October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -1 Rules and Regulations

RULE 236 WOOD PRODUCTS COATING OPERATIONS

Adopted 11-03-94

(Amended 2-09-95, 4-10-97, 8-14-97, 10-14-10 [Effective 7-1-11])

CONTENTS

100 GENERAL

101 PURPOSE

102 APPLICABILITY

103 SEVERABILITY

104 EXEMPTIONS

200 DEFINITIONS

201 AEROSOL-SPRAY COATING

202 AFFECTED POLLUTANT

203 AIR ASSISTED AIRLESS SPRAY

204 BINDERS

205 CAPTURE EFFICIENCY

206 CLEANUP MATERIAL

207 CLEAR TOPCOAT

208 CLOSED CONTAINER

209 COATING

210 CONTROL DEVICE EFFICIENCY

211 CONVERSION VARNISH

212 CRACKLE LACQUER

213 DETAILING OR TOUCH-UP GUNS

214 DIP COAT

215 ELECTROSTATIC APPLICATION

216 EMISSIONS UNIT

217 EMISSION CONTROL SYSTEM

218 ENCLOSED GUN CLEANER

219 EXEMPT COMPOUNDS

220 FAUX FINISH

221 FILLER

222 FLOW COATING

223 HIGH-SOLIDS

224 HIGH-VOLUME-LOW-PRESSURE (HVLP) SPRAY

225 IMITATION WOOD GRAIN

226 INKS

227 LEAF FINISH

228 LOW-SOLIDS COATING

229 LOW-VOLUME, LOW-PRESSURE (LVLP) EQUIPMENT

230 MOLD-SEAL COATING

231 MULTI-COLORED COATING

232 NEW WOOD PRODUCT

233 NON-SHOP ARCHITECTURAL COATING OPERATIONS

234 OPAQUE STAINS

235 PIGMENTED COATINGS

236 REACTIVE DILUENT

237 REFINISHING OPERATION

238 REPAIR

239 ROLL COATER

240 SEALER

241 SEMITRANSPARENT STAIN
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 2 Placer County APCD

242 SIMULATED WOOD MATERIALS

243 STAIN

244 STENCIL COATING

245 STRIPPER

246 SURFACE PREPARATION MATERIAL

247 TINT

248 TONER

249 TOUCH-UP

250 VOC COMPOSITE PARTIAL VAPOR PRESSURE

251 VOLATILE ORGANIC COMPOUND (VOC)

252 VOC CONTENT

253 WASH COAT

254 WOOD PANEL

255 WOOD PRODUCTS

256 WOOD PRODUCT COATING APPLICATION OPERATIONS

300 STANDARDS

301 APPLICATION EQUIPMENT REQUIREMENTS

302 LIMITS FOR VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS

303 LIMITS FOR VOC CONTENT OF COATINGS FOR REFINISHING, REPAIRING, 

PRESERVING, OR RESTORING WOOD PRODUCTS

304 LIMITS OF VOC CONTENT FOR STRIPPERS

305 EMISSION CONTROL SYSTEM

306 REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP MATERIALS

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF SPECIFICATION

402 PROHIBITION OF POSSESSION

403 PROHIBITION OF SALE OR MANUFACTURE

404 LABELING REQUIREMENTS, VOC CONTENT

405 OPERATION AND MAINTENANCE PLAN

500 MONITORING AND RECORDS

501 RECORDKEEPING

502 RETENTION OF RECORDS

503 TEST METHODS
October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -3 Rules and Regulations

100 GENERAL

101 PURPOSE: To establish limits on the emission of volatile organic compounds (VOC) from 

coatings and strippers used on wood products, and from products used in surface 

preparation and cleanup.

102 APPLICABILITY:

102.1 Business Category: The provisions of this rule shall apply to any person who uses, 

manufactures, blends, sells, repackages, distributes, or specifies wood products 

coatings and/or strippers to be used for the coating and/or surface preparation of 

wood products, including furniture, cabinets, and custom replica furniture.

103 SEVERABILITY: If any section, subsection, sentence, clause, phrase, or portion of this rule 

is, for any reason, held invalid, unconstitutional or unenforceable by any court of competent 

jurisdiction, that portion shall be deemed as a separate, distinct, and independent provision, 

and the holding shall not affect the validity to the remaining portions of the rule.

104 EXEMPTIONS:

104.1 Exemption, Residential: Residential non-commercial operations are exempt from all 

provisions of this rule.

