UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

FEATHER RIVER AIR QUALITY MANAGEMENT DISTRICT

Rule 3.20, Wood Products Coating Operations

Prepared by: Arnold Lazarus

Reviewed by: Andy Steckel

October 2014
2

RULE IDENTIFICATION 

Agency: Feather River Air Quality Management District 

(FRAQMD)

SIP Approved Rule: There are no versions of FRAQMD Rule 3.20 which have 

been SIP approved.

Subject of this TSD: Rule 3.20 - Wood Products Coating Operations

Adopted - August 1, 2011

Submitted - February 10, 2014

RULE BACKGROUND –

Under Section 107(d) of the Clean Air Act (CAA), EPA designated portions of Yuba and 

Sutter counties nonattainment for the following three National Ambient Air Quality 

Standards (NAAQS): 1-hour ozone, 1997 8-hour ozone and 2008 8-hour ozone. These 

areas are regulated by the Feather River Air Quality Management District (FRAQMD).

FRAQMD Rule 3.20 is a new rule to the federally approved State Implementation Plan 

(SIP) that was adopted by FRAQMD to establish limits on the emission of volatile 

organic compounds (VOC) from coating and strippers used on wood products. 

According to the associated FRAQMD Staff report, “Feather River Air Quality 

Management District (District) is a Bi-County agency that administers local, state, and 

federal air quality management programs for Yuba and Sutter Counties. ”

1 On August 

18, 2014, FRAQMD adopted Resolution #2014-10 adopting a RACT Analysis and 

Negative Declaration Staff Report declaring “there are no major sources of ozone 

precursors and that the District’s rules are as stringent as the CTG’s for the applicable 

source type.”2 The CTGs cited for which FRAQMD adopted a Negative Declaration 

include:

1. Control of Volatile Organic Compound Emission from Wood Furniture Operations

EPA-453/R-96-007 1996/04.

2. Control Technique Guidelines for Flat Wood Paneling Coatings EPA-453/R-06-

004 2006/09.

RULE SUMMARY - FRAQMD Rule 3.20, Wood Products Coating Operations (WPCO), 

is a rule designed to establish limits on the emission of VOC from coatings and strippers 

used on wood products. According to the Staff Report, it was based on Sacramento 

Metropolitan Air Quality Management District (SMAQMD) Rule 463, “Wood Products 

 

1 FRAQMD Final Staff Report, “Rule 3.14: Surface Preparation and Clean-up, Rule 3.19: Vehicle and Automotive 

Coating Operations, Rule 3.20: Wood Products Coating Operations. Rule 1.1 Definitions” June 6, 2011, p.1.

2 Letter of Declaration, Feather River AQMD to California Air Resources Board, August 18, 2014.
3

Coatings.”

3 Rule 3.20 includes the following major requirements:

1. The rule applies to any person who uses, manufactures, blends, sells, 

repackages, distributes, or specifies the use of wood products coatings and/or 

strippers for use within the District.

2. Wood coating products may only be applied when using one of the listed 

application methods in section D.1.

3. The rule established VOC content limits for wood coatings of various categories 

in sections D.2 and D.3. There are also VOC content limits for strippers in 

section D.4.

4. As an alternative to using compliant coatings, a person may use emission control 

equipment, provided the equipment achieves an equivalent or greater level of 

VOC reductions as using compliant coatings. The requirements are outlined in 

section D.5.

5. Another alternative to using compliant coatings is the averaging provision

described in section D.6.

6. The rule established various administrative requirements outlining labeling, vapor 

pressure calculations, VOC content calculations, and operation and maintenance 

plan requirements, recordkeeping, records retention, and test methods used in 

sections F and G.

EPA EVALUATION CRITERIA – 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. Stringency – Rule 3.20 is not subject to RACT because FRAQMD has submitted 

a “negative declaration” stating that there are no major sources or sources 

subject to EPA’s CTG emitting VOC in the District. However, we are comparing 

Rule 3.20 to SMAQMD Rule 463, Ventura County Air Pollution Control District 

(VCAPCD) Rule 74.30, San Joaquin Valley Air Pollution Control District 

(SJVAPCD) Rule 4606 and the relevant CTG4in case RACT is required in the 

future. 

 

3 FRAQMD Staff Report, “Rule 3.20, Wood Products Coating Operations” August 30, 2005, p.2.

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“Control of Volatile Organic Compound Emissions from Wood Furniture Operations” (EPA-453/R-06-007, April 

1996)
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3. SIP Relaxation - CAA §110(l) prohibits EPA from approving any SIP revision that 

would interfere with any applicable requirement concerning attainment and 

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

CAA. In addition, CAA §193 prohibits the modification of any SIP-approved control 

requirement in effect before November 15, 1990, in a nonattainment area.

EPA EVALUATION

1. The rule requirements and applicability are clear, and the monitoring, 

recordkeeping, reporting and other provisions sufficiently ensure that affected 

sources and regulators can evaluate and determine compliance with Rule 3.20 

consistently. Therefore, we determine that the rule adequately fulfils the 

enforceability requirements summarized in paragraph #1 above.

2. The submitted rule has almost identical VOC content limits and similar 

administrative requirements as SMAQMD Rule 463, VCAPCD Rule 74.30, 

SJVAPCD Rule 4606 and is generally more stringent than the CTG. However, 

several provisions discussed below in the recommendations section may need to 

be addressed in order to determine that this rule implements RACT should that 

be needed in the future. 

3. We propose to determine that our approval of the submittal would comply with 

CAA §§110(l) and 193 because (1) the proposed SIP revision would not interfere 

with the on-going process for ensuring that requirements for RFP and attainment 

of the NAAQS are met, and (2) the emission limits and other requirements in the 

submitted rule clearly strengthen the SIP because there are currently no 

requirements specifically pertaining to WPCO currently in the FRAQMD portion 

of the SIP.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 3.20 sufficient for 

EPA to propose less than full approval at this time.

EPA ACTION - Rule 3.20 satisfies relevant CAA §110 and part D requirements. 

Therefore, EPA staff recommends full approval of this rule into the SIP.

EPA RECOMMENDATIONS

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

recommended for the next time the rule is amended.

1. Sources using less than 55 gallons per year of wood product coatings and/or 

strippers are exempt from the requirements of this rule. Bay Area Air Quality 

Management District (BAAQMD) Rule 8-32, SJVAPCD Rule 4606, and Santa 

Barbara County Air Pollution Control District (SBAPCD) Rule 351 limit this 

exemption to 20 gallons per year. We recommend revising Rule 3.20 consistent 
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with these other district requirements.

2. The VOC limit for “High-Solid Stain” in Section D.2 is 350 g/l. SJVAPCD Rule 

4606, SBAPCD Rule 351, and VCAPCD Rule 74-30 all have a limit of 240 g/l for 

this category. We recommend revising Rule 3.20 consistent with these other 

district rules.

3. The VOC limit for “Sealer” in Section D.2 is 275 g/l. VCAPCD Rule 74.30 has a 

limit of 240 g/l for this category. We recommend revising Rule 3.20 consistent 

with VCAPCD Rule 74-30.

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

Operation” (EPA-453/R-96-007, April 1996), we recommend the rule add an 

operator training program to work practices. See, e.g., Appendix B of the cited 

CTG (B.5 (b)), “Operator Training Course.”

5. We recommend removing “Stencil Coatings when used to comply with U.S. 

Military Specifications” from “Exemptions” (Section B.1.e.) to be consistent with 

SMAQMD Rule 463.

6. We recommend full titles of ASTM test methods and the appropriate year be 

added to Section G.

7. We recommend removing exemption B.1.c. SBAPCD Rule 351, VCAPCD Rule 

74.30 and SJVAPCD Rule 4606 do not have an exemption for flat paneling.

8. We recommend removing the Emissions Averaging Plan option in section E.3, or 

revising it consistent with EPA’s Economic Incentive Policy guidance5 and the 

CTG.6 This likely includes, for example, allowing averaging only for section D.3 

(Refinishing, Repairing, Preserving or Restoring Wood Products), limiting

averaging to a maximum of 20 gallons per year and ensuring an environmental 

benefit of the averaging option. 

 

5

Improving Air Quality with Economic Incentive Programs, EPA-452/R-01-001, January 2001. 

6 Control Techniques Guidelines, EPA 453-R-96-007 Control of VOC Emission from Wood Furniture 

Manufacturing Operations, April 1996, Section 7, P.4.
6

REFERENCES

1. FRAQMD Rule 3.20 - Wood Products Coating Operations, amended August 1, 

2011.

2. The Bluebook (Issues Relating to VOC Regulation Cutpoints, Deficiencies, and

Deviations, EPA, May 25, 1988).

3. The Little Bluebook (Guidance Document for Correcting Common VOC & Other 

Rule Deficiencies, EPA Region 9, August 21, 2001).

4. SMAQMD Rule 463, Wood Products Coatings, amended September 25, 2008.

5. SBAPCD Rule 351, Surface Coating of Wood Products, amended August 20, 

1998.

6. SJVAPCD Rule 4606, Wood Products and Flat Wood Paneling Products Coating 

Operations, Amended October 16, 2008.

7. VCAPCD Rule 74.30, Wood Products Coatings, amended June 27, 2006.

8. BAAQMD Rule 8.32, Wood Products Coatings, amended December 20, 1995.

9. Control Techniques Guidelines, EPA 453-R-96-007 Control of VOC Emission 

from Wood Furniture Manufacturing Operations, April 1996.

10. Control Technique Guidelines for Flat Wood Paneling Coatings EPA-453/R-06-

004, September 2006