish

emission or use caps, can allow monthly recordkeeping for sources using only compliant 

materials. In addition, a facility’s permit to operate will often require daily recordkeeping if 

the facility is subject to New Source Review. 

26. EPA COMMENT

All references to EPA test methods in Subsections (g)(1), (2) and (8) should have the 

complete title and the most recent date as listed in 

http://www.epa.gov/ttn/emc/promgate.html. 

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 
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27. EPA COMMENT

Regarding Subsections (g)(1), (2), (4), (6) and (8), other district test methods and guidelines 

should have the date of the EPA-approved version, which is not the date it was "approved by 

the EPA." The statement "approved by the EPA" should be removed. Refer to 

http://www.arb.ca.gov/fcaa/tv/tvinfo/accp_mth.htm for these approved version dates. In 

Subsection (g)(8) the guideline referenced should be SCAQMD CE - Guideline for 

Determination of VOC Capture Efficiency, dated May, 1995.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 

28. EPA COMMENT

All ASTM test methods listed in Subsections (g)(3) and (7) should have the complete title and 

the EPA-approved version date, as listed in 40 CFR 60.1, not "or its most current version."

The most recent version year, shown in parenthesis, should be removed. The correct 

approved ASTM test procedures are: D5403-93, D3792-91, D4017-96a and D4457-91. 

DISTRICT RESPONSE

The District disagrees. The current ASTM test method references in proposed amended 

Rule 67.11, Section (g), are consistent with language in other District rules, including those 

rules that were recently adopted into the California State Implementation Plan. Furthermore, 

coating Manufacturer’s and Testing Laboratories that perform ASTM test methods will only 

use the most current ASTM test method. The District does not want to reference a specific 

EPA approval date and have the rule be outdated once the EPA approval date changes. 

29. EPA COMMENT

In Subsection (g)(7), the correct title for the EPA-approved district procedure is SD 1, 

Procedures for Estimating the Vapor Pressure of VOC Mixtures, dated June 20, 1990.

DISTRICT RESPONSE

The District agrees. The proposed amended rule has been revised as suggested. 

AD:jl

08/01/11