104.2 Exemption, Non-Shop Architectural Coating Operations: The coating of stationary 

structures and their appurtenances in a non-shop environment, is subject to Rule 

218, ARCHITECTURAL COATINGS, and is exempt from all provisions of this rule.

104.3 Exemption, Aerosol Spray Coatings: Aerosol wood products coatings sold in nonrefillable aerosol containers are exempt from all provisions of this rule.

104.4 Exemption, Panels and Siding: The factory application of wood products coatings in 

the manufacturing of finished wood panels intended for attachment to the inside 

walls of buildings, including, but not limited to, homes and office buildings, mobile 

homes, trailers, prefabricated buildings and similar structures, is subject to Rule 238, 

FACTORY COATING OF FLAT WOOD PANELING, and is exempt from all 

provisions of this rule.

104.5 Exemption, Other: The application of coatings by template or stencil to add designs, 

letters or numbers to wood products, and the application of coatings to wooden 

musical instruments are exempt from all provisions of this rule.

104.6 Partial Exemption, Low Volume: Businesses using less than 55 gallons per year of 

wood products coatings and/or strippers (singly or in any combination) are exempt 

from all provisions of this rule with the exception of Section 501, Recordkeeping.

104.7 Partial Exemption, Specific Finishes: Coatings used to produce the following finishes 

are exempt from the provisions of Sections 302, 303 and 304, provided that records 

are maintained as specified in Section 501, Recordkeeping:

104.7.1 Crackle lacquers;

104.7.2 Faux finishes;

104.7.3 Imitation wood grain;

104.7.4 Leaf finishes.
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 4 Placer County APCD

104.8 Exemption, Tints: Tints applied to stains in quantities not to exceed one pint of tint in 

any operating day are exempt from all provisions of this rule, except for records. 

Records shall be maintained and reported as specified in Sections 501.1.4 and 

501.2.2

104.9 Exemption From Requirements of Other District Rules: Any wood products coating, 

stripper or cleaning solvent subject to the VOC limitations of this rule, Sections 302, 

303, and 304, is exempt from the requirements of Rule 219, ORGANIC SOLVENTS.

200 DEFINITIONS

201 AEROSOL-SPRAY COATING: A coating which is sold in a hand-held, pressurized, 

non-refillable container of 1 liter (1.1 quarts) or less, and which is expelled from the container 

in a finely divided spray when a valve on the container is depressed.

202 AFFECTED POLLUTANT: Volatile organic compounds (VOC), as defined in Section 251.

203 AIR ASSISTED AIRLESS SPRAY: Equipment used to apply coatings that uses fluid 

pressure to atomize coating and air pressure between 0.1 and 20 psig to adjust the spray 

pattern.

204 BINDERS: Non-volatile polymeric organic materials (resins) which form surface film in 

coating applications.

205 CAPTURE EFFICIENCY: Expressed in percent, capture efficiency is the ratio of the weight 

of the VOC in the effluent stream entering a control device to the weight of the VOC emitted 

from wood product coating operations, both measured simultaneously in accordance with 

Section 503.4, and calculated by the following equation:

 Wc

Capture Efficiency = ------- X 100

 We

Where: Wc = Weight of VOC entering the control device

We = Weight of VOC discharged from the coating operations

206 CLEANUP MATERIAL: A VOC-containing material used to clean application equipment 

used in wood products coating operations.

207 CLEAR TOPCOAT: The final coating which contains binders, but not opaque pigments, and 

is specifically formulated to form a transparent or translucent solid protective film.

208 CLOSED CONTAINER: A container which has a cover where the cover meets with the main 

body of the container without any gaps between the cover and the main body of the 

container.

209 COATING: A material which is applied to a surface and which forms a film in order to 

beautify and/or protect such surface. "Coating" includes, but is not limited to, materials such 

as topcoats, stains, sealers, fillers, conversion varnish, pigmented coating, multicolored 

coating, moldseal coating, washcoat, and toner.
October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -5 Rules and Regulations

210 CONTROL DEVICE EFFICIENCY: Expressed in percent, control device efficiency is the 

ratio of the weight of the VOC removed by the control device from the effluent stream 

entering the control device to the weight of VOC in the effluent stream entering the control 

device, both measured simultaneously in accordance with Section 503.5, and calculated by 

the following equation:

(Wc - Wa)

Control Device Efficiency = -------------- X 100

 Wc

Where: Wc = Weight of VOC entering the control device

Wa = Weight of VOC discharged from the control device

211 CONVERSION VARNISH: A coating comprised of a homogeneous (alkyd-amino resin) 

liquid which, when acid catalyzed and applied, hardens upon exposure to air or heat, by 

evaporation and polymerization, to form a continuous film that imparts protective or 

decorative properties to wood surfaces. When used as a self sealing system or as a 

pigmented coating, conversion varnish shall not be subject to the July 1, 2005 VOC limit for 

Sealers or for Pigmented Coatings, as specified in Section 302.

212 CRACKLE LACQUER: A clear or pigmented topcoat intended to produce a cracked or 

crazed appearance when dry.

213 DETAILING OR TOUCH-UP GUNS: Small air spray equipment, including air brushes, that 

operates at no greater than five (5) cfm air flow and no greater than 50 psig air pressure and 

is used to repair or touch-up portions of wood products.

214 DIP COAT: A coating which is applied by dipping an object into a vat of coating material and 

allowing any excess coating material to drain off.

215 ELECTROSTATIC APPLICATION: The electrical charging of atomized coating droplets for 

deposition by electrostatic attraction.

216 EMISSIONS UNIT: An identifiable operation or piece of process equipment such as an 

article, machine, or other contrivance which controls, emits, may emit, or results in the 

emissions of any affected pollutant directly or as fugitive emissions.

217 EMISSION CONTROL SYSTEM: A system for reducing emissions of VOC from coating 

operations. It consists of (1) equipment which captures drying oven exhaust and fugitive 

emissions from the line and transports them to the control device, and (2) a VOC control 

device which destroys the VOC or otherwise limits the emission of VOC to the atmosphere. 

The capture efficiency and the control device efficiency are calculated in accordance with 

Sections 205 and 210, respectively.

The Emission Control System Efficiency is calculated by the following equation:

Efficiency = Capture Efficiency X Control Device Efficiency / 100

218 ENCLOSED GUN CLEANER:

218.1 A device that is used for the cleaning of spray guns, pots and hoses, that has an 

enclosed solvent container, is not open to the ambient air when in use, and has a 

mechanism to force the cleanup material through the gun while the cleaner is in 

operation; or
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 6 Placer County APCD

218.2 A device that is used for the cleaning of spray guns, pots and hoses, that has an 

enclosed solvent container, uses non-atomized solvent flow to flush the spray 

equipment and collects and returns the discharged solvent to the enclosed container.

219 EXEMPT COMPOUNDS: For the purposes of this rule, exempt compounds are as described 

in Rule 102, DEFINITIONS.

220 FAUX FINISH: A finish intended to simulate a surface other than wood, including stone, 

sand, slate, marble, metal, metal flake or leather.

221 FILLER: A preparation used to fill in cracks, grains, etc., of wood before applying a coating.

222 FLOW COATING: A coating application system where paint flows over the part and the 

excess coating drains back into the collection system.

223 HIGH-SOLIDS: A coating containing more than one (1) pound of solids per gallon of coating, 

by weight, when measured in accordance with Section 503.1, and which can include wiping 

stains, glazes, and opaque stains.

224 HIGH-VOLUME-LOW-PRESSURE (HVLP) SPRAY: Equipment used to apply coatings by 

means of a spray gun which is designed to be operated and which is operated between 0.1 

and 10 psig air pressure measured dynamically at the center of the air cap and at the air 

horns.

225 IMITATION WOOD GRAIN: A hand applied finish that simulates the appearance of a 

specific natural wood grain.

226 INKS: A fluid that contains dyes and/or colorants and is used to make markings but not to 

protect surfaces.

227 LEAF FINISH: A finish used in conjunction with metal leaf or foil.

228 LOW-SOLIDS COATING: A coating containing one (1) pound of solids per gallon of coating 

or less, by weight, when measured in accordance with Section 503.1, and which can include 

semi-transparent stains, toners, and washcoats.

229 LOW-VOLUME, LOW-PRESSURE (LVLP) EQUIPMENT: Spray coating application 

equipment with air pressure between 0.1 and 10.0 psig and air volume less than 15.5 cfm per 

spray gun and which operates at a maximum fluid delivery pressure of 50 psig.

230 MOLD-SEAL COATING: The initial coating applied to a new mold or repaired mold to 

provide a smooth surface which, when coated with a mold release coating, prevents products 

from sticking to the mold.

231 MULTI-COLORED COATING: A coating which exhibits more than one (1) color when 

applied and which is packaged in a single container and applied in a single coat.

232 NEW WOOD PRODUCT: A wood product which has not been previously coated or a wood 

product from which uncured coatings have been removed to repair flaws in initial coatings 

applications.

233 NON-SHOP ARCHITECTURAL COATING OPERATIONS: The commercial application of 

coatings to stationary structures and/or their appurtenances, to mobile homes, to pavements, 

or to curbs, and not conducted inside, or on the premises of, a factory or shop building 

facility.
October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -7 Rules and Regulations

234 OPAQUE STAINS: Stains not classified as semitransparent stains, which contain pigments 

which give character to wood.

235 PIGMENTED COATINGS: Opaque coatings which contain binders and colored pigments 

which are formulated to hide the wood surface, either as an undercoat or topcoat.

236 REACTIVE DILUENT: A liquid component of a coating which is a VOC during application, 

and one in which, through chemical or physical reactions, such as polymerization, becomes 

an integral part of a finished coating.

237 REFINISHING OPERATION: The steps necessary to remove cured coatings and to repair, 

preserve, or restore a wood product.

238 REPAIR: Recoating portions of previously coated product to cover mechanical damage to 

the coating following normal painting operations.

239 ROLL COATER: A series of mechanical rollers that forms a thin coating film on the surface 

of roller, which is applied to a substrate by moving the substrate underneath the roller.

240 SEALER: A coating containing binders, which seals the wood prior to application of the 

subsequent coatings.

241 SEMITRANSPARENT STAIN: A stain containing dyes and/or semi-transparent pigments 

which are formulated to enhance wood grain and change surface color but not to conceal 

surface grain, and include sap stain and non-grain raising stains. Semitransparent stains with 

greater than one (1) pound of solids per gallon of coating shall be considered opaque stains.

242 SIMULATED WOOD MATERIALS: Materials, such as plastic, glass, metal, etc., that are 

made to give a wood-like appearance or are processed like a wood product.

243 STAIN: A semitransparent or opaque coating labeled and formulated to change the color of 

a surface, but not conceal the grain pattern or texture.

244 STENCIL COATING: An ink or a pigmented coating which is rolled or brushed onto a 

template or stamp in order to add identifying letters and/or numbers to wood products.

245 STRIPPER: A liquid used to remove cured coatings, cured inks, and/or cured adhesives.

246 SURFACE PREPARATION MATERIAL: A VOC-containing material applied to the surface 

of any wood product, prior to the application of coatings, to clean the wood product or to 

promote the adhesion of subsequent coatings.

247 TINT: A colorant added in small quantities to a stain to achieve a particular color for a 

finished product.

248 TONER: A wash coat which contains binders and dyes or pigments to add tint to a coated 

surface.

249 TOUCH-UP: A coating used to cover minor coating imperfections appearing after the main 

coating operation.
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 8 Placer County APCD

250 VOC COMPOSITE PARTIAL VAPOR PRESSURE: VOC composite partial vapor pressure 

for determination of compliance with Section 304 shall be calculated by the following 

equation:

Where: PPc = VOC composite partial pressure at 20o

C, in mm Hg

Wi = Weight of the "I"th VOC compound, in grams

Ww = Weight of water, in grams

We = Weight of exempt compounds, in grams

MWi = Molecular weight of the "I"th VOC compound, in (g/g-mole)

MWw = Molecular weight of water, in (g/g-mole)

MWe = Molecular weight of exempt compound, in (g/g-mole)

Vpi = Vapor pressure of the "I"th VOC compound at 20o

C, in mmHg

251 VOLATILE ORGANIC COMPOUND (VOC): Any chemical compound containing at least one

atom of carbon, except for the Exempt Compounds listed in Rule 102, DEFINITIONS.

252 VOC CONTENT:

252.1 Regulatory VOC Content: The weight of VOC per combined volume of VOC and 

coating solids, shall be calculated by the following equation:

Where: G1 = Weight of VOC per liter of coating, less water and less 

exempt compounds

Wv = Weight of all volatile compounds, in grams

Ww = Weight of water, in grams

Wec = Weight of exempt compounds, in grams

Vm = Volume of coating material, in liters

Vw = Volume of water, in liters

Vec = Volume of exempt compounds, in liters

252.2 Actual VOC Content: The weight (in grams) of VOC per liter of wood products 

coating material is expressed as grams VOC per liter of material, and shall be 

calculated using the following:

Where: GA = Weight of VOC per liter of total coating

Wv = Weight of all volatile compounds, in grams

Ww = Weight of water, in grams

Wec = Weight of exempt compounds, in grams

Vm = Volume of material, including any added VOC-containing

solvents or reducers but excluding any colorants added to tint 

the base, in liters

MW

i

+ WSUB

MW

W +

MW

W

(W )(VP )/ MW

PP =

i

n

e i=1

e

w

w

i i i

n

i=1 c

∑

∑

V -V -V

W -W -W G = m w ec

v w ec

1

v

(W W W ) G m

v w ec

A

− − =
October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -9 Rules and Regulations

253 WASH COAT: A coating, containing binders, which penetrates into and seals wood, 

prevents undesired staining, and seals in wood pitch. Washcoats with greater than one (1) 

pound of solids per gallon of coating shall be considered sealers.

254 WOOD PANEL: Any piece of wood, or wood composition, which is solid or laminated, and 

which is larger than 10 square feet in size, and which is not subsequently cut into smaller 

pieces.

255 WOOD PRODUCTS: Surface-coated objects such as cabinets (kitchen, bath and vanity), 

tables, chairs, beds, sofas, shutters, doors, trim, containers, tools, ladders, art objects, and 

any other objects made of solid wood and/or wood composition and/or of simulated wood 

material used in combination with solid wood or wood composition.

256 WOOD PRODUCT COATING APPLICATION OPERATIONS: A combination of coating 

application steps which may include use of spray guns, flash-off areas, spray booths, ovens, 

conveyors, and/or other equipment operated for the purpose of applying coating to wood 

products.

300 STANDARDS

301 APPLICATION EQUIPMENT REQUIREMENTS: A person subject to the provisions of this 

rule shall not apply any wood product coating to any wood products, unless one of the 

following application methods is used:

301.1 Hand application methods, such as brush or roller;

301.2 Roll coater;

301.3 Dip coat;

301.4 Flowcoat;

301.5 High Volume Low Pressure spray equipment;

301.6 Low Volume Low Pressure spray equipment;

301.7 Air assisted airless, for touch-up and repair only;

301.8 Electrostatic application equipment;

301.9 Any other equivalent method which has been approved in writing by the Air Pollution 

Control Officer.

302 LIMITS FOR VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS: Except as 

provided in Sections 103 and 305, no person shall apply any coatings to a new wood product, 

or use VOC-containing solvents, if such materials have a VOC content exceeding the 

applicable limits specified in the following table. The VOC content of coatings, except lowsolid stains, toners, washcoats and solvents, shall be determined in accordance with 

Sections 252.1 (VOC regulatory content) and 503.1. The VOC content of low-solid stains, 

toners washcoats and solvents, shall be determined in accordance with Sections 252.2 (VOC 

actual content) and 503.1. VOC limits expressed in grams VOC per liter of coating shall be 

used.
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 10 Placer County APCD

 LIMITS FOR VOC CONTENT OF COATINGS FOR NEW WOOD PRODUCTS

SPECIFIC MATERIAL

VOC LIMITS

VOC Regulatory Content, Grams VOC Per Liter of Coating 

Less Water and Exempt Compounds, as defined in 

Section 252.1 (lb/gal)

Clear Topcoats 275 (2.3)

Conversion Varnish 550* (4.6)

Filler 275 (2.3)

High-Solid Stain 350 (2.9)

Inks 500 (4.2)

Mold-Seal Coating 750 (6.2)

Multi-colored Coating 275 (2.3)

Pigmented Coating 275* (2.3)

Sealer 275* (2.3)

VOC LIMITS

VOC Actual Content, Grams VOC per Liter of Material, as 

defined in Section 252.2 (lb/gal)

Low Solid Stains, Toners and 

Washcoats 120 (1.0)

VOC LIMITS

VOC Actual Content, Grams VOC Per Liter of Material, as 

defined in Section 252.2 (lb/gal)

Surface Prep and Clean-up 

Solvents Containing VOC’s 25 (0.2)

* (See Section 211 for special conditions for Conversion Varnish)

302.1 Notwithstanding the VOC limits specified in this section, a person may apply a sealer 

with a VOC content not exceeding 680 grams/liter, provided that the topcoat used on 

the same wood product does not exceed 275 grams/liter.

303 LIMITS FOR VOC CONTENT OF COATINGS FOR REFINISHING, REPAIRING, 

PRESERVING, OR RESTORING WOOD PRODUCTS: Except as provided in Sections 103

and 305, no person shall apply any coatings to refinish, repair, preserve, or restore a wood 

product, or use VOC-containing solvents, if such materials have a VOC content exceeding 

the applicable limits specified in the following table. The VOC content of coatings, except lowsolid stains, toners, and washcoats, shall be determined in accordance with Sections 252.1

and 503.1. The VOC content of low-solid stains, toners and washcoats and VOC-containing 

solvents shall be determined in accordance with Sections 252.2 and 503.1. VOC limits 

expressed in grams per liter shall be used.
October 14, 2010 (Effective July 1, 2011)

Placer County APCD 236 -11 Rules and Regulations

LIMITS FOR VOC CONTENT OF COATINGS TO REFINISH, REPAIR, PRESERVE OR RESTORE

SPECIFIC MATERIAL VOC LIMITS

VOC Regulatory Content, Grams VOC Per 

Liter of Coating Less Water and Exempt 

Compounds, as defined in Section 252.1

(lb/gal)

Clear Topcoats 680 (5.7)

Conversion Varnish 550* (4.6)

Filler 500 (4.2)

High-Solid Stain 700 (5.9)

Inks 500 (4.2)

Mold-Seal Coating 750 (6.3)

Multi-colored Coating 680 (5.7)

Pigmented Coating 600* (5.0)

Sealer 680* (5.7)

VOC LIMIT

VOC Actual Content, Grams VOC Per Liter of 

Material, as defined in Section 252.2 (lb/gal)

Low Solid Stains, Toners and 

Washcoats

480 (4.0)

VOC LIMIT

VOC Actual Content, Grams VOC Per Liter of 

Material, as defined in Section 252.2 (lb/gal)

Surface Prep or Clean-up 

Solvents Containing VOC’s

25 (0.2)

* (See Section 211 for special conditions for Conversion Varnish)

304 LIMITS OF VOC CONTENT FOR STRIPPERS: A person shall not use a stripper on wood 

products unless:

304.1 The stripper contains less than 350 grams of VOC per liter of material; or

304.2 The VOC composite partial vapor pressure for the stripper is 2 mm Hg (0.04 psia) or 

less at 20o

C (68oF), as calculated pursuant to Section 250.

305 EMISSION CONTROL SYSTEM:

305.1 As an alternative, a person may comply with the VOC limits specified in Sections 

302, 303, and 304, by using an approved air pollution control system consisting of a 

capture system and a control device, which reduces VOC emissions from the 

application of wood products coatings or strippers by an equivalent or greater amount 

than the limits specified in Sections 302, 303, and 304, with the written approval of 
October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 236 - 12 Placer County APCD

the Air Pollution Control Officer. In order to achieve an equivalent or greater level of 

VOC reduction, the minimum allowable emission control system efficiency of such a 

system, when calculated pursuant to Section 217, shall be the efficiency calculated 

by the following equation:

)X100 (1-(VOC / D )

(1-(VOC /( D ) X

(VOC )

(VOC ) C.E.= 1-(

LWc c

LWn Max n Max

LWn Max

LWc , ,

,

Where: C.E. = Minimum allowable emission control system 

efficiency, percent

VOCLWc = VOC Limit of Rule 236, less water and less 

exempt compounds, pursuant to Sections 302, 

303, and/or 304

VOCLWn,Max = Maximum VOC content of non-compliant coating 

used in conjunction with a control device, less 

water and less exempt compounds

Dn,Max = Density of solvent, reducer, or thinner contained 

in the non-compliant coating, containing the 

maximum VOC content of the multi-component 

coating, g/L

Dc = Density of corresponding solvent, reducer, or 

thinner used in the compliant coating system (= 

880 g/L)

305.2 The capture system shall vent all drying oven exhaust to the control device and shall 

have one or more inlets for collection of fugitive emissions; and

305.3 During any period of operation of a thermal incinerator, combustion temperature shall 

be continuously monitored; and

305.4 During any period of operation of a catalytic incinerator, exhaust gas temperature 

shall be continuously monitored; and

305.5 Written approval for the use of such equipment is obtained from the Air Pollution 

Control Officer prior to installation or use of the equipment.

306 REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP MATERIALS: Any 

person subject to this rule shall comply with the following requirements:

306.1 Spray gun nozzles only, may be soaked in solvent-based materials for cleaning, 

provided the container (not to exceed five (5) gallons in size) is kept tightly covered at 

all times except when accessing the container.

306.2 Closed, non leaking, and non-absorbent containers shall be used for the disposal of 

cloth or paper used for surface preparation, cleanup, and coating removal.

306.3 VOC-containing materials shall be stored in containers, which are closed when not in 

use, and shall be disposed of in a manner that the VOC’s are not emitted into the 

atmosphere.

306.4 A person shall not use solvent-based VOC-containing materials for the cleanup of 

spray equipment used in wood products coating application operations, unless the 

spray equipment is disassembled and cleaned in an enclosed gun cleaner.
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Placer County APCD 236 -13 Rules and Regulations

306.5 A person shall not perform surface preparation or cleanup with a material containing 

VOC’s in excess of 25 grams per liter in accordance with VOC limit standards in 

Sections 302 and 303.

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF SPECIFICATION: No person shall require for use or specify the 

application of any coating subject to the provisions of this rule that does not meet the limits 

and requirements of this rule. The prohibition of this Section shall apply to all written or oral 

contracts under the terms of which any coating is to be applied to any wood product at any 

physical location within the District. 

402 PROHIBITION OF POSSESSION: No person shall possess any coating subject to the 

provisions of this rule that does not meet the limits and requirements of the rule.

403 PROHIBITION OF SALE OR MANUFACTURE:

403.1 No person shall manufacture, blend, repackage for sale, supply, sell, offer for sale, or 

distribute within the District, any coating with a VOC content in excess of the limits 

specified in Section 302 or 303 or 304. This shall apply to the sale of any noncompliant coating which will be applied at any physical location within the jurisdiction 

of the District.

403.2 The provision of Section 403.1 shall not apply to the application of coatings where 

either: (a) The product is used exclusively within a emission control systems as 

allowed in Section 305; or (b) For coatings for use outside of the District.

404 LABELING REQUIREMENTS, VOC CONTENT: Each container of any coating, surface 

preparation material, or cleanup material, or stripper manufactured shall display its maximum 

VOC content of the coating, as applied, and after any thinning as recommended by the 

manufacturer, or shall have this information provided in a product data sheet supplied with 

the container. VOC content shall be displayed as grams of VOC per liter of coating (less 

water and less exempt solvent, and excluding any colorant added to tint bases), surface 

preparation and cleanup material, or stripper. VOC content displayed may be calculated 

using product formulation data, or may be determined using the test method in Section 503.1. 

Alternatively, containers for strippers subject to the provisions of Section 304 may display 

only the partial vapor pressure.

405 OPERATION AND MAINTENANCE PLAN: A person using an emission control system 

pursuant to Section 305, as a means of alternate compliance with this rule, as provided in 

Sections 302, 303 and 304, must submit an Operation and Maintenance Plan for the 

emission control system to the Air Pollution Control Officer for approval. A person proposing 

to install a new emission control system as a means of alternate compliance with this rule 

shall submit in addition to an Operation and Maintenance Plan, an application for Authority to 

Construct, pursuant to Rule 501, GENERAL PERMIT REQUIREMENTS. The Plan shall 

specify operating and maintenance procedures which will demonstrate continuous operation 

of the emission control system during periods of emissions-producing operations. The Plan 

shall also specify which records must be kept to document these operating and maintenance 

procedures. These records shall comply with the requirements of Sections 501 and 502. The 

Plan shall be implemented upon approval of the Air Pollution Control Officer.

500 MONITORING AND RECORDS

501 RECORDKEEPING: In addition to any applicable record keeping requirements of either Rule 

502, NEW SOURCE REVIEW, Rule 507, FEDERAL OPERATING PERMIT PROGRAM, and 

Rule 511, POTENTIAL TO EMIT, or any other District rule which may be applicable, any 
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Rules and Regulations 236 - 14 Placer County APCD

person subject to this rule shall maintain the following records in order to evaluate 

compliance:

501.1 Product Data:

501.1.1 A data sheet, material list, or invoice giving material name, manufacturer 

identification, material application, and VOC content.

501.1.2 Any catalysts, reducers, or other components used, and the mix ratio.

501.1.3 The applicable VOC limit from Section 302 or 303 and the actual VOC 

content of the wood product coating as applied.

501.1.4 Name, description, container size and actual VOC content of any tints 

used to color stains for coating wood products.

501.2 Product Usage and Frequency:

501.2.1 For persons using coatings or materials which comply with the VOC 

limits specified in Sections 302, 303, and 304, records shall be 

maintained on a monthly basis, showing the type and volume of 

coatings, strippers and surface preparation and cleanup materials used. 

Coating type shall be designated according to the coating categories as 

listed in Sections 302, 303, and 304.

501.2.2 Persons using stains and/or tints and subject to this rule shall maintain 

records on a monthly basis that provide the following information as 

applicable:

Name, description, container size, and actual VOC content of 

any tints used to color stains.

Usage of any tint is limited to one pint of tint in any operating 

day. Records of any tint use shall be maintained on a monthly

basis and submitted to the District when requested.

501.2.3 If at any time a person uses coatings or materials exceeding the VOC 

limits specified in Sections 302, 303, and 304, records shall be 

maintained on a daily basis showing the type and volume of materials 

used.

501.2.4 For persons using tints to color stains, usage is limited to one pint or less 

in any operating day. Records of any tint use shall be maintained on a 

daily basis and submitted monthly to the Placer Air Pollution Control 

District.

501.3 Emission Control System:

501.3.1 A person using an emission control system as a means of alternate 

compliance pursuant to Section 305, shall maintain records on a monthly 

basis, showing the type and volume of coatings and solvents used.

501.3.2 A person using an emission control system as a means of alternate 

compliance with this rule pursuant to Section 305, shall maintain daily

records of key system operating and maintenance procedures which will 

demonstrate continuous operation and compliance of the emission 

control system during periods of emission-producing activities. Key 
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Placer County APCD 236 -15 Rules and Regulations

system operating parameters are those necessary to ensure compliance 

with the requirements of Section 305.

502 RETENTION OF RECORDS: All records required by this rule shall be retained for at least 

three years, except for sources subject to Rule 507, FEDERAL OPERATING PERMIT 

PROGRAM, which shall be retained for at least five years. Such records shall be made 

available to the Air Pollution Control Officer upon request.

503 TEST METHODS

503.1 Determination of VOC Content: VOC content, solids content, and water content of 

wood product coatings, strippers, and surface preparation and cleanup materials, 

subject to this rule, shall be determined in accordance with United States 

Environmental Protection Agency (U.S. EPA) Method 24 and Sections 252, 253 or 

254 of this rule, as applicable.

503.2 Determination of Composition of VOC: The composition of VOC shall be as specified 

on the manufacturer's label or data sheet, or as determined by ASTM Method E260-

96, “Standard Practice for Packed Column Gas Chromatograph”.

503.3 Determination of Compounds Exempt From VOC Definition: Exempt Compounds per 

Section 219 of this rule, and as defined in Rule 102, DEFINITIONS, shall be 

determined in accordance with ASTM D4457-85, “Standard Test Method for 

Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coatings 

by Direct Injection into a Gas Chromatograph”, or ARB Method 432. If any of the 

perfluorocarbons or volatile cyclic and linear methyl siloxanes are being claimed as 

exempt compounds, the person making the claim must state in advance which 

compounds are present, and the U.S. EPA-approved test method used to make the 

determination of these compounds.

503.4 Determination of Capture Efficiency: Efficiency of the capture system shall be 

determined in accordance with U.S. EPA “Guidelines for Determining Capture 

Efficiency, January 9, 1995”. Individual capture efficiency test runs subject to the U.S. 

EPA technical guidelines, calculated in accordance with Section 205, shall be 

determined by:

503.4.1 40 CFR 51, Appendix M, Methods 204-204F; or

503.4.2 The South Coast Air Quality Management District “Protocol for 

Determination of Volatile Organic Compound (VOC) Capture Efficiency”; 

or

503.4.3 Any other method approved by the U.S. EPA, the California Air 

Resources Board, and the Air Pollution Control Officer.

503.5 Determination of Control Device Efficiency: Efficiency of the emission control device 

shall be based upon test measurements made in accordance with (1) U.S. EPA 

Method 25 or 25A, for VOC concentration, and (2) U.S. EPA Method 2 or 2C for flow 

rates, as applicable, and calculated in accordance with Section 210. U.S. EPA 

Method 18 or CARB Method 422 “Determination of Volatile Organic Compounds in 

Emissions from Stationary Sources” may be used to determine emissions of exempt 

compounds.

503.6 Vapor Pressure: Vapor pressures may be obtained from standard reference texts or 

may be determined by ASTM D2879-97, “Standard Test Method for Vapor PressureTemperature Relationship and Initial Decomposition Temperature of Liquids by 

Isoteniscope”.
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Rules and Regulations 236 - 16 Placer County APCD

503.7 Volatile Content of Radiation Curable Materials: Volatile content of radiation curable 

materials shall be obtained in accordance with ASTM D5403-93, “Standard Test 

Methods for Volatile Content of Radiation Curable Materials”.

503.8 Multiple Test Methods: When more than one test method or a set of test methods is 

specified for any testing, a violation of any requirement of this rule established by any 

one of the specified test methods or set of test methods shall constitute a violation of 

this rule.