SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses October 16, 2008 

A - 1 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4606

APPENDIX A 

COMMENTS AND RESPONSES FOR RULES 4603 AND 4606 

October 16, 2008 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses October 16, 2008 

A - 2 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4606

SUMMARY OF SIGNIFICANT COMMENTS ON SEPTEMBER 18, 2008 VERSION OF 

PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4606 

AND DISTRICT STAFF’S RESPONSES 

EPA Comments 

EPA has reviewed proposed Rules 4603 and 4606 and has no comments at this time. 

ARB Comments on Rule 4603 

1. Comment: From our discussion with District staff, we understand that the purpose 

of the current rule amendments is to make the rule consistent with the U.S. EPA 

requirements for RACT and RACM. Given the District’s nonattainment of the State 

ozone and PM air quality standards, we recommend that the District consider All 

Feasible Measures that have been successfully implemented elsewhere. 

Specifically, the district should lower the VOC limit for general air-dried coatings 

from 340 grams per liter (g/L) specified in Section 5.1.2 to 275 g/L. The VOC limits 

in Table 1 for Extreme High Gloss (Air Dried) should be changed from 420 g/L to 

340 g/L and Extreme Performance (Baked) should be changed from 420 g/L to 360 

g/L. (ARB) 

Response: Although SCAQMD Rule 1107 has lower VOC limits on the coating 

categories mentioned by ARB and EPA, it should be noted that Rule 1107 has 

many exemptions than Rule 4603. Without a thorough analysis of the potential 

emissions generated by Rule 1107 exemptions, it is difficult to conclude that Rule 

1107 is overall more stringent simply because three coating categories have 

slightly lower limits than Rule 4603. District staff will consider ARB’s comments 

when the rule is reopened in the future. 

ARB Comment on Rule 4606 

2. Comment: Section 5.0, Table 1, VOC Content Limits: The VOC limit for Sanding 

Sealer is 275 g/l. Ventura County Air Pollution Control District (VCAPCD) Rule 74-

30, Section (B)(1), has a limit of 240 g/l for this category. We recommend that the 

District include this lower limit in the rule. 

Response: Ventura’s Rule 74-30 has a limit of 240 grams/liter for new wood 

products and 680 grams/liter for refinishing operation. Although refinishing is 

exempt by Rule 4606, based on a review of the District’s Permit to Operate 

database, there are only two permitted wood coating facilities that perform wood 

coating refinishing operations that emit a total of one ton/year of VOC. The 

emissions generated by Ventura’s 680 grams/liter limit for refinishing coatings may 

actually be higher (depending on the number of facilities) than the emissions from 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses October 16, 2008 

A - 3 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4606

the 275 grams/liter limit in Rule 4606. Staff believes that overall Rule 4606 is as 

stringent as Rule 74-30.

3. Comment: The VOC limit for strippers is 350 g/l. San Diego County Air Pollution 

Control District Rule 67-11, Section (d)(5)(i), has a limit of 200 g/l for strippers. We 

recommend that the District include this lower limit in the rule. 

Response: San Diego County Rule 67-11 allows the use of stripper that has 200 

grams/liter, or has an initial boiling point (IBP) of 190oC (374o

F) or greater, or has a 

total vapor pressure (VP) of 20 mmHg or less at 68o

F. It is important to mention 

that even though a material has a low IBP or low VP such that it evaporates slowly, 

it may have a high VOC content that results to higher emissions after a period of 

time. For example, stoddard solvent (mineral spirit) has a low VP (about 3.1 mm 

Hg) but it is 100% volatiles by volume, and therefore the emissions would be 

greater than the emissions that would result from Rule 4606 stripper VOC limit of 

350 grams/liter. Staff believes that overall the stripper VOC limit of Rule 4606 is as 

stringent as Rule 67-11 that allows three compliance options mentioned above. 

4. Comment: Section 5.4.3 requires the overall capture and control efficiency to be 

at least 85% by weight. VCAPCD Rule 74-30 Section (B)(6)(a) has an overall 

capture and control efficiency of at least 90% by weight. We recommend that the 

District include this higher efficiency in the rule. 

Response: Currently, there are no existing permitted wood coating operations in 

the District that operate a VOC emission control system so changing the control 

efficiency at this time would not result in any emissions reduction. New or modified 

wood coating operations that elect to install and operate a VOC emission control 

system would be subject to District rule 2201 (New and Modified Stationary Source 

Review Rule) and would be evaluated for Best Available Control Technology 

(BACT) and Offset requirements. BACT type VOC emission control system would 

require at least 90% overall capture and control efficiency. Staff will consider 

increasing the control efficiency when the rule is reopened for future amendments. 

5. Comment: Section 5.7.2 limits the VOC content of strippable booth coating to 450 

g/l. This requirement would fit better in Section 5.1. We recommend moving this 

limit to Section 5.1. 

Response: District staff previously responded to similar ARB comment that the 

strippable booth coating is part of the solvent cleaning provisions of the rule to 

minimize VOC emissions. Such coating is applied on the surface of interior walls 

and floors of paint booth for protection from overspray during products coating 

operations, which later on can be peeled off instead of cleaning with organic 

solvents. Relocating the strippable booth coating limit in Section 5.1 that pertains 

to wood coatings VOC limits would imply that strippable booth coating is used on 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix A: Comments and Responses October 16, 2008 

A - 4 Final Staff Report with Appendices for 

 Proposed Amendments to Rule 4603 and Rule 4606

wood products which is not the case. Therefore, the existing provision will remain 

in its current location in the rule. 

Stakeholders’ Comments 

No comments were received from stakeholders. 

 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-1 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

APPENDIX B 

RULE CONSISTENCY ANALYSIS 

FOR PROPOSED AMENDMENTS TO RULE 4603 AND RULE 4606 

October 16, 2008
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-2 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

RULE CONSISTENCY ANALYSIS 

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Prior to adopting, amending, or repealing a rule or regulation, California Health and 

Safety Code Section 40727.2 requires that District staff perform a written analysis that 

identifies and compares the air pollution control elements of the proposed rule with the 

corresponding elements of existing or proposed District and United States 

Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to 

the affected source category. The elements that were analyzed are emission limits; 

work practices; monitoring and testing; and recordkeeping and reporting requirements. 

The analysis is detailed in Section II of this report. Conclusions based on the analysis 

are shown in Section III. 

II. RULE CONSISTENCY ANALYSIS 

District staff reviewed EPA rules, regulations, and guidelines, as well as District rules for 

the source categories covered by Rule 4603 and Rule 4606. The analysis was confined 

to those provisions that incorporate the standards established in EPA’s CTGs for large 

appliance coating operations, metal furniture coating operations, and flat wood paneling 

products coating operations. Existing coatings VOC limits, operating parameters, 

monitoring, testing, records, and reporting requirements from coating operations other 

than those that affect the implementation of the CTG standards were not analyzed for 

purposes of the rule consistency analysis. 

A. Existing or Proposed District Rules 

The following existing District prohibitory rules also apply to Rule 4603 (Surface Coating 

of Metal Parts and Products) and Rule 4606 (Wood Coating Operations): 

Rule 1020 (Definitions) 

Rule 1020 applies to sources subject to Rule 4603 and Rule 4606 only because the 

definition of VOC is referred to the definition that is indicated in Rule 1020. District staff 

is not proposing any change to the existing definition of VOC so there is no impact on 

the proposed amendments to the rules. 

Rule 2020 (Exemptions) 

Rule 2020 Section 6.8.2 provides operators some exemption from obtaining a District 

Permit to Operate (PTO) for certain surface coating operations. Specifically, Section 

6.8.2 exempts from PTO surface coating operations, except powder coating 

operations), which use less than one quart of coating per day or less than eight gallons 

of coating per year. Powder coating operations that use less than five pounds of 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-3 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

coating material per day or less than 50 pounds of material per year is exempt from 

PTO. 

Rule 2201 (New or Modified Stationary Source Review) 

Rule 2201 applies to permitting of new or modified stationary sources of air pollution. It 

provides the review new or modified stationary sources of air pollution and establishes 

the mechanisms including emission trade-offs by which Authorities to Construct such 

sources may be granted without interfering with the attainment or maintenance of 

Ambient Air Quality standards. It also requires no net increase in emissions above 

specified thresholds from new or modified stationary sources of all nonattainment 

pollutants and their precursors. In addition it establishes the requirements that trigger 

the need to install and operate Best Available Control Technology (BACT) and emission 

offsets. The proposed changes to Rule 4603 and 4606 do not change the existing 

requirements of Rule 2201. As discussed in Section IIIC of the Final Draft Staff Report 

metal furniture coating operation sources that are likely subject to the proposed 

changes to Rule 4603 are already using coatings that meet the proposed VOC limits. In 

addition, there is no flat wood product coating operation in the District, therefore the 

proposed changes to Rule 4606 does not affect the requirements of Rule 2201. 

B. Existing or Proposed Federal Rules, Regulations, and Guidelines

1. Control Techniques Guidelines (CTGs) 

CTG for Large Appliance Coatings (EPA 453/R-07-004) and CTG for Metal Furniture 

Coatings (EPA 453/R-07-005) 

EPA finalized the above CTGs in September 2007. The standards established by these 

CTGs are summarized in Sections IIIA and IIIC of the Final Draft Staff Report. Since 

the purpose of the rulemaking project is to incorporate the standards of the CTGs, the 

proposed changes to Rule 4603 are identical to the CTGs’ applicability threshold, 

coating VOC limits, add-on control equipment emission control efficiency, and work 

practice standards. 

CTG for Flat Wood Paneling Coatings (EPA 453/R-06-004) 

EPA finalized the above CTG in September 2006. The standards established by this 

CTG are summarized in Section IIID of the Final Draft Staff Report. Since the purpose 

of the rulemaking project is to incorporate the standards of the CTG, the proposed 

changes to Rule 4603 are identical to the CTG’s applicability threshold, coating VOC 

limits, add-on control equipment emission control efficiency, and work practice 

standards. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-4 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

2. New Source Performance Standards (NSPS)

NSPS requirements are organized by source category in 40 Code of Federal Regulation 

(CFR) Part 60. Since EPA has delegated the authority to implement NSPS 

requirements to the District, all NSPS promulgated by EPA have been incorporated by 

reference into District Rule 4001 (New Source Performance Standards). Rule 4001 lists 

71 NSPS which apply to a variety of source categories. 

District staff analyzed two NSPSs that are relevant to the proposed amendments to 

Rule 4603 to incorporate the CTG standards for metal furniture and large appliance 

parts and products coating operations into the rule. 40 CFR 60 Subpart EE establishes 

the NSPS for surface coating of metal furniture. 40 CFR 60 Subpart SS establishes the 

NSPS for industrial coating of large appliances. The analysis of the major provisions of 

Rule 4603 in comparison with 40 CFR 60 Subpart EE and Subpart SS is presented in 

Table 1 of this report. District staff did not find any NSPS relevant to wood coating 

operations. Therefore, no rule consistency analysis was done to compare Rule 4606 

with NSPS. 

3. National Emission Standards for Hazardous Air Pollutants (NESHAPs) 

NESHAPs are requirements contained in 40 CFR 61 and 40 CFR 63. Since EPA has 

delegated the authority to implement NESHAP requirements to the District, all NESHAP 

promulgated by EPA have been incorporated by reference into District Rule 4002 

(national Emission Standards for Hazardous Air Pollutants). 

District staff analyzed two NESHAPs that are relevant to the proposed amendments to 

Rule 4603 to incorporate the CTG standards for metal furniture and large appliance 

parts and products coating operations. 40 CFR 63 Subpart NNNN establishes the 

NESHAP standards for surface coating of large appliances. 40 CFR 63 Subpart RRRR 

establishes the NESHAP standards for surface coating of metal furniture. Although, 40 

CFR 63 Subpart MMMM applies to surface coating of miscellaneous metal parts and 

products, District staff did not analyze this NESHAP since there is no change to the 

existing Rule 4603 requirements for miscellaneous metal parts and products other than 

to incorporate the CTG standards specifically for metal furniture and large appliance 

parts and products coating operations. The analysis of the major provisions of Rule 

4603 in comparison with 40 CFR 63 Subpart NNNN and Subpart RRRR is presented in 

Table 2 of this report. 

District staff analyzed one NESHAP that is relevant to the proposed amendments to 

Rule 4606 to incorporate the CTG standards for flat wood paneling products coating 

operations. 40 CFR 63 Subpart QQQQ establishes the NESHAP standards for surface 

coating of wood building products. According to EPA, the Wood Building Products 

source category was originally listed as the “flat wood peneling” source category, but he 

name was changed to wood building products to more accurately reflect the types of 

products and manufacturing sources in the source category. The wood building 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-5 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

products covered by 40 CFR 63 Subpart QQQQ include interior wall paneling and 

tileboard, exterior siding and primed doorskins, other interior panels, flooring, doors, 

window, and miscellaneous. The analysis of the major provisions of Rule 4606 

pertaining to flat wood paneling products coating operations in comparison with 40 CFR 

63 Subpart QQQQ is presented in Table 3 of this report. 

III. RESULTS OF RULE CONSISTENCY ANALYSIS 

District staff found that facilities affected by the proposed changes to Rule 4603 are 

already using coatings that comply with the proposed coating VOC limits. The 

proposed changes to Rule 4606 would not affect existing wood products coating 

operations because the changes only applies to flat wood paneling coating operations. 

District staff has determined that there is no flat wood paneling products manufacturing 

company currently operating within the San Joaquin Valley. Furthermore, District staff 

found that none of the proposed requirements of this rulemaking project would conflict 

with federal rules, regulations, or policies covering similar stationary sources. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-6 Final Staff Report with Appendices for Proposed Amendmen

Table 1 - Comparative Analysis of Rule 4603 and Applicable New Source Performance Standards (NSPS) 

Rule 4603 40 CFR 60 Subpart EE (Surface Coating of Metal Furniture) 

Applicability Metal parts and products, large appliances parts or products, and 

metal furniture. Large appliances parts or products coating operations, and metal furniture coating operations at a stationary source where the 

emissions are equal to or greater than 3 tons of VOC per 12-month rolling period are subject to the new VOC content limits of the 

proposed Rule 4603. 

Metal furniture coating operation facility that commences construction, modification, or reconstruction after 11/28/80. 

Exemption Except for large appliance parts and products, and metal furniture 

the rule exempts stationary source that uses 55 gallons or less of 

non compliant coatings per rolling 365-day period 

Facilities using less than 3,842 liters of coating (as applied) per 

year. 

Standards • General Coatings Limits (except for large appliance parts and 

products, and metal furniture): Baked: 275 grams/liter; Air-dried: 40 grams/liter Air-dried Dip coating of steel joists: 340 grams/liter to 400 

grams/liter depending on viscosity of coatings. 

• Specialty Coating Limits (except for large appliance parts and 

products, and metal furniture): Baked: 360 to 880 grams/liter; Air-dried: 420 to 880 grams/liter. 

• Coatings Limits for Large Appliance Parts and Products, and 

Metal Furniture Baked: 275 to 420 grams/liter; Air-dried: 275 to 420 grams/liter. 

• Install and operate a VOC emission control system instead of 

complying with coating VOC limits. 

• Prohibits discharge into the atmosphere of VOC emissions from 

metal furniture surface coating operation in excess of 0.90 kg/liter (900 grams/liter) of coating solids applied. 

• Establishes specific performance tests and compliance 

provisions. 

• Specifies coating application methods and corresponding 

transfer efficiencies (air atomized - 25%; airless spray - 25%; manual electrostatic spray - 60%; nonrotational automatic electrostatic spray - 70; rotating head electrostatic spray 

manual and automatic - 80%; dip and flow coating - 90%; electrodeposition - 95%) 

• Allows use of VOC capture and control system to comply with 

the required VOC emission limit. Requires testing and monitoring of the VOC emission control system. 

Work Practice • Store all VOC-containing materials in closed containers. 

Containers must be closed at all times except when specifically in use. 

• Close mixing vessels that contain VOC-containing coatings and 

materials, except when specifically in use. 

• Minimize spills and convey VOC-containing materials in closed 

containers or pipes. 

• Specifies coating application equipment (electrodeposition, 

electrostatic application, HVLP guns, flow coating, roll coating, 

dip coating, brush coating, continuous coating, or other type 

that meets at least 65% transfer efficiency. 

None specified. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-7 Final Staff Report with Appendices for Proposed Amendmen

Continuation of Table 1 – Comparison of Rule 4603 and Applicable New Source Performance Standards (NSPS) 

Rule 4603 40 CFR 60 Subpart EE (Surface Coating of Metal Furniture) 

Recordkeeping and Reporting 

Maintain records of MSDS for each coating used, VOC content of 

coating, and amount used. Keep records for at least five years and make such records available to the APCO upon request. 

• Requires initial performance test and then monthly thereafter: 

Volume-weighted average mass of VOC emitted to the atmosphere per volume of applied coating solids for a period of 

one calendar month. 

• List of coatings used during a period of one calendar month, 

VOC content of each coating and the minimum transfer 

efficiency of coating application equipment used during the month. 

• For VOC control system: total VOC emitted that enters the 

control device, VOC reduction efficiency of the control device, average combustion temperature, description of method used to establish the amount of VOC captured and sent to the incinerator. 

• For thermal and catalytic incinerators, each 3-hr period of 

coating operation during which the average temperature recorded immediately before the catalyst bed is more than 28

oC 

(50

oF) below the average temperature at the same location 

during the most recent performance test at which the destruction efficiency was determined as specified in Section 60.313. 

• For facilities where compliance is achieved through the use of 

solvent recovery system: volume of VOC-solvent recovered; overall VOC emission reduction achieved. 

• Submit a written report every calendar quarter of each instance 

where the volume-weighted average of the total mass of VOC emitted into the atmosphere per volume of applied coating solids is greater than the specified limit. If no instances have occurred during a particular quarter, a report stating this shall be submitted semiannually. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-8 Final Staff Report with Appendices for Proposed Amendmen

Table 2- Comparison of Rule 4603 and National Emission Standards for Hazardous Pollutants (NESHAP) 

Rule 4603 40 CFR 63 Subpart NNNN (Surface Coating of Large Appliances) 40 CFR 63 Subpart R

Furniture) 

Applicability Refer to discussion 

indicated in Table 1 

• Large appliance parts and products coating facility that is a major source of 

HAP that emits or has the potential to emit a single HAP of 9.07 megagrams 

(10 tons) per year or more or any combination of HAP of 22.68 megagrams (25 tons) per year. 

• Applies to each new, reconstructed, and existing affected source. 

• A new affected source that commences construction after 7/23/02 and the 

construction is of a completely new large appliance surface coating facility where previously no large appliance surface coating facility had existed. 

• Major source of H

emit a single HAP or more or any co(25 tons) per year

• Applies to each ne

source. 

