UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX AIR DIVISION

Technical Support Document 

for 

EPA’s Proposed Rulemaking 

for the 

California State Implementation Plan 

San Joaquin Valley Air Pollution Control District, Rule 4606, Wood Products and 

Flat Wood Paneling Product Coating Operations 

Prepared by: Nicole Law 

Reviewed by: Andrew Steckel 

June 2009 
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RULE IDENTIFICATION - 

Agency: San Joaquin Valley Air Pollution Control District 

(SJVAPCD) 

SIP Approved Rule: Rule 4606 – Wood Products and Flat Wood Paneling 

Products Coating 

Adopted – December 20, 2001; Submitted – February 

20, 2002 

EPA Approved – June 26, 2002 (67 FR 42999) 

Superseded Submittals: Adopted – September 20, 2007; Submitted – March 7, 

2008 

Subject of this TSD: Rule 4606 – Wood Products and Flat Wood Paneling 

Products Coating 

 Amended – October 16, 2008; Submitted – December 

23, 2008 

RULE SUMMARY - SJVAPCD Rule 4606, Wood Products and Flat Wood 

Paneling Products Coating, is a rule designed to limit volatile organic compound 

(VOC) emissions from facilities engaged in coating of wood products and flat 

wood paneling. It also limits VOC emissions from organic solvent cleaning and 

storage and disposal of solvents and waste solvent materials associated with 

such coating. The rule describes related administrative requirements for 

recording and measuring emissions. Changes from the approved SIP rule 

include: 

1. Changed the applicability to include flat wood paneling. 

2. Added several definitions in Section (3.0) and made numerous other 

editorial changes to improve clarity. 

3. Added requirements for flat wood paneling which include VOC limits, 

control efficiencies, and work practice standards. 

4. Exemption in Section (4.5) regarding incineration devices was removed. 

5. Added capture and control efficiency equations under test methods. 

6. Lowered VOC limits for organic solvents used in cleaning operations to 25 

grams of VOC per liter of material. 

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), the Little 
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Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) and State Implementation 

Plans, General Preamble for the Implementation of Title I of the Clean Air 

Amendments of 1990 (57 FR 13498, April 16, 1992) 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 Wood Furniture Manufacturing 

Operations” (EPA-453/R-96-007, April 1996), “Control Techniques 

Guidelines for Flat Wood Paneling Coatings” (EPA-453/R-06-004, 

September 2006), SJVAPCD’s 2009 RACT SIP Demonstration (April 16, 

2009), “Preamble, Final Rule to Implement the 8-hour Ozone National 

Ambient Air Quality Standard: (70 FR 71612 November 29, 2005), Letter 

from William T. Hartnett to Regional Air Division Directors, “RACT Qs & As 

– Reasonable Available Control Technology (RACT) Questions and 

Answers” (May 18, 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. 

On April 16, 2009, SJVAPCD adopted its “2009 RACT SIP,” which provides the 

District’s demonstration that RACT is implemented for all appropriate activities. 

This includes several pages discussing Rule 4606 (cover and applicable pages 

attached). In summary, SJVAPCD found that: 

- Rule 4606 satisfies RACT because it is consistent with the requirements in 

the 1996 CTG, “Wood Furniture Manufacturing Operations” and the 2006 

CTG, “Flat Wood Paneling Coatings.” 

- Rule 4606 is as stringent as other rules in other large California 

nonattainment areas. 

We concur with SJVAPCD’s conclusion that Rule 4606 implements RACT for 

reasons including: 

- EPA’s 2006 CTG, “Flat Wood Paneling Coatings,” generally defines 

presumptive RACT for this activity nationwide as VOC limits in coatings of 

250 grams of VOC/liter of coating and 350 grams of VOC/gram of solids. 

SJV Rule 4606 contains the VOC limits and work practices recommended in 

this 2006 CTG. 

- The requirements in Rule 4606 are generally more stringent than EPA’s 

1996 CTG, “Wood Furniture Manufacturing Operations.” While Rule 4606 
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exempts refinishing, replacement, and custom replica furniture operations 

from VOC control requirements and the CTG does not, only two sources in 

the district fall under this category, and both have VOC emissions well 

below the CTG threshold of 10 tons/year of VOC per facility. 

- Most requirements in Rule 4606 are equivalent or more stringent than 

requirements in analogous rules in other large California nonattainment 

areas. While a few requirements are more stringent in other areas, the 

variations are not significant and are generally offset by other more 

stringent requirements in Rule 4606. 

- SJVAPCD, SCAQMD and the other large California nonattainment 

agencies generally have among the most stringent stationary source 

requirements nationwide, and we are not aware of other reasonably 

available technological or operational controls likely to significantly reduce 

additional emission from this activity. 

Therefore, we believe Rule 4606 meets RACT requirements. In addition, 

recordkeeping and other compliance provisions in the rule ensure that the 

requirements are adequately enforceable. 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 4606 

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. 

1. Consistent with the CTG for Emissions from Wood Furniture Manufacturing 

Operation” (EPA-453/R-96-007, April 1996), we recommend the addition of 

an operator training program to work practices. 

2. We recommend adding VOC limits for refinishing, replacement, and 

custom replica furniture operations. For example, please see SMAQMD 

Rule 463 Section (303) and VCPCD Rule 74.30 Section (B.2). 

3. We recommend full titles of ARB test methods be added to Section (6.8). 

EPA ACTION - 

The revised Rule 4606 mainly incorporates new requirements for coating 

operations of flat wood panels, strengthening the SIP. SJVAPCD projects no 

significant emission impacts from these changes, as there are no coating 

operations for flat wood panels in the district. The rule fulfils the relevant CAA 

§110 and part D requirements. EPA staff recommends approval of Rule 4606 

pursuant to CAA §110(k)(3). 
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ATTACHMENTS – 

1. SJVAPCD Rule 4606, Wood Products and Flat Wood Paneling Products 

Coating Operations, as submitted on December 23, 2008. 

2. SJVAPCD Rule 4606, Wood Products Coating Operations, as approved 

into the SIP on June 26, 2002. 

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. “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. “Reasonably Available Control Technology (RACT) Demonstration for 

Ozone State Implementation Plans (SIP)” SJVAPCD, April 16, 2009. 

ADDITIONAL REFERENCES - 

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

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

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

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

3. Portions of the proposed post-1987 ozone and carbon monoxide policy that 

concern RACT, 52 FR 45044, November 24, 1987. 

4. “State Implementation Plans, General Preamble for the Implementation of 

Title I of the Clean Air Amendments of 1990” 57 FR 13498, April 16, 1992. 

5. “Preamble, Final Rule to Implement the 8-hour Ozone National Ambient Air 

Quality Standard” 70 FR 71612; Nov. 29, 2005. 

6. Letter from William T. Hartnett to Regional Air Division Directors, “RACT 

Qs & As – Reasonable Available Control Technology (RACT) Questions 

and Answers,” May 18, 2006.