February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 1 Rules and Regulations 

### RULE 238 FACTORY COATING OF FLAT WOOD PANELING

Adopted 11

- 03

- 94

(Amended 2

- 09

- 95, 6

- 08

- 95, 8

- 14

- 97, 02

- 18

- 04 )

, 10

- 14

- 10 [Effective 7

- 1

- 11] )

CONTENTS

100 GENERAL

101 PURPOSE

102 APPLICABILITY

103 EXEMPTIONS

200 DEFINITIONS

201 ADHESIVE

202 CAPTURE EFFICIENCY

203 COATING

204 CONTROL DEVICE EFFICIENCY

205 DIP COATER

206 ELECTROSTATIC SPRAY APPLICATION

207 EMISSION CONTROL SYSTEM

206 208 EXEMPT COMPOUNDS

207 209 FLATWOOD PANELING

208 210 FLOW COATER

211 HAND APPLICATION METHODS

212 HARDBOARD

209 213 HARDWOOD PLYWOOD

210 214 HIGH VOLUME, LOW PRESSURE (HVLP) SPRAY EQUIPMENT

215 INK

211 216 LOW SOLIDS COATING

212 217 NATURAL FINISH HARDWOOD PLYWOOD PANELS

213 218 NON

- HEAT

- SET INK

214 219 PANEL

215 220 PRINTED INTERIOR PANELS

216 221 ROLL COATER

2 22 SEMI

- TRANSPARENT STAIN

2 23 SIMULATED WOOD MATERIALS

2 24 STAIN

2 25 THIN PARTICLEBOARD

217 2 26 TILEBOARD

218 22 7 TINT

2 28 VOC CONTENT PER LITER OF COATING, LESS WATER AND EXEMPT COMPOUNDS

219 VOC CONTENT FOR LOW SOLIDS COATINGS

220 2 29 VOLATILE ORGANIC COMPOUND (VOC)

221 2 3 0 WOOD FLAT STOCK

300 STANDARDS

301 GENERAL REQUIREMENTS

302 APPLICATION EQUIPMENT REQUIREMENTS

303 CLEANUP AND STORAGE PROCEDURES

400 ADMINISTRATIVE REQUIREMENTS

401 OPERATION AND MAINTENANCE PLANFebruary 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 2 Placer County APCD 500 MONITORING AND RECORDS

501 COATING LIST

502 RECORDKEEPING

503 RECORDKEEPING OF STAINS AND TINTS

504 EMISSION CONTROL SYSTEM RECORDS

504 505 RETENTION OF RECORDS

505 506 TEST METHODSFebruary 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 3 Rules and Regulations This Page Intentionally Left BlankFebruary 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 4 Placer County APCD 100 GENERAL

101 PURPOSE: The purpose of this Rule is to limit the emission of volatile organic compounds

(VOC) from the factory application of coatings and inks to flatwood paneling as defined in

Section 207 209 , and to woo d flat stock, as defined in Section 221 23 0

.

102 APPLICABILITY:

102.1 Geographic: The provisions of this rule apply only to facilities located in the

Sacramento Valley Air Basin portion of Placer County, as defined by California Code

of Regulations, Title 17, Division 3, Chapter 1, Subchapter 1.5, Article 1, Section

60106.

102.2 102. 1 Business Category: The provisions of this rule shall apply to any person who

applies in a shop or factory facility, coatings or inks used to coat any products defined

i n Section 207 209 or 221 231 , or who manufactures, blends, sells, repac kages,

distributes

, or specifies

, such coatings and inks

. Standard Industrial Code (SIC)

classifications covering these coating processes are 2431, 2435, 2436, 2492 and

2499.

103 EXEMPT IONS:

103.1 Exemption, Furniture

, and Cabinet Components: Surface coating of wood

flat wood stock intended to be used as a furniture or cabinet component component s

, is subject to Rule 236, Wood Products Coating Operations WOOD PRODUCTS

COATING OPERATIONS , and is exempt from all provisions of this rule.

