UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

F or EPA’s Direct Final Rulemaking

F or the California State Implementation Plan San Diego County Air Pollution Control District, Rule 6 7

. 11
, Wood Products Coating Operations

Prepared by: Adrianne Borgia
Reviewed by: Andrew Steckel

Febr uary, 2013- 2

-

Agency : San Diego County Air Pollution Control District (SDCAPCD)
Previously Submitted Rule : Rule 6 7. 11

– Wood Products Coating s Operation s Adopted and Effective

– March 14, 1989 Revised Effective

– August 13, 1997 Submitted

– May 18, 1998 EPA Withdrawn

– November 28 , 200 0 (6 5 FR 70795 )

Subject of this TSD : Rule 6 7. 11

– Wood Products Coating Operations Adopted

– June 27, 2012 Effective

– June 27, 2013 Submitted

– September 21, 2012

RULE SUMMARY

– SD C APCD Rule 67. 11
, Wood Products Coating Operations , is a rule that applies to all wood products excluding those coating operations subject to R ule 67.0, Architectural Coatings
, Rule 67.18, Marine Coating Operations and Rule 66.1, Miscellaneous Surface Coating Operations and Other Processes Emitting VOCs

. SDCAPCD regulates an ozone nonattainment subpart 1 area for the 8

- hour ozone national ambient air quality standard (NAAQS) 1 and SDCAPCD has designed Rule 6 7

. 11 partly to address the requirements for ozone non

- attainment areas as described in Clean Air Act (CAA) § 182. Both federal and state laws require the District to implement rules that regulate emissions of ozone precursors

– VOCs and o xides of nitrogen. Rule 6 7

. 11 serves to ensure ongoing compliance with Reasonably Available Control Technology (RACT) and State requirements to adopt all feasible measures applicable to the wood products coatings industry. The amendments to Rule 67.11 will reduce Volatile Organic Compound ( VOC ) emissions , principally by specifying more stringent VOC content limit s for coatings , stripping and cleaning materials

. Other means designed to reduc e VOC emissions are the use of specific coating application equipment including more clearly defined high transfer efficiency coating application equipment , the option of using control equipment and the usage recordkeeping requirements for coatings , stripping and surface preparation and cleaning materials to provide the VOC data necessary to evaluate compliance

. Rule 67.11 replaces Rule 67.11.1, Large Coating Operations for Wood Product, since these same large facilities are also subject to Rule 67.11. Consequently, Rule 67.11.1 has been simultan eously proposed for repeal.

1

. 40 CFR 81- 3

-

Significant rule changes include:
Minimal usage at a stationary source in subsection (b)(1)(ii) was reduced from 500 gallons to 20 gallons or any operation with 150 pounds or less VOC emissions in a 12

- month period.
Definitions of relevant and applicable terms are listed in section (c) of Rule 6 7

. 11

. Definitions for “Application Equipment ”
, “ Cleaning Material ” were added and the definitions for “Coating”, “Conversion Varnish”, “High

- Volume Low

- Pressure (HVLP) Spray”, “Stripping Material ” (formerly “ Stripper ” ), “ VOC Content Per Volume of Material ” and “ Wood Products ” were revised for clarification.
Section (d) itemiz es standards . The Coating Application Equipment in subsection (1) was changed to further define the HVLP spray gun usage requirements. In the VOC limits tables of subsection (2), several coatings category limits were lowered for the new wood products. These included f illers, high

- solid stains, multi

- colored coatings, and sealers. Low

- solids stains, toners and washcoats with limits in excess of 120 grams of VOC per liter are no longer allowed for new wood products and there is a new category for refinished wood products low

- solids coatings that cannot be categorized as stains, toners or washcoats with a limit of 480 grams per liter in subsection (3)

. A new category, conversion varnishes, with a VOC limit of 550 grams per liter, was also included in subsection (3). S ubsec tion (4) was added for surface preparation materials and the VOC limit for these is 25 grams per liter. In subsection (5), Stripping Materials, the minimum initial boiling point requirement has been eliminated and the required vapor pressure reduced from 2 0 mm Hg to 2 mm Hg at 20 o C . Finally, the option of using alternative cleaning equipment approved by the Air Pollution Control Officer (APCO) has been removed and the VOC limit of cleaning material was lowered from 200 grams per liter to 25 grams per liter in subsection (6).
The recordkeeping requirements of section (f) have been revised to include maintaining a current list of surface preparations materials’ VO C content. Finally, in section (g), Test Methods, several additional tests for determining VOC content and a new subsection for measuring exempt compound content have been included. The tests for measuring initial boiling points and solvent losses from alt ernative application cleaning equipment have been removed and the clause allowing the use of other test methods provided they are approved by the APCO, California Air Resources Board (CARB) or EPA has been added.- 4

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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 evaluate compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency

– We have compared Rule 67. 11 against previous Rule s 67. 11 and 67.11.1 ; Control Technique Guidelines (C TGs) titled, “Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations” (EPA

453/R

- 96

- 007, April 1996) and “Industrial Cleaning Solvents” ( EPA 453/ R

- 06

- 001
, September 2006 ) ; South Coast Air Quality Management District (SCAQMD) Rule 11 36
, Wood Products Coatings , a mended June 14, 1996 ; Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 4 63
, Wood Products Coatings , amended September 25, 2008 ; San Joaquin Unified Air Pollution Control District (SJUAPCD) Rule 4606, Wood Products and Flat Wood Paneling Products Coating amended October 16, 2008
, and other local rules for this category to help evaluate the RACT requirements of CAA §182(b)(2) and §182(f).

