7/06 Rule 74.30 : 1 VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT

RULE 74.30 - WOOD PRODUCTS COATINGS (Adopted 5/17/94, Revised 9/10/96, 11/11/03, 6/27/06)

A. Applicability

The provisions of this rule apply to an y person who manufactures, supplies, uses, or specifies the use of wood products coatings for commercial use.

B. Requirements

1. For either a new wood product or new pr oduct made of simula ted wood materials, no person shall use any coating that has an ROC (reactive organic compound) content, as applied, exceeding the applicable limit specified below:

ROC LIMITS

Grams Per Liter and Pounds per Gallon of Coating, Less Water and Exempt Compounds

On and After

7/1/1996

COATING (g/L) (lb/gal)

Clear topcoats..................................................................................275 (2.3) Filler................................................................................................275 (2.3) High-solid Stains.............................................................................240 (2.0) Inks..................................................................................................500 (4.2) Mold-seal Coating...........................................................................750 (6.3) Multi-colored Coating.....................................................................275 (2.3) Pigmented Coating..........................................................................275 (2.3) Sealer...............................................................................................240 (2.0)

ROC LIMITS

Grams Per Liter of Material

On and After

7/1/1996

COATING (g/L) (lb/gal)

Low-solids Stains, ..........................................................................120 (1.0) Toners, or Washcoats7/06 Rule 74.30 : 2 2. For a refinishing operation necessary to repair, preserve, or restore a wood product, no person shall use any coating th at has an ROC content, as applied, exceeding the applicable limit specified below:

ROC LIMITS

Grams Per Liter and Pounds per Gallon of Coating, Less Water and Exempt Compounds

On and After

7/1/1995

COATING (g/L) (lb/gal)

Clear topcoat ...................................................................................680 (5.7) Filler................................................................................................500 (4.2) High-solid Stains.............................................................................700 (5.8) Inks..................................................................................................500 (4.2) Mold-seal Coating...........................................................................750 (6.3) Multi-colored Coating.....................................................................680 (5.7) Pigmented Coating..........................................................................600 (5.0) Sealer...............................................................................................680 (5.7)

ROC LIMITS

Grams Per Liter of Material

On and After

7/1/1995

COATING (g/L) (lb/gal)

Low-solids Stains, Toners, or Washcoats .......................................480 (4.0)

3. No person shall use any st ripper on wood products unless:

a. The ROC content is 350 grams per liter (2.9 lb/gal) of material or less; or

b. The ROC composite partial pr essure of the stripper is 2 mm Hg (0.04 psia) or less at 20 o C (68 o F).

4. No person shall apply coatings to w ood products unless the coating is applied with properly operating equipment, accord ing to proper operating procedures, and by the use of one of the following methods:

a. electrostatic application, operated at a minimum of 60 KV;

b. flow coat;7/06 Rule 74.30 : 3 c. dip coat;

d. high-volume, low-pressure (HVLP) spray;

e. paint brush;

f. hand roller;

g. roll coater; or

h. such other coating application methods as are demonstrated to the APCO to be capable of achieving at least 65 percent transfer efficiency, and for which written approval of the APCO has been obtained.

5. Surface Preparation and Cleanup Solvent

a. After September 25, 2006, no person shall use a material for surface preparation that has an ROC cont ent exceeding 25 grams per liter of

material.

On or before September 25, 2006, no person shall use ROC-containing materials which have more than 200 gr ams of ROC per liter of material for surface preparation.

b. After September 25, 2006, no person shall use a material for either spray equipment cleaning or cleanup that has an ROC content exceeding 25 grams per liter of material.

On or before September 25, 2006, no person shall use ROC-containing materials for spray equipment cleaning unless:

1) The system used:

a) Is an enclosed gun washer or "low emission spray gun cleaner" that has been approved in writing by the APCO and is properly used for cleaning; or

b) Has been demonstrated to th e APCO to be as effective as the equipment described in the subparagraph above in minimizing the loss of the ROC-containing material to the atmosphere according the test method in Subsection E.4.

2) The ROC composite par tial pressure of organi c solvent used is less than 45 mm Hg at a temperature of 20 o C.7/06 Rule 74.30 : 4 c. On or before September 25, 2006, no person shall use ROC-containing materials for cleanup unless the ROC com posite partial pre ssure of organic solvent used is less than 45 mm Hg at 20 o C.

6. In lieu of the requirements of Subsec tions B.1, B.2, B.3 and B.4, emissions of ROC, excluding emissions from clean up operations, may be controlled by an emission capture and control system, which reduces ROC emissions to the atmosphere, pr ovided that:

a. During any period of continuous operation not to exceed 24 hours, the capture and control system shall have a combined efficiency of at least 90 percent, by weight.

b. The collection system shall vent a ll drying oven exhaust to the control device and shall have one or more inlets for collection of fugitive

emissions.

c. During any period of operation of a thermal incinerator, combustion temperature shall be continuously monitored.

d. During any period of operation of a catalytic incinerator, exhaust gas temperature shall be continuously monitored.

e. Written approval for such equipment, in the form of an Authority to Construct and Permit to Operat e, is received from the APCO.