103.2 Exemption, Non

- Shop Architectural Coatings: The coating of stationary structures

and their appurtenances in a non

- shop operation is subject to Rule 218, Architectural

Coatings ARCHITECTURAL COATINGS , and is exempt from all provisions of this

rule.

103.3 Exemption, Adhesives: The use of adhesives to manufacture fla twood panels or

wood flat stock

, is subject to Rule 235, Adhesives ADHESIVES

, and is exempt from

all provisions of this rule.

10 3.4 Exemption From Requirements of Other District Rules: Any coating, ink or cleanup

material

, which contains compounds that are subject to the VOC provisions of this

rule, is exempt from the provisions of Rule 219, Organic Solvents ORGANIC

SOLVENTS

.

103. 5 Exemption

- , Residential, Non

- Commercial Operations: Residential, non

- commercial

flatwood coating operations are exempt from all provisions of this rule.

103.6 Partial Exemption, Low Volume: Businesses using less than 55 gallons per year or o f

coatings, inks and VOC

- containing cleanup solvents or strippers, ( singly sing ularly or

in combination) are exempt from the provisions of this rule, except for

Recordkeeping, Section 502.

103.7 Exemption, Aerosol Spray Coatings

, for Touch

- Up: Aerosol

- spr ay coatings for touch

up and repair are exempt from all provisions of this rule.

103.8 103.8 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

record keeping

. Records shall be maintained and reported as specified in Section

503.February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 5 Rules and Regulations 103 .9 Exemption

, Other: The application of coatings by template in order to add designs,

letters, or numbers to wood products, is exempt from all provisions of this rule.

200 DEFINITIONS

201 ADHESIVE: Any substance that is applied for the primary purpose of bonding surfaces

together.

202 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 flatwood paneling coating operations, both measured simultaneously in accordance with

Se ction 505 subs ection 506 .2 , and can be calculated by the following equation:

W

c Capture Efficiency

= ------- X 100

W

e

Where: W

c = Weight of VOC entering the control device

W

e = Weight of VOC discharged from the coating operations

203 COATING: Any coating applied on any flatwood paneling or wood flat stock including but not

limited to water repellant preservative, semitransparent stains, opaque stains, Filler f iller , or

clear top coat.

204 CONTROL DEVICE EFFICIENCY: Expressed in percent, cont rol 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 accordan ce with Section 505 subs ection 506 .3 , and

can be calculated by the following equation:

(W

c - W

a )

Control Device Efficiency

= -------------- X 100

W

c

Where: W

c = Weight of VOC entering the control device

W

a = Weight of VOC discharged from the control device

205 205 DIP COATER: T o dip an object into a vat of coating material and drain off any excess

coating

.

2 06 ELECTROSTATIC SPRAY APPLICATION: Any method of spray application of coatings

where an electrostatic attraction is created between the part to be coated and the paint

particles.

207 EMISSION CONTROL SYSTEM: A system for reducing emissions of VOC from flatwood

pan eling coating operation s. It consists of (1) a capture device or system which collects all

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

emis sion of VOC to the atmosphere. The individual efficiencies are calculated in accordance

with Sections 202 and 204.

The overall efficiency of the emission control system is calculated by the following equation:

Capture Efficiency ,% X Control Device Efficiency ,%

Overall Efficiency ,% = ----------------------------------------------------------------------------

100February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 6 Placer County APCD 206 208 EXEMPT COMPOUNDS: For the purposes of this rule, exempt compounds are as

defined in Rule 102, Definitio ns DEFINITIONS

.

207 209 FLATWOOD PANELING: Printed interior panels made of hardwood plywood and thin

particle board, natural finish hardwood plywood, hardwood paneling, baseboard, wood flat

stock, veneers, doors, door skins, wood flat product skins, tilebo ard and wallboard.

208 2 10 FLOW COATER: T o coat an object by flowing a stream of coating over an object and

draining off any excess coating.

2 11 HAND APPLICATION METHODS: T he application of coatings, sealants, or adhesives by

manually held, non

- mechanically

- operated equipment. Such equipment includes paint

brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, rags, and sponges.