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 pro gress (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).

EPA EVALUATION

- T he following is EPA’s analysis of the rules ba sed on the evaluation criteria:

1. Enforceability

- In general, Rule 67. 11 is enforceable because it is clear and requires appropriate recordkeeping in section (f) and testing in section (g)

. Test methods have been updated to include the most current EPA methods as well as recent SCAQMD test methods that have been approved by EPA.

2. Stringency

– The submitted rule generally has more stringent emission limits than the 19 96 CTG
, “Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations” and the 2006 CTG, “Industrial- 5

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Cleaning Solvents” and is consistent with analogous current requirements in other areas, such as SMAQMD Rule 463 and SJUAPCD Rule 4606.

3. SIP Relaxation

– The VOC limits for fillers
, high

- solid stains, multi

- color coatings and sealers have been substantially reduced for new wood products and the limit for multi

- color coatings has been slightly reduced and a limit for a new category, any other low

- solids coat ings
, has been established for refinished wood products

. However, t he primary change to the rule is the reduction of the VOC limit for surface preparation and for the cleaning of application equipment from 200 grams per liter to 25 grams per liter

. In addition , the small usage exemption for coatings used at stationary sources was reduced from 500 gallons to 20 gallons in a consecutive 12

- month period. An exemption for the use of 20 gallons of non

compliant coating in a consecutive 12

- month period has al so been added but since the original exemption did not specify compliant or non

- compliant coating, this exemption is interpreted to be a clarification of the original exemption. Another small usage exemption was added for operations emitting 150 pounds or less in a consecutive 12

- month period. This can be compared to the 10 tons of one hazardous air pollutant or 25 tons per year of a combination of hazardous air pollutant limit in the National Emission Standards for Hazardous Air Pollutants (NESHAP). 2

In combination, SDCAPCD projects these revisions result in a 12% reduction of VOC emissions per year. 3
Therefore, we propose to determine that an approval of the submittal would comply with CAA sections 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 submitted SIP revisions are more stringent than the existing SIP requirements.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RU LE REVISION

– The following revisions are not currently the basis for rule disapproval, but are recommended for the next time the rule is amended: 1. Consider lowering the VOC limits for the following. The district rule with these lower limits is noted:
a. 240 grams per liter for High Solids Stains (SJVU APCD Rule 4606) b. 480 grams per liter for Low Solids Stains (SMAQMD 463)

2 . 40 CFR 63 subpart JJ

- Wood Fur n iture Manufacturing Operations 3 . SDAPCD Proposed Amendments to Rule 64.11

– “Wood Products Coating Operations”, Attachment B, “Socioeconomic Impact Assessment”.- 6

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2. Per the Guidance Document for Correc ting Com m on VOC & Other Rule Defici encies ( aka The Little Blue Book ), “Only those specific ASTM methods which appear in 40 CFR 60 are approved for use in SIPs.” We recommend using the following versions of the following ASTM standards:
a. ASTM D3792

– 79, 91 b. ASTM D4017

– 81,90, 96a
c. ASTM D4457

– 85,91

EPA ACTION

– The rule la rgely fulfills the relevant CAA §110 and Part D requirements. EPA staff recommends approval of Rule 67. 11 pursuant to CAA §110(k ) ( 3) and §301(a).

ATTACHMENTS

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1. SDAPCD Rule 67. 11
, Wood Products Coating s Operation s , Adopted and Effective March 14, 1989

. Revised Effective August 13, 1997. 2. SDAPCD Rule 67. 11
, Wood Products Coating Operations , Adopted June 27, 2012 and Effective June 27, 2013

.
ADDITIONAL REFERENCES

–
1. EPA’s Control Technique Guidelines (CTG) titled, Control of Volatile Organic Compound Emissions from Wood Furniture Manufacturing Operations (EPA

453/R

- 96

- 007, April 1996) http://www.epa.gov/airquality/ozonepollution/SIPToolkit/ctg_act/199604_voc_epa 453_r

- 96

- 007_wood_furniture_manufacturing.pdf 2. E PA’s Control Technique Guidelines (CTG) titled, “ Industrial Cleaning Solvents ” (EPA

- 453/R

- 06

- 00 1 ), September 2006 http://www.epa.gov/ttn/naaqs/ozone/ctg_act/200609_voc_epa453_r

- 06

- 001_ind_cleaning_solvents.pdf 3. “Issues Relating to VOC Regulation Cutpoints, Defici encies, and Deviations,” (a.k.a., Bluebook)
, EPA OAQPS, May 25, 1988

. http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf 4. “Guidance Document for Correcting Common VOC & Other Rule Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001. http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf