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 238, Factory Coating of Flat 

Wood Paneling 

Prepared by: Nicole Law 

Reviewed by: Andrew Steckel 

October 2011 
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RULE IDENTIFICATION - 

Agency: Placer County Air Pollution Control District (PCAPCD) 

SIP Approved Rule: Rule 238 – Factory Coating of Flat Wood Paneling 

Adopted – June 8, 1995; Submitted – October 13, 

1995 

EPA Approved – February 12, 1996 (61 FR 5288) 

Subject of this TSD: Rule 238 – Factory Coating of Flat Wood Paneling 

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

2011 

RULE SUMMARY PCAPCD Rule 238, Coating of Flat Wood Paneling, is a rule 

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

strippers used on wood paneling. Work practice procedures are also included in 

the rule to minimize VOC emissions. The rule describes related administrative 

requirements for recording and measuring emissions. Changes from the 

approved SIP rule include: 

1. Renamed the “description” section to “purpose” and shortened the section 

to only discuss what the rule purpose is. Added a “severability” section to 

the rule. 

2. Expanded the “applicability” section to include facilities located within the 

entire district. 

3. Added two new exemptions to the rule. The first clarifies that coating, 

inks, and cleanup materials subject to VOC limits in this rule are exempt 

from provisions of Rule 219, Organic Solvents. 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. Revised the low usage complete exemption from 20 gallons of coating per 

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

5. Added a low solids coatings and inks category with corresponding VOC 

limit of 120 g/L. 

6. Increased the emission control system efficiency requirement from 90% to 

95%. 

7. Added the “cleanup and storage procedures” section which describes 

requirements for handling solvents for cleanup use. They are generally 

work practice procedures which include storing solvents in closed 

containers, cleaning spray equipment in an enclosed system, and 

minimizing spilling. 

8. Added a requirement to submit an operation and maintenance plan for 

facilities electing to use an emission control system as an alternative 

control. 

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

basis. Similarly, tints used to color stains used in quantities of less than 

one pint per operating day are required to have monthly usage records. 
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10. Added recordkeeping requirements for emission control systems. Monthly 

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

operating and maintenance procedures of emission control systems. 

11. The retention period for records has been extended from 2 years to 3 

years. 

12. 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. 

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

Volatile Organic Compound Emissions from Existing Stationary Sourcesvolume VII: Factory Surface Coating of Flat Wood Paneling” (EPA-450/2-78-

032, June 1978), “Control Techniques Guidelines for Flat Wood Paneling 

Coatings” (EPA-453-/R-06-004, September 2006) 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 two 

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 and lower than the CTG 

recommended threshold of 15 lbs VOC/day. 

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

coating materials used. The new amendment lowers the frequency to 
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monthly records for any coating usage including tints used to color stains. 

The recordkeeping for general coating usage 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. However, the monthly recording 

for tints used to color stains is inconsistent with the daily exemption allowed 

for tints used to color stains and makes the exemption less unenforceable. 

Tints used to color stains used in quantities of one pint or less per day are 

exempt from provisions in the rule. Because the rule’s general exemption is 

more restrictive than the CTG’s recommendations, the rule complies with 

RACT requirements. Additionally, the district has indicated the two facilities 

under Rule 238 do not use coatings in the category of tints used to color 

stains. 

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

recommendations. We do not consider these revisions relaxations because they 

do not directly contribute to additional VOC emissions and are consistent with the 

2006 CTG, which we currently use to define RACT. 

The monitoring, recordkeeping, reporting and other requirements generally ensure 

that the submitted rule can be enforced. The rule is 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 328 

sufficient for EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

following revisions are not currently the basis for rule disapproval, but are 

recommended for the next time the rule is amended. 

• Require records be maintained on a daily basis for usage of tints used to 

color stains. 

• Expand the applicability of the rule to include exterior side paneling, as is 

done in the 2006 CTG. 

EPA ACTION - 

The submitted Rule 238 will clarify the rule and strengthens the SIP. The rule 

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

approval of Rule 238 pursuant to CAA §110(k)(3). 
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REFERENCES - 

1. PCAPCD Rule 238, Factory Coating of Flat Wood Paneling, as submitted 

on April 5, 2011. 

2. PCAPCD Rule 238, Factory Coating of Flat Wood Paneling, as approved 

into the SIP on February 12, 1996. 

3. “Control of Volatile Organic Compound Emissions from Existing Stationary 

Sources- volume VII: Factory Surface Coating of Flat Wood Paneling,” 

EPA-450/2-78-032, June 1978. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/197806_voc_epa450_2-78-

032_surface_coatings(v7).pdf 

4. “Control Techniques Guidelines for Flat Wood Paneling Coatings,” EPA453-/R-06-004, September 2006. 

http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r-06-

004_wood_panel_coatings.pdf 

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

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

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

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