21 2 HARDBOARD: A panel manufactured primarily from inter

- felted ligno

- cellulosic fibers which

are consolidated under heat and pressure in a hot press.

209 21 3 HARDWOOD PLYWOOD: Plywood whose surface layer is a veneer of hardwood.

210 21 4 HIGH VOLUME, LOW PRESSURE (HVLP) SPRAY EQUIPMENT: Spray equipment

used to apply coatings by means of a gun which is designed to be operated and which is

operated between 0.1 and 10 pounds per square inch, gauge , (psig) air atomized pressure,

measured dynamically at the center of the air cap and at the a ir horns.

21 5 INK: Any fluid or viscous composition used in printing impressing or transferring an image

onto a panel.

211 21 6 LOW SOLIDS COATING: A coating or ink containing 120 grams or less of solids per

liter (1.0 pounds or less of solids per gallon) of coating material.

212 21 7 NATURAL FINISH HARDWOOD PLYWOOD PANELS: Panels whose original grain

pattern is enhanced by essentially transparent finishes frequently supplemented by fillers and

toners.

213 21 8 NON

- HEAT

- SET INK: An ink which dries by oxidation and absorption into the substrate

without the use of heat from dryers or ovens.

214 21 9 PANEL: A flat piece of wood or wood product usually rectangular and used inside

homes and mobile homes for wall decorations.

215 2 20 PRINTED INTERIOR PANELS: Panels whose grain or natural surface is obscured by

fil lers and basecoats upon which a simulated grain or decorative pattern is printed.

216 2 21 ROLL COATER: A series of mechanical rollers that forms a thin coating film on the

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

roller.

22 2 SEMI

- TRANSPARENT 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

. Semi

- transparent stains

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

stains.

22 3 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.

22 4 STAIN: A semitransparent or opaque coating labeled and formulated to change the color of

a surface, but not conceal the grain pattern or texture.February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 7 Rules and Regulations 22 5 THIN PARTICLEBOARD: A manufactured board 1/4 inch or less in thickness made of

individual wood particles which have been coated with a binder and formed into flat sheets by

pressure.

217 22 6 TILEBOARD: Paneling that has a colored waterproof surface coating.

218 22 7 TINT: A colorant added in small quantities to a stain to achieve a particular color for a

finished product.

22 8 VOC CONTENT PER LITER OF COATING, LESS WATER AND EXEMPT COMPOUNDS :

228.1 R egulatory VOC Content : The weight of VOC per combined volume of VOC and

coating solid s, measured in accordance with Section 505 subs ection 506 .1, and

calculated by the following equation:



### W

v 

### - W

w 

### - W

ec



### G 1 

### =

--------------------------------- 

### V

m 

### - V

w 

### - V

ec

Where: G 1 = Weight of VOC in grams per liter of coating, less

water and exempt compounds

. W

v = Weight of volatile compounds, in grams

. W

w = Weight of water, in grams

. W

e c = Weigh t of exempt compounds, in grams

. V

m = Volume of coating material, in liters

. V

w = Volume of water, in liters

. V

ec = Volume of exempt compounds, in liters

.

(To convert G 1 to pounds per gallon, multiply by

0.008345)

219 22 8.2 Actual VOC CONTENT FOR LOW SOLIDS COATINGS Content : The weight of

VOC in grams, per liter of low solids coating total materia l, measured in accordance

with Section 505 subs ection 506 .1, and calculated by the following equation :



### W

v 

### - W

w 

### - W

ec



### G L 

### =

--------------------------------- 

### V

m

Where: 

### G L = Weight of VOC per liter of low solids coating

material, less water and exempt compounds

. W

v = Weight of volatile compounds, in grams

. W

w = Weight of water, in grams

. W

ec = Weigh t of exempt compounds, in grams

. V

m = Volume of coating material, in liters

.

(To convert G L to pounds per gallon, multiply by 0.008345)

220 2 29 VOLATILE ORGANIC COMPOUND (VOC): Any chemical compound containing at least

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

Definitions DEFINITIONS

.