• A new affected so

7/23/02 and the coappliance surface 

large appliance su

Exemption Refer to discussion 

indicated in Table 1 

• Non-major sources of HAP. • Large appliance parts such as metal or plastic handles, hinges, or fasteners 

that have a wider use beyond large appliances. 

• Surface coating conducted for the purpose of repairing or maintaining large 

appliances used by a facility and not for commerce.

• Surface coating of heat transfer coils or large commercial and industrial chillers. 

• Affected source th

contain no organic 

• Surface coating of 

subject to wood fu

• Surface coating co

facilities or that is maintenance oper

• Surface coating of 

hinges, or screws furniture unless thmetal furniture sou

• Surface coating of 

purpose of repairinby a major source emissions itself is 

• Surface coating of 

installations ownethe U.S. (including State). 

Standards Refer to discussion 

indicated in Table 1 

• Existing source: limits organic HAP emissions to the atmosphere to no more 

than 0.13 kg/liter (1.1 lb/gal) of coating solids used during each compliance 

period. The emission limit includes all coatings, thinners, and cleaning materials used. 

• Includes three compliance options (use of compliant materials, emission rate 

without use of add-on controls, or emission rate with add-on controls). 

• For New or recons

during each compemission limit prov63.4890(b)(1) are an alternative emi

liter (0.78 lb/galloncomponents subje

• For existing affect

HAP per liter (0.83 compliance period

• Operators that use 

required to meet a

• Operators that use 

option are requirein Table 1 of this s
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-9 Final Staff Report with Appendices for Proposed Amendmen

Continuation of Table 2- Comparison of Rule 4603 and National Emission Standards for Hazardous Pollutants (NESHA

Rule 4603 40 CFR 63 Subpart NNNN (Surface Coating of Large Appliances) 40 CFR 63 Subpart R

Furniture) 

Work Practice Refer to discussion 

indicated in Table 1 

• For operation that uses compliant material option or emission rate without addon controls option, compliance with any work practice standards are not 

required. 

• For operation that use emission rate with add-on controls option, implement a 

work practice plan to minimize organic HAP emissions from storage, mixing, and conveying coatings, thinners, and cleaning materials used in, and waste 

materials generated by, the coating operations. Store all HAP-containing 

materials in closed containers. Minimize spills of HAP-containing materials. Convey HAP-containing materials from one location to another in closed 

containers or pipes. Mixing vessels must be closed except when removing, or mixing contents. Minimize HAP emissions during cleaning of storage, mixing, 

and conveying equipment. 

Same as discussed fo

Recordkeeping and Reporting 

Refer to discussion indicated in Table 1 

• Submit Initial Notification no later than 6/23/03. For new or reconstructed 

source, submit Initial Notification no later than 120 days after initial start-up or 

11/2002 whichever is later. 

• Submit semiannual compliance reports (period from January 1 through June 30 

or from July 1 through December 31). 

• Demonstration of compliance with the emission limit requires submission of 

detailed data which include mass fraction of HAP for one coating, one thinner, 

and for one cleaning material; volume fraction coating; density of coating; amount of waste materials and mass of HAP contained in waste material, determination of kg or HAP emitted per liter of coating solids. 

• For emission rate without add-on controls option: provide calculation of the 

total mass of HAP emissions; calculation of the total volume of coating solids 

used; and calculation or HAP emission rates as specified in the applicable provisions. 

• For emission rate with add-on controls option, provide the calculation of the 

total mass of HAP emissions for the coatings, thinners, and cleaning materials used; calculation of the total volume of coating solids used; calculation of the mass HAP emission reduction by emission capture systems and add-on control 

devices; and calculation of HAP emission rate; a summary of the results of each add-on control device performance tests; a list of each emission capture 

system’s and add-on control device’s operating limits and a summary of the data used to calculate those limits. 

• Keep records of the data and information specified in Section 63.4130. 

Same as discussed fo

Compliance Deadlines 

Six months after rule amendments adoption date. 

• Comply by 7/23/02 if the initial start-up of new or reconstructed affected source 

is before 7/23/02. 

• Comply by the initial start-up date if the new or reconstructed source occurs 

after 7/23/02. 

• For existing source comply by 7/25/2005. 

• Comply by 5/23/03 

reconstructed affe

• Comply by the init

is after 5/23/03. 

• Comply by 7/25/20
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-10 Final Staff Report with Appendices for Proposed Amendmen

Table 3 – Comparison of Rule 4606 with National Emission Standards for Hazardous Air Pollutants (NESHAP) 

 Rule 4606 40 CFR 63 Subpart QQQQ (Surface Coating of Wood BuApplicability Application of coatings to wood products, including furniture, cabinets, flat 

wood paneling, and custom replica furniture. Flat wood Paneling products coating operation that emits 15 lb/day of VOC before consideration of controls. 

• Any affected source that performs surface coating ope

products that use at least 4,170 liters (1,100 gallons) o

source, is located at a major source, or is a part of a m

• A major source is a source that has the potential to em

single HAP or 22.68 megagrams/yr (25 tons/yr) of any 

• Applies to new, reconstructed, and existing source ( a 

construction commenced after 6/21/02). 

Exemptions • Coating operations that use a total of less than 20 gallons of coating per 

year. 

• Aerosol spray coatings for touch and repair. • Application of coatings by templates to add designs, letters, or numbers to 

wood products. 

• Application of coatings to wooden instruments. • Residential noncommercial operations. • Architectural coatings subject to District Rule 4601. 

• Refinishing, replacement, and custom replica furniture coating operation. 

• Specific finishes, except for flat wood paneling products, (crackle lacquers, 

faux finishes, imitation wood grain, leaf finishes)

• Surface coating operations covered by 40 CFR 63 Su

Wood Products). 

• Surface coating operations covered by 40 CFR 63 Su

Manufacturing). 

• Surface coating operations occurring during manufact

mobile/modular homes. 

• Surface coating occurring at research and laboratory f

construction or maintenance operations, hobby shops purposes, non commercial coating operations, or coatrefillable aerosol containers. 

• Surface coating involving wood treatment or fire retard

products sources that involve impregnating the wood 

chemicals or fire retardant by using retort or other pre

Standards • For wood products except flat wood paneling: 275 to 750 grams/liter 

depending on type of coating. Low solid stain: 120 grams/liter; Stripper: 350 grams/liter. 

• For flat wood paneling products: 250 grams/liter of coating, less water and 

exempt compound, as applied, or 350 grams/liter of material as applied. 

• In lieu of complying with coating VOC limits, install and operate a VOC 

emission control system (overall capture and control efficiency of at least 

85% for wood products and at least 90% for flat wood paneling products coating operation. 

• Cleaning solvent VOC limits:Until 9/20/08, 50 to 550 grams/liter depending 

on type of cleaning operation. On and after 9/21/08, organic solvent limit is 25 grams/liter for any type of cleaning operation. 

• Emission Limits: • Doors, windows, and miscellaneous: 231 grams HAP/

grams HAP/liter solids for new or reconstructed sourc

• Flooring: 83 grams HAP/liter solids for existing source

reconstructed source. 

• Interior wall paneling or tileboard: 183 grams HAP/lite

HAP/liter solids for new or reconstructed source. 

• Other interior panels: 20 grams HAP/liter solids for ex

for new or reconstructed source. 

• Exterior siding and primed doorskins: 7 grams HAP/lit

HAP/liter solids for new or reconstructed source. 

• Compliance Options: use compliant materials; HAP e

(12-month average emission) is less than or equal to temission rate with add-on controls (HAP emission rate emission limit with the use of add-on controls). 

Work Practice • Store all VOC-containing materials in closed containers which must remain 

close at all times except when specifically in use.

• Close mixing vessels containing VOC coatings and other materials, except 

when specifically in use. 

• Minimize spills of VOC-containing materials and clean spills immediately. 

Convey any VOC-containing materials in closed containers or pipes. 

• Store all organic-HAP coatings, thinners, cleaning ma

containers. 

• Cover mixing vessels containing organic-HAP except 

contents. 

• Minimize emissions during cleaning of storage, mixing 

• Minimize spills of organic-HAP coatings, thinners, clea

• Minimize emissions through careful handling and tran

from one location to another in closed containers or p
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-11 Final Staff Report with Appendices for Proposed Amendmen

Continuation of Table 3 – Comparison of Rule 4606 with National Emission Standards for Hazardous Air Pollutants (NES

 Rule 4606 40 CFR 63 Subpart QQQQ (Surface Coating of Wood BuRecordkeeping and Reporting 

• Maintain current list of coatings, inks, adhesives, and solvents in use, 

including manufacturers recommended mix ratio of components, VOC content and amount of each coatings, solvents, and adhesives used. 

• Records of key operating parameters of VOC emission control system. 

• Keep records for five years and make them available to the APCO upon 

request. 

• Requires continuous parameter monitoring for all capt

• Specifies the provisions for demonstrating compliance 

HAP emission rate) with the applicable HAP emission 

• Submit Initial Notification within 120 days of start-up o

• Submit Notification of Intent to conduct Performance T

• Submit performance test report within 60 days after co

• Submit Notification of Compliance Status within 30 da

(the first 12 months after compliance date). 

• Submit semiannual compliance reports due on July 31 

• Keep records of reported information and all other info

compliance for five years. 

Compliance Deadlines 

Six months after rule amendments adoption date. • Compliance date is 5/28/2006 for existing sources.

• Compliance date is the initial start-up or 5/28/2003, wh

reconstructed sources. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

APPENDIX B: Rule Consistency Analysis October 16, 2008 

B-12 Final Staff Report with Appendices for Proposed 

Amendments to Rule 4603 and Rule 4606 

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Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Proposed Amendments to: 

Rule 4603 (Surface Coating of Metal Parts and Products) 

Rule 4606 (Wood Products Coating Operations) 

October 16, 2008 

Prepared by: Joven R. Nazareno, Senior Air Quality Engineer 

Reviewed by: George Heinen, Supervising Air Quality Engineer 

Errol Villegas, Planning Manager 

I. SUMMARY 

A. Reasons for Rule Development and Implementation 

The San Joaquin Valley Air Basin (SJVAB) is a continuous inter-mountain valley 

comprised of eight counties in the southern portion of the San Joaquin Valley of 

California: Fresno, Kings, Madera, Merced, San Joaquin, Stanislaus, Tulare, and the 

Valley portion of Kern. The SJVAB is approximately 250 miles long, averages 80 miles 

wide, and is partially enclosed by the Coast Mountain range on the west, the Tehachapi 

Mountains on the south, and the Sierra Nevada range on the east. These surrounding 

mountains trap pollution. Low wind speeds combined with low-lying inversion layers in 

the winter create a climate conducive to the formation of high particulate matter (PM) 

concentrations. The region’s hot, dry summers are conducive to ozone formation. 

The SJVAB is currently designated as nonattainment for the national ambient air quality 

standard (NAAQS) for particulate matter 2.5 microns in diameter or less (PM2.5) and 

serious nonattainment for the eight-hour ozone NAAQS. Prior to the United States 

Environmental Protection Agency’s (EPA’s) implementation of the eight-hour ozone 

standard, the SJVAB was also classified as an extreme nonattainment area for the onehour ozone NAAQS. Although EPA revoked the one-hour ozone NAAQS, the San 

Joaquin Valley Air Pollution Control District (District) is still required to meet certain 

requirements mandated by the federal Clean Air Act related to the extreme designation. 

In addition to being classified as nonattainment of federal air standards, SJVAB is 

classified as severe nonattainment for the California ozone air quality standard and 

nonattainment for the California air quality standard for particulate matter ten microns in 

diameter or smaller (PM10). 

The federal Clean Air Act (CAA) Section 172(c) provides that state implementation 

plans (SIPs) for nonattainment areas must include Reasonably Available Control 

Technology (RACT) and Reasonably Available Control Measures (RACM), for sources 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

2 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, states 

must revise their SIPs to include RACT for each category of volatile organic compounds 

(VOC) sources covered by Control Techniques Guidelines (CTG) documents between 

November 15, 1990 and the date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the 

lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility. 44 FR 53761 (September 17, 1979). In subsequent Federal 

Register notices, EPA has addressed how states can meet the RACT requirements of 

the CAA. The CTG is intended to provide State and local air pollution control 

authorities such as San Joaquin Valley Unified Air Pollution Control District (District) 

information that should assist in determining RACT standards. 

In September 2006, EPA issued a CTG for Flat Wood Paneling Coatings. In October 

2007, EPA issued a CTG for Large Appliance Coatings, and a CTG for Metal Furniture 

Coatings. District staff considers the recommended controls in the CTGs constitute 

RACT as well as RACM for these source categories. The CTGs contains VOC content 

limits for coatings, VOC control device efficiency, and work practice standards to reduce 

VOC emissions from such coating operations. The CTG standards are discussed in 

Section III of this Draft Staff Report. 

B. Description of the Rule Development Project 

The purpose of this rule development project is to implement RACT and RACM by 

amending Rule 4603 (Surface Coating of Metal Parts and Products) and Rule 4606 

(Wood Products Coating Operations). To accomplish this, the emission control 

standards recommended in the CTG for Large Appliances Coatings, and the CTG for 

Metal Furniture Coatings would be included in Rule 4603. The emission control 

standards in the CTG for Flat Wood Paneling Coatings would be included in Rule 4606. 

II. BACKGROUND 

A. Existing Rule 4603 (Surface Coating of Metal Parts and Products) 

Rule 4603 was adopted in April 11, 1991. The rule has been amended several times, 

most recently on September 20, 2007. The rule applies to coating of metal parts and 

products and to the solvent cleaning process associated with coating operations. 

The purpose of the rule is to limit VOC emissions from coating of metal parts and 

products, and from organic cleaning, storage and disposal of solvents and waste 

solvent materials associated with such coating. 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

3 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

Rule 4603 allows certain exemptions from the rule or from the coating VOC content 

limits. For example, a facility is exempt from the VOC content limits of the rule if the 

amount of coatings used does not exceed a total of 55 gallons of non-compliant 

coatings per rolling consecutive 365-day period, provided the operator complies with 

the coating application methods and administrative requirements such as 

recordkeeping. Also coating operations that are subject to other District coating rules 

such as Rule 4661 (Organic Solvents), Rule 4602 (Motor vehicle and Mobile Equipment 

Coating Operations), Rule 4612 (Motor Vehicle and Mobile Equipment Operations 

Phase II), and Rule 4605 (Aerospace Assembly and Component Manufacturing 

Operations) Rule 4604 (Can and Coil Coating Operations). Additional exemptions from 

the rule includes coating operation involving touch-up and repair, polyester resin 

operations and the application of polyester resin to metal parts and products. The rule 

also contains certain exemptions for solvent cleaning operations. 

Rule 4603 establishes VOC content limits for coatings used in the manufacture and 

fabrication of metal parts and products. The general VOC limits for baked coating and 

for air-dried coating is 275 grams per liter (2.3 pounds/gallon) and 340 grams/liter (2.8 

pounds/gallon, respectively. Both limits are expressed weight of VOC/volume of 

coating, less water and less exempt compounds, as applied. The rule also establishes 

VOC limits for specialty coatings ranging from 360 grams/liter (3.0 pounds/gallon) to 

880 grams/liter (7.3 pounds/gallon) depending on the category of coating. Specialty 

coating category includes camouflage, extreme performance, heat resistant, high gloss, 

high performance architectural, high temperature, metallic topcoat, pretreatment primer, 

silicone release, solar absorbent, and solid film lubricant. 

In lieu of complying with the coating VOC limits, an operator may use an APCOapproved VOC emission control system provided it is under District permit, has an 

overall capture and control efficiency of at least 90 percent by weight, and the 

emissions resulting from the use of the control system would not result in emissions in 

excess of those that would have been achieved had the operator complied with the 

VOC content limits of the coating or solvents. In addition to the coatings VOC limits, 

the rule also include provisions for coating application methods, which include 

electrostatic application, electrodeposition, high-volume, low-pressure (HVLP) spray 

equipment, flow coating, roll coating dip coating, brush coating or other application 

method demonstrated to the District as capable of achieving at least 65 percent transfer 

efficiency. 

Rule 4603 establishes the VOC content limits for organic solvent cleaning materials. 

Until September 20, 2008, the VOC content limit of organic cleaning solvents range 

from 50 grams/liter (0.42 pound/gallon) to 550 grams/liter (4.6 pounds/gallon) 

depending on the type of cleaning operation. These limits would drop to 25 grams/liter 

(0.21 pound/gallon) for all cleaning categories effective on and after September 21, 

2008. 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

4 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

B. Existing Rule 4606 (Wood Products Coating Operations) 

Rule 4606 was adopted on December 19, 1991. The rule has undergone several 

amendments with the last occurring on September 20, 2007. The purpose of the rule is 

to limit the emissions of VOC from wood products coating operations, and from organic 

solvent cleaning, storage and disposal of solvents and waste solvent materials 

associated with such coating operations. The rule applies to coating of wood products, 

including furniture, cabinets, and custom replica. The rule define wood products as 

“objects such as cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, doors, 

trims, 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.” 

Rule 4606 allows certain exemptions from the rule or from the coating VOC content 

limits. For example, the rule exempts aerosol-spray coatings for touch and repair, 

stationary source that use a total of less than 20 gallons of coating per year in all wood 

products coating operations, application of coatings by template in order to add 

designs, letters, or numbers to wood products, coatings to wooden musical instruments, 

and residential noncommercial operation. Also, the rule also exempts specific finishes 

such as crackle lacquers, faux finishes, imitation wood grain, and leaf finishes, 

refinishing, replacement, and custom replica furniture coating operation is also exempt 

from the rule. 

Rule 4606 establishes the coating VOC limits for wood products that are not exempt 

from the rule. The VOC limits range from 275 grams/liter (3.3 pounds/gallon) to 750 

grams/liter (6.3 pounds/gallon) depending on the coating category. The VOC limit is 

expressed in weight of VOC per volume of coating, less water and less exempt 

compounds, as applied. The VOC limits for low-solids stain and for stripper is 120 

grams/liter (1.0 pound/gallon) and 350 grams/liter (2.9 pounds/gallon), respectively. 

These limits are expressed in weight of VOC per volume of material. In lieu of 

complying with the coating VOC limits, an operator may use an APCO-approved VOC 

emission control system provided it is under District permit, has an overall capture and 

control efficiency of at least 85 percent by weight, and the emissions resulting from the 

use of the control system would not result in emissions in excess of those that would 

have been achieved had the operator complied with the VOC content limits of the 

coating or solvents. 

Rule 4606 establishes the VOC content limits for organic solvent cleaning materials. 

Until September 20, 2008, the VOC content limit of organic cleaning solvents range 

from 50 grams/liter (0.42 pound/gallon) to 550 grams/liter (4.6 pounds/gallon) 

depending on the type of cleaning operation. These limits would drop to 25 grams/liter 

(0.21 pound/gallon) for all cleaning categories effective on and after September 21, 

2008. 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

5 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

For detailed requirements, please refer to the current Rules 4603 and 4606, which are 

available on the District’s website at www.valleyair.org. 

III. PROPOSED CHANGES TO RULE 4603 AND RULE 4606 

A. CTG for Large Appliance Coatings 

In September 2007, EPA issued the CTG for large appliance coatings. The CTG 

applies to each large appliance coating operations, including related cleaning activities, 

at the facility that are equal to or exceed 15 pounds per day, or an equivalent level such 

as 3 tons per 12-month rolling period, before consideration of controls. Large appliance 

part is defined as any organic surface-coated metal, lid, door, casing, panel, or other 

interior or exterior metal part or accessory that is assembled to form a large appliance 

product. Large appliance product is defined as any organic-surface coated metal 

range, oven, microwave, refrigerator, freezer, washer, dryer, dishwasher, water heater, 

or trash compactor manufactured for household, commercial or recreational use. The 

following discussions are excerpts from the provisions of the CTG: 

Process Description and Sources of VOC Emissions 

Large appliance coatings include, but are not limited to materials referred to as paint, 

topcoats, basecoats, primers, enamels, and adhesives used in the manufacture of large 

appliance parts or products. Coatings are applied using different methods such as air 

atomized spraying and airless spraying, dip coating, electrodeposition, and flow coating. 

In a typical liquid spray and dip coating operations, the coated parts/products move 

from the coating application area through a flash-of area where solvents in the coating 

begin to evaporate slowly, thus avoiding bubbling of the coating while it is curing in the 

oven. After the typical coating operation, large appliance products are dried and cured 

using heated dryers or by air drying. Touch-up operations are performed using manual 

air spray guns and a lacquer base coating, which has good drying characteristics that 

allow for shorter drying times. 

VOC emissions from large appliance coating processes result from the evaporation of 

the coating components and cleaning materials. Different types of low-VOC coatings 

are available for large appliance parts and products. These coatings include: powder 

coatings, waterborne coatings, higher solids coatings, and ultraviolet coatings. 

Available Controls for VOC Emissions from Coatings 

Two general types of emission control techniques for reducing VOC emissions from 

large appliance coatings are pollution prevention measures and emission capture and 

add-on control systems. Pollution prevention measures include coating product 

substitution/reformulation and work practices to reduce emissions. In addition to 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

6 Final Staff Report with Appendices for 

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pollution prevention measures, emissions can be reduced by the use of capture system 

in conjunction with add-on control systems (e.g., thermal oxidizer or carbon adsorption) 

that destroy or recover VOC in the exhaust streams.

Emission Limits Based on Low-VOC Coatings 

The CTG recommends the VOC limits for coatings as shown in Table 1. 

Table 1 – VOC Limit, mass of VOC/volume of coating, as applied 

excluding water and exempt compounds 

VOC Limit 

Baked Air-dried 

Coating Type 

kg/l lb/gal kg/l lb/gal 

General, one component 0.275 2.3 0.275 2.3 

General, multi-component 0.275 2.3 0.340 2.8 

Extreme High Gloss 0.360 3.0 0.340 2.8 

Extreme high performance 0.360 3.0 0.420 3.5 

Heat resistant 0.360 3.0 0.420 3.5 

Metallic 0.420 3.5 0.420 3.5 

Pretreatment coating 0.420 3.5 0.420 3.5 

Solar absorbent 0.360 3.0 0.420 3.5 

The CTG recommends exempting stencil coatings, safety-indicating coatings, solid-film 

lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair 

coatings, and coating application utilizing hand-held aerosols 

If product performance or other needs require the use of high-VOC materials than those 

that would meet the recommended VOC limits, a facility could choose to use add-on 

control equipment to meet an overall control efficiency of 90 percent. 

The CTG establishes work practice standards to reduce VOC emissions. The 

standards include: storing all VOC coatings, thinners, and cleaning materials in closed 

containers, minimizing spills of VOC-containing coatings, thinners, cleaning spills 

immediately, conveying VOC-containing materials in closed containers or pipes, closing 

mixing vessels which contain VOC coatings and other materials except when 

specifically in use, and minimizing emissions of VOC during cleaning of storage, mixing, 

and conveying equipment. 

B. CTG for Metal Furniture Coatings 

 

In September 2007, EPA issued the CTG for metal furniture coatings. The CTG 

applies to each metal furniture coating operations at a facility where the total actual 

VOC emissions are equal to or exceed 15 pounds per day, or an equivalent level such 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

7 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

as 3 tons per 12-month rolling period, before consideration of controls. The CTG does 

not recommend control approaches for facilities that emit below this level because of 

the very small VOC emissions reductions that could be achieved. The following 

discussions are excerpts from the provisions contained in the CTG: 

Process Description and Sources of VOC Emissions 

A metal furniture is the furniture or components of furniture constructed either entirely or 

partially from metal. These include, but are not limited to, the following products: 

household, office, institutional, laboratory, hospital, public building, restaurant, barber 

and beauty shop, dental furniture, as well as components of these products. Metal 

Furniture also includes office and store fixtures, partitions, shelving, lockers, lamps and 

lighting fixtures, and wastebaskets. Metal furniture coatings include paints and 

adhesives and typically applied without a primer. 

Metal furniture manufacturing process involves the following operations: (a) raw 

material preparation; (b) surface preparation; (c) coating and adhesive application; and 

(d) assembly. Raw material preparation and assembly operations do not involve any 

VOC emissions. Primarily, the VOC emissions are generated from process operations 

involving surface preparation, coating application, and cleaning activities that use VOCcontaining materials (e.g., coatings, thinners, and solvent-containing cleaning 

materials). The primary source of VOC emissions from metal furniture coating 

operation occur during the coating application process, flash-off, and drying/curing of 

the coatings. The remainder of the emissions comes from mixing and thinning of the 

coatings as well as during cleaning operations. 

Available Controls for VOC Emissions from Coatings 

The two general emission control techniques for reducing VOC emissions from metal 

furniture coating operations are: (1) pollution prevention measures; (2) emission 

capture and add-on control systems. 

Pollution control measures include product substitution and reformulation, work practice 

procedures, and equipment substitution. VOC emissions can be reduced by using low 

VOC coatings such as powder coatings, higher solids coatings, waterborne coatings, 

and ultraviolet coatings. Using low-VOC cleaning materials also reduce VOC emissions 

during cleaning activities. Additionally, emissions can be minimized by using work 

practice procedures such as reducing coating wastes and using efficient coating 

application equipment that increases the coating transfer efficiency 

VOC emissions from coating operations can also be reduced by the use of capture 

systems in conjunction with add-on control device that either destroy or recover the 

VOC in the exhaust streams. Capture systems include hoods and enclosures to collect 

the solvent-laden air from the process vents or fugitive emissions from flash-off areas 

and then directing the captured air to a control device for destruction or recovery. 
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8 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

Spray booths and ovens are the primary components of the capture system. Add-on 

control systems include such devices as thermal oxidizers, catalytic oxidizers, and 

carbon adsorbers. 

Emission Limits Based on Low-VOC Coatings 

The CTG recommends the VOC limits for coatings as shown in Tables 2. 

Table 2 – VOC Limit, mass of VOC/volume of coating, as applied 

excluding water and exempt compounds

Coating Type Baked Air-Dried 

kg/l lb/gal kg/l lb/gal 

General, One Component kg/l lb/gal 0.275 2.3 

General, Multi-Component 0.275 2.3 0.340 2.8 

Extreme High Gloss 0.275 2.3 0.340 2.8 

Extreme Performance 0.360 3.0 0.420 3.5 

Heat Resistant 0.360 3.0 0.420 3.5 

Metallic 0.360 3.0 0.420 3.5 

Pretreatment Coatings 0.420 3.5 0.420 3.5 

Solar Absorbent 0.420 3.5 0.420 3.5 

The CTG recommends exempting stencil coatings, safety-indicating coatings, solid-film 

lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair 

coatings, and coating application utilizing hand-held aerosols 

If product performance or other needs require the use of high-VOC materials than those 

that would meet the recommended VOC limits, a facility could choose to use add-on 

control equipment to meet an overall control efficiency of 90 percent. 

The CTG establishes work practice standards to reduce VOC emissions. The 

standards include: storing all VOC coatings, thinners, and cleaning materials in closed 

containers, minimizing spills of VOC-containing coatings, thinners, cleaning spills 

immediately, conveying VOC-containing materials in closed containers or pipes, closing 

mixing vessels which contain VOC coatings and other materials except when 

specifically in use, and minimizing emissions of VOC during cleaning of storage, mixing, 

and conveying equipment. 

C. Proposed Amendments to Rule 4603 

Affected Sources 

Based on research of the District’s permit database and observations of District 

Compliance Division inspectors, staff found that there are only two permitted facilities 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

9 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

which perform coating operations during manufacturing or fabricating cooling towers 

and cooling units, and one company that performs coating on beverage vending 

machines (similar to refrigerators) that are considered as large appliance parts or 

products coating operations. The three affected facilities shown in Table 3 are already 

in compliance with the proposed coating VOC limits as shown in Table 1. 

There are eight permitted metal furniture coating facilities in the District as shown in 

Table 4. Four of these facilities are subject to the CTG because their coating operation 

emissions exceed the 3 tons of VOC per 12-month rolling period applicability threshold. 

The four facilities subject to the CTG emissions applicability threshold are already using 

coatings that comply with the proposed VOC content limits. The other four facilities emit 

less than the CTG emission applicability threshold so they are not subject to the 

proposed new limits even though they are already using compliant coatings. One of the 

total eight metal furniture coating facilities is exempt from the CTG or Rule 4603 

requirements because it is performing only touch and repair coating operation of metal 

furniture. 

Table 3 – Permitted Large Appliances Coating Facilities in the District 

Facility Name 

CTG VOC 

Limit airdried (lb/gal) 

Rule 4603 

limit air-dried 

(lb/gal) 

VOC of 

coating in use 

air-dried 

(lb/gal) 

Compliance 

with CTG 

Limits 

Coating 

Operation 

VOC Emission 

(lb/day) 

Baltimore 

Aircoil of 

California 2.3 2.8 

<1% by 

weight 

powder 

coating N/A 

3 lb/day (not 

subject to 

CTG) 

2.3 2.8 1 yes 

Evapco West 2.3 2.8 1.5 yes 

49 lb/day 

(subject CTG) 

Pepsi Cola 

Bottling 

Company 

2.3 (onecomponent 

coating) 

2.8 (multicomponent 

coating) 

2.8 2.8 (multicomponent 

coating) 

yes 54.7 lb/day 

(subject to 

CTG) 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

10 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

Table 4 – Permitted Metal Furniture Coating Facilities in the District 

Facility Name 

CTG VOC 

Limit airdried (lb/gal) 

Rule 4603 

limit air-dried 

(lb/gal) 

VOC of 

coating in use 

air-dried 

(lb/gal) 

Compliance 

with CTG 

Limits 

Coating 

Operation 

VOC Emission 

(lb/day) 

California 

State Prison 2.3 2.8 1.03 yes 

>15 lb/day 

(subject to 

CTG) 

Sturdy Safe 2.3 2.8 2.6 N/A 

5 lb/day (not 

subject to 

CTG) 

Edsal 

Sandersky 

Corp. 2.3 2.8 

<1% by 

weight 

powder 

coating yes 

42 lb/day 

(subject to 

CTG) 

Elements by 

Grapevine 2.3 2.8 2.1 yes 

40 lb/day 

(subject to 

CTG) 

Lodi Metal 

Tech, Inc. 2.3 2.8 

<1% by 

weight 

powder 

coating yes 

49.3 (subject 

to CTG) 

Ward 

Brothers 

Office 

Furniture 2.3 2.8 2.25 N/A 

11 lb/day (not 

subject to 

CTG 

Levitt Weaver 2.3 2.8 2.57 N/A 

Inc. 

2.3 2.8 2.3 

 4.9 lb/day 

(not subject to 

CTG) 

Frederick 

Antique 

Restoration 2.3 2.8 2.1 

exempt 

touch-up and 

repair 

exempt from 

CTG and Rule 

4603 

The following are proposed amendments to Rule 4603:

• Section 1.0 (Purpose) and Section 2.0 (Applicability) 

These sections would be modified to clarify that large appliances parts or products, and 

metal furniture coating operations are subject to the rule. 

• Section 3.0 (Definitions) 

The definitions of extreme high gloss, large appliance part, large appliance product, 

metal furniture, multi-component coating, and one-component coating would be added 

into the rule. The existing definition of extreme performance coating would be modified 

for clarity. As recommended by EPA, the existing names “metallic topcoat”, “high gloss” 
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11 Final Staff Report with Appendices for 

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and “pretreatment wash primer” in Table 1 would be changes to “metallic coating” and 

“extreme high gloss” and “pretreatment coating”, respectively, for consistency with 

names of the coatings used in Table 2. The new or modified definitions would improve 

the clarity, effectiveness, and enforceability of the rule. 

• Section 5.2 (Specialty Coating Limits) 

This section would be modified to clarify that the current specialty coating VOC limits in 

Table 1 apply to all metal parts and products, except for coating operations on large 

appliance parts or products, and metal furniture that are subject to new Section 5.4 as 

discussed below. 

• New Section 5.4 and New Table 2 (Coating Limits for Large Appliance Parts or 

Products, and Metal Furniture) 

New Section 5.4.1 and new Table 2 would specify the coating limits for large appliance 

parts or products coating operations, or metal furniture coating operations whose VOC 

emissions, including related cleaning activities, at a stationary source are equal to or 

greater than 3.0 tons of VOC per 12-month rolling period, before consideration of 

controls. The VOC content limits in Table 2 of the rule range from 275 grams/liter (2.3 

pounds/gallon) to 420 grams/liter (3.5 pounds/gallon) of coating, less water and exempt 

compounds, as applied, depending on the type of coating. The coatings VOC content 

limits in Table 2 of the rule are consistent with the CTG limits discussed in Sections IIIA 

and IIIB of this staff report. In lieu of complying with Table 2 VOC limits, an operator 

use an APCO-approved VOC emission control system that meets the requirements 

specified in the rule. 

The new Table 2 coating VOC content limits are effective on and after April 16, 2009. 

Since operators of existing large appliance parts and products coating operations and 

metal furniture coating operations are already using coatings that meet the proposed 

VOC content limits a longer compliance deadline is not needed. 

Operators of large appliance parts or products coating operations, or metal furniture 

coating operations would need to keep the applicable records required by Section 6.2 

of the rule to demonstrate if the VOC emissions from all large appliance parts or 

products coating operations, or metal furniture coating operations, including related 

cleaning activities, are equal to or greater than 3 tons of VOC per 12-month rolling 

period, thereby making the source operation subject to Table 2 limits. 

In the June 24, 2008 version of Draft rule 4603, District staff previously proposed that 

large appliance parts and products coating operations and metal furniture coating 

operations at a stationary sources where the total actual VOC emissions are equal to or 

greater than 15 pounds of VOC per day or 3 tons of VOC per 12-month rolling period 

would be subject to the proposed new VOC content limits in Table 2 of the draft rule. In 
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Final Staff Report: Rule 4603 and Rule 4606 October 16, 2008 

12 Final Staff Report with Appendices for 

Proposed Amendments to Rule 4603 and Rule 4606 

order to eliminate ambiguity in enforcing the rule because of previously proposed dual 

threshold, District staff would propose to use the 3 tons of VOC per 12-month rolling 

period threshold and delete the 15 pound of VOC per day threshold. 

In the June 24, 2008 version of Draft Rule 4603, District staff previously proposed a 

new Section 5.3.3 which stated that Table 2 coating VOC content limits in the rule 

would not apply to stencil coatings, safety-indicating coatings, solid-film lubricants, 

electric-insulating and thermal coatings, and coating application using hand-held 

aerosol cans performed at a stationary source whose VOC emissions from all large 

appliance parts or products coating operations or metal furniture coating operations, 

including related cleaning activities, are equal to or greater than 3 tons of VOC per 12-

month rolling period. But stationary sources whose emissions are less than this 

threshold would have been required to comply with the existing limits in Section 5.1 and 

Section 5.2 Table 1 for stencil coatings, safety-indicating coatings, solid-film lubricants, 

electric-insulating and thermal coatings, and coating application using hand-held 

aerosol cans. EPA commented that the previously proposed provision seems 

counterintuitive that larger facilities would need exemptions from the requirements that 

apply to smaller facilities. District staff reevaluated the previously proposed Section 

5.3.3 and determined that EPA raised legitimate concern. Therefore, in response to 

EPA’s concern, previously proposed Section 5.3.3 would be deleted because the 

proposed provision would essentially relax the current SIP-approved Rule 4603 since 

the existing rule does not exempt stencil coatings, safety-indicating coatings, solid-film 

lubricants, electric-insulating and thermal coatings, and coating application using handheld aerosol cans. 

New Section 5.4.2 would specify that large appliance parts or products coating 

operations, or metal furniture coating operations whose VOC emissions, including 

related cleaning activities, at a stationary source are less than 3.0 tons per 12-month 

rolling period, before consideration of controls, at a stationary source would need to 

comply with the existing VOC content limits of coatings specified in Sections 5.1 and 

5.2. This new provision is necessary to prevent relaxation of an existing SIP-approved 

rule since sources whose emissions are less than 3.0 tons per 12-month rolling period 

are currently subject to the existing VOC limits. 

• Section 5.5.4 (VOC Emission Control System Requirement) 

To enhance the effectiveness and enforceability of the rule, a calculation equation would 

be included to determine if the minimum required overall capture and control efficiency of 

an emission control system is at equivalent or greater level of VOC reduction as would be 

achieved using compliant materials, or work practices. 
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• New Section 5.6 (Work Practice Standards) 

New Section 5.6 would include provisions for work practice standards that apply to large 

appliance parts and products, and metal furniture coating operations, including cleaning 

activities, where the total VOC emissions are equal to or greater than 3.0 tons per 12-

month rolling period. The work practice standards are consistent with the CTG as 

discussed in Section IIIA of the staff report. 

• Section 6.3 (Test Methods) 

Section 6.3 specifies the allowable test methods that must be used to demonstrate 

compliance with the rule requirements. Section 6.3 would be revised to allow operators to 

use alternate test methods other than specified in the rule provided the test methods have 

been approved by the APCO, ARB, and EPA. This change would provide operators 

flexibility to use other test methods that are equally efficient and accurate, but less 

expensive than the methods prescribed by the rule. 

• Section 6.3.7 (Determination of Overall Capture and Control Efficiency) 

As recommended by EPA, two equations would be added in Section 6.3.7 for calculating 

the capture efficiency and the control efficiency of a VOC emission control system. 

District staff included the same calculation equations from SCAQMD Rule 1136 (Wood 

Products Coatings) as recommended by EPA. 

D. CTG for Flat Wood Paneling Coatings 

In September 2006, EPA issued the CTG for flat wood paneling coatings. The CTG 

applies to facilities that apply flat wood paneling coatings that emit at least 15 pounds of 

VOC per day before consideration of controls. Flat wood paneling coatings means 

wood paneling products that are interior, exterior or tileboard (class I hardboard) panel 

to which protective, decorative, functional material or layer has been applied. EPA has 

determined that the 15 pounds of VOC per day applicability threshold is appropriate 

and is consistent with Section 183(e) of the CAA. The following discussions are 

excerpts from the provisions contained in the CTG: 

Process Description and Sources of VOC Emissions 

Types of Flat Wood Paneling 

The following discussions are selected excerpts from the CTG: 

Flat wood paneling products are used in construction and can be classified into three 

product types: decorative interior panels, exterior siding, and tileboard. 
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Decorative interior panels are hardboard, plywood, medium density fiberboard (MDF), 

or particleboard, that is usually grooved, embossed, and/or sometimes grain printed to 

resemble various wood species. Coated board used for interior panels are subject to 

industry performance specifications (consensus standards). These standards require 

multiple coating layers and coating steps. In order to maintain production speeds the 

use of solvents that evaporate without leaving cure blisters or residual solvent in the 

coating film or substrate are necessary. Interior panels are typically manufactured at the 

same facilities as tileboard, but in much smaller quantities. 

Exterior siding may be made of solid wood, hardboard, or waferboard. Siding made of 

solid wood and hardboard is typically primed at the manufacturing facility and finished in 

the field. Field applied coatings are not subject to this CTG. Finishing of solid wood and 

hardboard may be performed during manufacturing; however, this occurs on a limited 

basis. This industry segment involves exterior products that must have coatings able to 

withstand extreme and long-term weather conditions. These requirements impact the 

amount of VOC emitted from the coating of exterior siding. 

Tileboard is a premium interior wall paneling product made of hardboard that is used in 

high moisture areas such as kitchens and bathrooms. Tileboard must meet the 

specifications for Class I hardboard as approved by the American National Standards 

Institute (ANSI). The ANSI standard specifies requirements and test methods for water 

absorption, thickness swelling, edge straightness, and moisture content. Tileboard has 

more stringent product performance requirements compared to standard interior wall 

paneling. 

Sources of VOC Emissions 

Coatings are applied to flat wood paneling for three principal purposes: protection from 

moisture, temperature extremes, climate related hazards, and from insect infestation; to 

improve appearance; and for surface modification (i.e., to enhance surfaces to make 

other coatings more effective). Releases of VOC occur during the coating process as 

the coatings are mixed or thinned, as they are applied to the substrate, and as they dry 

and the VOC within the coating evaporate into the air. 

Coatings applied to flat wood paneling include fillers, sealers, “groove” coats, primers, 

stains, basecoats, inks and topcoats. Most coatings are applied by direct roll coating, 

with filler being applied by reverse roll coating. Other coating methods include offset 

rotogravure, spray techniques, brush coating and curtain coating. A typical flat wood 

paneling coating line includes a succession of coating operations, which begins with 

mechanical alterations of the substrate (filling of holes, cutting of grooves, sanding, 

etc.), followed by the coating operations, and packaging or stacking for shipment. 

VOC emissions from a flat wood coating facility occur primarily at the coating line, with 

some emissions also occurring at paint mixing and storage areas. To assist facilities 
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and regulatory agencies in estimating emissions, VOC emissions factors for 

conventional solvent based applied to interior printed panels are as follows (expressed 

as kilograms of VOC per 100 square meters coated): 3.0 for filler, 0.5 for sealer, 2.4 for 

basecoat, 0.3 for inks, and 1.8 for topcoats. 

Available Controls to Meet the CTG Standards 

• Low-VOC, waterborne coatings are generally available and are not produced and 

marketed specifically for flat wood paneling industry. Conversion to waterborne 

coatings can lower the VOC emissions greatly. Most coating operations are capable 

of converting to waterborne coatings. 

 

• Ultraviolet Cure and Electron Beam Cure coatings involve change in process, which is 

an alternative to using waterborne coatings. A VOC reduction of near 100 percent is 

achievable through the use of such coatings. 

• Add-on Controls such as thermal oxidizers or carbon adsorption could be use to 

reduce emissions especially for applications where performance requirements or 

other needs dictate the use of high-VOC coatings that do not meet the CTG coating 

VOC content limits. 

Recommended Control Options 

EPA recommends emission limits for inks, coatings and adhesives used by the flat 

wood paneling coating facilities as well as work practices for cleaning materials used. 

The recommended emissions limits for inks, coatings, and adhesives can be achieved 

either by using materials with VOC contents low enough to achieve the limits during 

application, or by reducing the amount of VOC emitted through the use of add-on 

controls. Table 5 summarizes the coating VOC content limits recommended in this 

CTG. 
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Table 5 – CTG VOC Limits for Flat Wood Paneling Coating Operations 

 Surface Coatings, Inks, or Should Meet One of These Emission Limits: 

Adhesives Applied to the 

Following Flat Wood 

Paneling Categories 

lb VOC per 

gallon material 

(grams VOC per 

liter material) 

[Excluding water 

and exempt 

compounds] 

lb VOC per 

gallon solids 

(grams VOC per 

liter solids) 

Overall Control 

Efficiency Using an 

Add-On Control 

Device: 

Printed interior panels made 

of hardwood plywood, or thin 

particleboard 2.1 (250) 2.9 (350) 90% 

Natural finish hardwood 

plywood panels 2.1 (250) 2.9 (350) 90% 

Class II finishes on 

hardboard panels 2.1 (250) 2.9 (350) 90% 

Tileboard 2.1 (250) 2.9 (350) 90% 

Exterior siding 2.1 (250) 2.9 (350) 90% 

The CTG establishes work practice standards to reduce VOC emissions from coating 

operations. The standards include the following requirements: 

• Storing all VOC-containing coatings, thinners, cleaning materials, and waste 

materials in closed containers. The containers shall remain closed at all times, 

except when specifically in use. 

• Closing mixing vessels that contain VOC coatings and other materials, except 

when specifically in use. 

• Minimizing spills of any VOC-containing materials and clean up spills immediately. 

• Conveying VOC-containing materials in closed containers or pipes. 

. 

There are 80 facilities in the United States that produce flat wood paneling products, 

per the 2002 National Emissions Inventory (NEI). Of the 80 facilities producing flat wood 

paneling products, 24 are located in ozone nonattainment areas (based on the April 

2006 designations) and meet the standards presented in this CTG. Of those 24 facilities 

one is in California, that one being in Placer County. Upon further research by the EPA 

two facilities were found in California that produce flat wood paneling, both of them are 

located in the South Coast District. Information on flat wood paneling coatings facilities 

in the South Coast area of California was not contained in the 2002 NEI database, and 

was therefore left out of Table 7. However, no flat wood paneling manufacturing 

company is located in the San Joaquin Valley Air Basin. 
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EPA used the 2002 NEI as the source of emissions data and statistical information 

concerning the flat wood paneling industry as a whole. Plants are located throughout 

the United States, with the largest number of facilities on the Pacific Coast and in the 

Southern States. Table 6 summarizes where the flat wood paneling coating facilities are 

located, as well as the associated Local and State Requirements. 

Table 6 - Flat Wood Paneling Coating Facilities in Current Nonattainment Areas and 

Associated State or Local Requirements (Based on 2002 NEI)

Ozone 

Nonattainment 

Area 

Number 

of 

Facilities

Product Applicability Applicable State 

Emission Limit 

Alternative Control 

Device Limits 

Placer County 

(California) 

1 1978 CTG 

Not applicable to exterior siding. 

<2.1 lb VOC per 

gallon of coating 

(excluding water) 

Overall control efficiency 

of 90% 

Michigan 1 Interior paneling. Not applicable to 

exterior siding, cabinetry, furniture or 

tileboard. 

1978 CTG Limits 1978 CTG Limits 

North Carolina 1 1978 CTG 

Not applicable to exterior siding and 

tileboard. 

1978 CTG Limits 1978 CTG Limits 

Ohio 1 No rule specific to flat wood, wood 

building products or tileboard. 

1978 CTG Limits 1978 CTG Limits 

South Carolina 1 Wood construction products for 

interior paneling. Not applicable to 

exterior siding and tileboard. 

1978 CTG Limits 1978 CTG Limits 

Texas 2 Interior paneling and tileboard. 

Not applicable to exterior siding. 

1978 CTG Limits 1978 CTG Limits 

Virginia 1 Interior panels 

Not applicable to exterior siding and 

tileboard. 

1978 CTG Limits 1978 CTG Limits 

Indiana 3 Interior panels Not applicable to 

exterior siding and tileboard. 

1978 CTG Limits 1978 CTG Limits 

Tennessee 1 Interior paneling. Not applicable to 

exterior siding and tileboard. 

1978 CTG Limits 1978 CTG Limits 

Illinois 1 None None None 

Pennsylvania 8 None None None 

New Hampshire 2 None None None 

Wisconsin 1 1978 CTG Limits Not 

applicable to exterior siding and 

tileboard. 

1978 CTG Limits 1978 CTG Limits 
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E. Proposed Amendments to Rule 4606 

Affected Sources 

Based on research of the District’s permit database and observations of District 

Compliance Division inspectors, staff concluded that there is no flat wood paneling 

manufacturing in the San Joaquin Valley at this time. This supports the information 

presented by EPA that there are no facilities within the boundaries of the District subject 

to this CTG. Although, there is no flat wood paneling manufacturing and coating 

operation in the District, staff is proposing to amend Rule 4606 to regulate the 

emissions from this source category if such a facility starts operation in the future within 

the District. 

The following are proposed amendments to Rule 4606:

 

• Section 1.0 (Purpose) and Section 2.0 (Applicability) 

These sections would be modified to clearly indicate that the rule applies also to flat 

wood paneling coating operation instead of just wood products coating operations. This 

clarification is necessary because the current definition in the rule for wood products 

does not specifically include flat wood paneling products. 

• Section 3.0 (Definitions) 

As recommended by EPA, the definitions of Class II hardboard panel finishes, exterior 

wood siding, flat wood paneling coating operations, flat wood paneling product, 

hardwood plywood, natural finish hardwood plywood panel, panel, particleboard, printed 

interior panel, and tileboard would be included in Section 3.0. These definitions are 

similar to the definitions indicated in EPA’s 1978 CTG for Factory Surface Coating of 

Flat Wood Paneling (EPA-450/2-78-032), Placer County APCD Rule 238 (Factory 

Coating of Flat Wood Paneling), and SCAQMD Rule 1104 (Wood Flat Stock Coating 

Operations). These definitions would improve the clarity and effectiveness of the rule 

since these terms are used in the rule. 

• New Section 5.3 and New Table 3 (Flat Wood Coating Operation) 

New Section 5.3 and new Table 3 would specify the coating limits for flat wood paneling 

products coating whose VOC emissions, including related cleaning activities, at a 

stationary source are at least 15 pounds per day before consideration of controls. 

Table 3 of the rule would specify that for all flat wood paneling product categories, the 

VOC content limit of the coating should not exceed 250 grams/liter (2.1 pounds/gallon) 

of coating, excluding water and exempt compounds, as applied. Operators would need 

to keep applicable records required by Sections 6.2, 6.4, and 6.5 to demonstrate if the 

VOC emissions from flat wood paneling products coating operation exceed 15 pounds 
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per day of VOC emissions, thereby making the source operation subject to Table 3 

limits. The new coating VOC content limit is effective on and after April 16, 2009. 

New Section 5.3.2 would specify that flat wood paneling products coating operations 

whose VOC emissions, including related cleaning activities, are less than 15 pounds 

per day, before consideration of controls at a stationary source would need to comply 

with the existing applicable coatings VOC content limits specified in Sections 5.1 Tables 

1 or 2 of the current rule. This new provision is necessary to prevent relaxation of an 

existing SIP-approved rule since such sources are currently subject to the existing rule 

limits. 

• New Section 5.4.4 (VOC Control System Efficiency for Flat Wood Paneling Product 

Coating Operation): 

Existing Section 5.3 (now renumbered Section 5.4), allows an operator to install and 

operate an APCO-approved VOC emission control system in lieu of complying with the 

coatings VOC content limits. Section 5.4 specifies the criteria for an APCO- approved 

control system. The current control efficiency for wood products coating operations is 

85 percent. However, for flat wood paneling products coating operations VOC control 

system, new Section 5.4.4 would specify an overall capture and control efficiency of at 

least 90 percent by weight. 

• New Section 5.6 (Work Practice Standards for Flat Wood Paneling Product Coating 

Operation) 

This new section would specify the work practice standards for flat wood paneling 

product coating operations. The work practice standards are consistent with the CTG 

as discussed in Section IIIC of the staff report. 

• Section 6.8.5 (Determination of Overall Capture and Control Efficiency) 

As recommended by EPA, two equations would be added for calculating the capture 

efficiency and the control efficiency of a VOC emission control system. These calculation 

equations are similar to the requirements of SCAQMD Rule 1136 (Wood Products 

Coatings). 

• Compliance Schedule 

The proposed amendments to Rule 4606 would become effective on and after April 16, 

2009. Since there is no flat wood coating facilities currently operating in the San 

Joaquin Valley Air Basin, a longer compliance period is not needed. 

Existing Section 7.1 allows an operator who becomes subject to the requirements of the 

rule through loss of exemption status allowed by Section 4.0 would need to be in full 
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compliance with the rule with 12 months from the date that an exemption status is lost. 

District staff is proposing to revise Section 7.1 that would require the operator to be in 

compliance with the rule requirements effective on and after the date that the 

exemption is lost. 

IV. VOC EMISSION AND REDUCTIONS 

The ARB emissions inventory database shows that the 2008 annual baseline emission 

(grown and controlled) from metal parts and products coating operations is about 0.65 

tons of VOC per day. As discussed in Section IIIB of the Final Draft Staff Report, there 

are three large appliance parts and products and eight metal furniture coating 

operations facilities currently operating in the San Joaquin Valley that would be subject 

to the proposed amendments to Rule 4603. These facilities are already using coatings 

that meet the proposed VOC content limits, therefore no VOC emissions reduction 

would result from the proposed changes to Rule 4603. 

The ARB emissions inventory database shows that the 2008 annual baseline emission 

(grown and controlled) from wood products coating operations is about 1.3 tons of VOC 

per day. As previously mentioned, there is no flat wood paneling product manufacturing 

facility currently operating in the San Joaquin Valley Air Basin, therefore no VOC 

emissions reduction would result in the proposed amendments to Rule 4606. 

V. COST EFFECTIVENESS AND SOCIOECONOMIC ANALYSES 

Pursuant to California Health & Safety Code Section 40920.6(a), the District is required to 

analyze the cost effectiveness of new rules or rule amendments that implement Best 

Available Retrofit Control Technology (BARCT) or all feasible measure. The proposed 

amendments to Rule 4603 and Rule 4606 would add federal RACT requirements but not 

BARCT or all feasible measure, and are therefore not subject to the cost effectiveness 

analysis mandate. It is important to mention that affected sources subject to the 

proposed changes to Rule 4603 are already using coatings that comply with the proposed 

VOC limits, therefore there are no additional costs associated with the proposed 

amendments. Furthermore, since there are no sources in the District that manufacture 

flat wood paneling products, the proposed amendments to Rule 4606 would not impose 

additional compliance costs. 

Pursuant to California Health & Safety Code Section 40728.5 (a) requires the District to 

perform an assessment of the socioeconomic impacts of the adoption, amendment, or 

repeal of a rule or regulation that significantly affect air quality or emission limitation. As 

discussed above, sources subject to the proposed changes to Rule 4603 are already 

using coatings that meet the proposed limits and that there is no flat wood paneling 

products manufacturing facilities currently operating in the District, therefore the proposed 
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amendments are not expected to have any adverse impact on the regional economy of 

the San Joaquin Valley. 

VI. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA), staff investigated the 

possible environmental impacts of the proposed amendments to Rule 4603 and Rule 

4606. Based on the lack of evidence to the contrary, District staff has concluded that the 

proposed amendments to the rules will not have any significant adverse effects on the 

environment. Staff recommends filing a Notice of Exemption under the provisions of 

Public Resource Code 15061 (b)(3). 

VII. RULE CONSISTENCY ANALYSIS 

As required by California Health & Safety Code Section 40727.2, District staff prepared 

a rule consistency analysis that compares the elements of amendments with the 

corresponding elements of other District rules, federal regulations and guidelines that 

apply to the same source category or type of equipment. District staff found that none 

of the proposed requirements of these rules would conflict with federal rules, 

regulations, or policies covering similar stationary sources. The rule consistency 

analysis is presented in Appendix B of the Final Staff Report. 

VIII. RULE DEVELOPMENT PROCESS 

As part of the rule development process, in June 2008 District staff mailed copies of the 

proposed amendments to Rules 4603 and 4606 to affected sources, interested parties, 

the public, EPA and ARB to solicit their comments. In addition, the notice of the 

proposed amendments to the rules was also published in a general circulation 

newspaper in each of the eight San Joaquin Valley counties. The commenting deadline 

ended on July 24, 2008. Comments received during the rule development process 

were incorporated into the rule amendments as appropriate. Comments received and 

District responses are discussed in Appendix A of the Final Draft Staff Report dated 

September 18, 2008. 

District staff submitted the proposed rules to the District Governing Board for adoption 

on October 16, 2008. The notice of the public hearing for the proposed rules was 

published in a general circulation newspaper in each of the eight San Joaquin Valley 

counties and was mailed to affected source, interested parties, the public, EPA and 

ARB. The public notice solicited written comments to be submitted by mail, and it also 

identified the name and telephone number of the District staff who can answer 

questions and respond to comments. The commenting deadline ended on September 
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29, 2008. Comments received during the rule development process were incorporated 

into the rule amendments as appropriate. Comments received and District responses 

are discussed in Appendix A of the Final Staff Report dated October 16 16, 2008. 

 

IX. REFERENCES 

1. EPA CTG for Large Appliance Coatings (EPA 453/R-07-004), September 2007. 

2. EPA CTG for Metal Furniture Coatings (EPA 453/R-07-005), September 2007. 

3. EPA CTG for Flat Wood Paneling Coatings (EPA 453/R-06-004), September 

2006. 

4. EPA 450/2-78-032 (Control of Volatile Organic Emissions from Existing 

Stationary Sources, Volume VII: Factory Surface Coating of Flat Wood 

Paneling). 

5. South Coast Air Quality Management District (SCAQMD) Rule 1104 (Wood Flat 

Stock Coating Operations). 

6. SCAQMD Rule 1107 (Coating of Metal Parts and Products). 

7. Placer County Air Pollution Control District Rule 238 (Factory Coating of Flat 

Wood Paneling).