UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

For

EPA’s Direct Final Rulemaking

For the

California State Implementation Plan

San Diego County Air Pollution Control District, 

Rule 67.11, Wood Products Coating Operations

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

February, 2013
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Agency: San Diego County Air Pollution Control District (SDCAPCD)

Previously 

Submitted Rule: Rule 67.11 – Wood Products Coatings Operations

Adopted and Effective – March 14, 1989

Revised Effective – August 13, 1997

Submitted – May 18, 1998

EPA Withdrawn – November 28, 2000 (65 FR 70795)

Subject of this TSD: Rule 67.11 – Wood Products Coating Operations

Adopted – June 27, 2012

Effective – June 27, 2013

Submitted – September 21, 2012

RULE SUMMARY – SDCAPCD Rule 67.11, Wood Products Coating Operations, is a 

rule that applies to all wood products excluding those coating operations subject to Rule 

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)1and SDCAPCD has designed Rule 

67.11 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 oxides of 

nitrogen. Rule 67.11 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 limits for coatings, stripping and cleaning materials. Other means 

designed to reduce 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 simultaneously 

proposed for repeal. 

 

1. 40 CFR 81
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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 67.11.

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) itemizes 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 fillers, 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). Subsection (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 20 mm Hg to 2 mm Hg at 20oC. 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’ VOC 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 alternative 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. 
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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 Rules 67.11 and 

67.11.1; Control Technique Guidelines (CTGs) titled, “Control of Volatile Organic 

Compound Emissions from Wood Furniture Manufacturing Operations” (EPA453/R-96-007, April 1996) and “Industrial Cleaning Solvents” (EPA 453/R-06-001, 

September 2006); South Coast Air Quality Management District (SCAQMD) Rule 

1136, Wood Products Coatings, amended June 14, 1996; Sacramento 

Metropolitan Air Quality Management District (SMAQMD) Rule 463, 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 

progress (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 - The following is EPA’s analysis of the rules based 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 1996 CTG, “Control of Volatile Organic Compound Emissions from 

Wood Furniture Manufacturing Operations” and the 2006 CTG, “Industrial 
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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 coatings, has been established for refinished wood products. 

However, the 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 noncompliant coating in a consecutive 12-month period has also 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 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. 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 (SJVUAPCD Rule 4606)

b. 480 grams per liter for Low Solids Stains (SMAQMD 463)

 

2. 40 CFR 63 subpart JJ - Wood Furniture Manufacturing Operations 

3. SDAPCD Proposed Amendments to Rule 64.11 – “Wood Products Coating Operations”, Attachment B, 

“Socioeconomic Impact Assessment”.
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2. Per the Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies (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 largely 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 -

1. SDAPCD Rule 67.11, Wood Products Coatings Operations, 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 (EPA453/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. EPA’s Control Technique Guidelines (CTG) titled, “Industrial Cleaning Solvents” 

(EPA-453/R-06-001), 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, Deficiencies, 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