221 2 3 0 WOOD FLAT STOCK: Interior panels containing wood including but not limited to

redwood stocks, plywood panel s, particle boards, composition hardboards, and any other

panels containing solid wood or wood product.February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 8 Placer County APCD 300 STANDARDS

301 GENERAL REQUIREMENTS: Any person applying coatings or inks to flatwood paneling

products subject to this rule shall comply with either of the following requirements listed in

Sections subs ections 301.1 and or 301.2:

301.1 Coating Materials and Inks

- Use only coatings : C oatings and inks shall only be used

that comply with the following VOC Limits:

Coating Materials

and Inks Maximum Allowabl e VOC content,

as applied

All coatings and inks except

for Low Solids l ow s olids

coatings and inks (below). 250 grams or less of VOC per liter (2.1

pounds VOC per gallon) less water and

exempt compounds, as calculated in

accordance with Section 218 228 .1

(Regulatory VOC Content)

Low Solids s olids coatings

and inks 120 grams or less of VOC per liter (1.0

pounds V OC per gallon) of material as

calculated in accordance with Section

219 22 8.2 (Actual VOC Content)

OR

301.2 Install and operate on the line(s), an Emission Control System e mission c ontrol

s ystem as defined in Section 205 207 , that operates at an overall efficiency of at least

90 95 %, as calculated in accordance with Section 205 20 7 , and that has been

approved pursuant to Section 401.

302 APPLICATION EQUIPMENT REQUIREMENTS: A person or facility shall not apply coatings

to wood products subject to the provisions of this rule unless the coating is applied with

properly operating equipment, in accordance with proper operating procedures, and by the

use of one of the following methods:

302.1 Electrostatic application ;

302.2 High volume, low pressure (HVLP) spray ;

302.3 Hand ro ller ;

302.4 Flow coat ;

302.5 Roll coater ;

302.6 Dip coat ;

302.7 Paint brush ;

302.8 Detailing or touch

- - up guns

.

303 CLEANUP AND STORAGE PROCEDURES: Any person or facility using VOC

- containing

solvents for cleanup or related uses shall observe the following procedures:February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 9 Rules and Regulations 303.1 All solvent, including waste solvent and waste solvent residues, shall be stored in

closed , non

- absorbant, non

- leaking, contai ners at all times

. Each container shall

have a label indicating the name of the solvent or material it contains.

303.2 If recovery of waste solvent by distillation is performed, solvent residues shall not

contain more than 10 percent solvent by volume after distillation.

303.3 Solvents shall not be used for the cleanup of spray equipment including paint lines

unless an enclosed system or other system, that has been approved in writing for use

by the Air Pollution Control Officer or submitted to and approved by the California Air

Resources Board, is used for cleanup. The system must enclose spray guns, cups,

nozzles, bowls, and other parts during washing, rinsing, and draining procedures.

Equipment used shall minimize the evaporation of organic compounds to the

atmosphere

. Spray equipment may be cleaned without the use of an enclosed

system if cleaning solutions are used that do not contain VOCs.

30 3

. 4 Spillage of VOC

- containing materials shall be minimized

. Spills shall be cleaned u p

immediately.

30 3

. 5 VOC

- containing materials shall be stored and disposed of in closed containers

. Storage and disposal containers must be kept closed, except when depositing or

removing the materials

. Disposal shall be conducted in a manner that the VOC are

not emitted to the atmosphere.

30 3

. 6 VOC

- containing materials shall be conveyed in closed containers or pipes.

30 3

. 7 Mixing vessels for VOC

- containing materials must be closed except when in use.

30 3

. 8 VOC emissions shall be minimized during cleani ng of storage, mixing, and conveying

equipment.

400 ADMINISTRATIVE REQUIREMENTS

401 OPERATION AND MAINTENANCE PLAN: A person using an existing emission control

system as a means of compliance with this rule, pursuant to Section 301.2, shall submit an

Operation and Maintenance Plan for the emission control system to the Air Pollution Control

Officer for approval

. A pe rson proposing to install a new emission control system as a means

of compliance with this rule, shall submit in addition to an Operation and Maintenance Plan,

an application for an Authority to Construct, pursuant to Rule 501, General Permit

Requirements. 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 shall be kept to document these operating and maintenance procedures

. These

records shall comply with the requirements of Sections 503 Section 500 . The Plan shall be

implemented upon approval of the Air Pollution Control Officer.

500 MONITORING AND RECORD S

501 COATING LIST: Any person subject to Section 301 shall maintain at the facility, a current list

of coatings and inks in use, which includes all of the data necessary to evaluate compliance

with the standards of this rule.

502 RECORDKEEPING: Any per son subject to this Rule shall maintain records on a

daily monthly basis that provide the following information as applicable:

502.1 Coating types an d mix ratios of components used ;February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 10 Placer County APCD 502.2 Quantity of each coating applied ;

502.3 Description of substrate(s) coated ;

502.4 Oven or cure temperature, if applicable ;

502.5 Type and amount of solvent used for cleanup and surface preparation

.

503

503 RECORDKEEPING FOR STAINS AND TINTS: In addition to the requirements in Section

502, any person subjec t to this rule shall maintain records on a monthly basis that provide the

following information as applicable:

503.1 Name, d escription, container size and a ctual VOC cont ent of any tints used to color

stains for fa ctory coating of wood products.

503.2 For persons using tints to color stains, usage is limi ted to one pint of tint in any

operating day. Records of any tint use shall be m aintained on a monthly basis and

submitted to the Placer Air Pollution Control District when requested

.

50 4 EMISSION CONTROL SYSTEM RECORDS: A person using an emission control system as

a means of compliance with this rule pursuant to Section 301.2, shall maintain daily records

of key system operating and maintenance procedures which will demonstrate continuous

operatio n and compliance of the emission control system during periods of emission

producing activities. Key system operating parameters are those necessary to ensure

compliance with the requirements of Section 301.2.

504 505 RETENTION OF RECORDS: All records maintained pursuant to this rule shall be

retained for at least three years from date of entry, with the exception of sources subject to

the requirements of Rule 507, Federal Operating Permit Program

. FEDERAL OPERATING

PERMIT PROGRAM

. These sources shall retai n records at least five years. Records shall

be made available for inspection by the Air Pollution Control Officer upon request.

505 50 6 TEST METHODS :

505 50 6 .1 Determination of VOC Content: VOC content

, solids content and water content

of flatwood paneling coatings shall be determined in accordance with United States

Environmental Protection Agency (U.S. EPA) Method 24 or U.S. EPA Method 24A

and Sections 218, 219 and 220 of this rule S ection 228

.

505 506 .2 Determination of Captur e Efficiency: Efficiency of the capture system, calculated

in accordance with Section 202, shall be based upon test measurements made in

accordance with U.S. EPA “Guidelines for Determining Capture Efficiency, January 9,

1995"

. Individual capture efficie ncy test runs subject to the U.S. EPA technical

guidelines shall be determined by:

505 50 6 .2.1 Applicable U.S. EPA methods 40 CFR 51, Appendix M, Methods

204 , 204A, 204B, 204C, 204E, and/or

- 204F; or

505 506 .2.2 The South Coast Air Quality Management District “Protocol for

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

or

505 506 .2.3 Any other method approved by U.S. EPA, the California Air

Resources Board, and the Air Pollution Control Officer.February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Placer County APCD 238

- 11 Rules and Regulations 505 506 .3 Determination of Contro l Device Efficiency: Efficiency of the emissions control

device, calculated in accordance with Section 204, shall be based upon test

measurements made in accordance with (1) U.S. EPA Method 18, 25

, or 25A, for

VOC concentration, and (2) U.S. EPA Method 2 or 2C for flow rates, as applicable

. 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.

50 6

. 4 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.February 18, 2004

October 14, 2010 (Effective July 1, 2011)

Rules and Regulations 238

- 12 Placer County APCD This page intentionally left blank