7. Storage of ROC-containing materials: All ROC containing materials, including, but not limited to surface coatings, clea nup solvents, or surface preparation

materials shall be stored in closed c ontainers which are nonabsorbent and do not

leak.

8. No person shall specify the use in the Dist rict of any coating to be applied to any wood products subject to the provisions of this rule that does not meet the limits and requirements of this rule.

9. The manufacturer of any coating or strippe r subject to this rule shall designate on the coating container or on separate data sheet(s) the maximum VOC content of the coating, as supplied. The VOC conten t, except for low-solids stains, toners, and washcoats, shall be expressed as grams per liter of coating (less water and less exempt organic compounds).

10. Cleaning and Stripping Material Comp liance Statement: The manufacturer of liquid cleaning materials or st rippers subject to this ru le shall designate on product

labels or data sheets the ROC content and ROC Compos ite Partial Pressure of cleaning materials as supplied. This de signation shall incl ude recommendations7/06 Rule 74.30 : 5 regarding mixing with any other ROC c ontaining materials, and express the cleaning material ROC content when used in accordance with the manufacturer's

recommendations. All lette rs and numbers used to designate ROC or VOC content on product labels sha ll be visible and legible. (Effective September 10, 1997)

C. Exemptions

1. The provisions of this rule shall not apply to aerosol coating products.

2. Sections B.1, B.2, B.3, B.4, and B.5 of this rule, shall not apply to any stationary source that emits less than 200 pounds of ROC in every rolling period of 12 consecutive calendar months from wood pr oducts coating operations. Any person claiming this exemption shall maintain monthly records to substantiate this claim. Emissions from aerosol products, cold clean ers, and vapor degr easers shall not be

included in this determination.

3. This rule shall not apply to the coating of building appurtenances such as cabinets, shutters, fences and handrails coated at the site of permanent installation.

4. The limits in subsection B.1 and B.2 for Pigmented Coatings, Fillers, Washcoats, Sealers and Clear Topcoats shall not a pply to the coating of wooden musical

instruments.

D. Recordkeeping Requirements.

Any person subject to this rule shall:

1. Maintain a current file for each coating in use and in storage. The file shall

include a data sheet or material lis t giving material name, manufacturer identification, specific mixing instruc tions, and ROC content as applied.

2. Maintain a current file for each solvent and stripper in use and in storage. The file

shall include a data sheet or material list giving ma terial name, manufacturer identification, ROC content and, if required, ROC com posite partia l pressure.

3. Maintain records on a daily basis showin g the amount of coatings, strippers, and solvents used. Itemize each coating, stripper, and solvent and use the specific ROC content and density value for each. If only compliant coatings, strippers and solvents are used, these records may be kept on a monthly basis.

4. If compliance is achieved through the us e of emission control equipment maintain daily records of key system operating para meters and maintenanc e procedures that demonstrate continuous operation and comp liance of the emission control system during periods of emission producing activities. Key sy stem operating parameters7/06 Rule 74.30 : 6 for emission control equipment are those necessary to ensure compliance with ROC content of coating requi rements such as temperatur es, pressures, and flow

rates.

5. Inventory, usage, and emission contro l equipment operation records shall be retained for a minimum of two years and shall be made available to District personnel upon request.

E. Test Methods

1. Measurement of the ROC content of coa tings, strippers, and solvents shall be conducted and reported in accordan ce with EPA Reference Method 24, “Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Su rface Coatings,” and ARB Method 432,

“Determination of Dichloromethane a nd 1,1,1-Trichloroethan e in Paints and Coatings,” for determination of exempt compounds as necessary.

2. ROC composite pressure shall be calculated using a widely accepted published source such as: Boublik, T., V. Fried and E. Hala, "The Vapor Pressure of Pure Substances," Elsevier Sc ientific Publishing Co., New York (1973), Perry's Chemical Engineer's Handbook, McGraw-Hill Book Company, CRC Handbook of Chemistry and Physics, Chemical Rubber Publishing Company (1986-87), and Lange's Handbook of Chemistry, John A. Dean, editor, McGraw-Hill Book Company (1985). The true vapor pressu re of a component in a mix may be determined by ASTM Method D2879-86. The ROC composite pressure of a solvent mix consisting entirely of ROC may be determined by ASTM Method

D2879-86.

3. Transfer efficiency shall be determined in accordance with South Coast Air Quality Management District method Spra y Equipment Transfer Efficiency Test Procedure for Equipment User, May 24, 1989.

4. The active and passive solvent losses fro m spray gun cleaning systems shall be determined using South Coast Air Quality Management District's "General Test Method for Determining Solvent Losses fro m Spray Gun Cleaning Systems" dated October 3, 1989 or later. The test solven t for this determin ation shall be any lacquer thinner with a minimum ROC compos ite partial pressure of 105 mm Hg at

20 o C. The minimum test temperature shall be 15 o C.

5. Capture efficiency shall be determined according to EPA Guidelines for Determining Capture Efficiency, dated January 9, 1995, and 40 CFR 51, Appendix M, Methods 204-204F as applicable. Control system efficiency shall be determined by 40 CFR 60, Appe ndix A, Methods 18, 25 or 25A.7/06 Rule 74.30 : 7 6. High Volume-Low Pressure (HVLP) equipment shall be identified by either test air cap measurements or an inlet pressu re measurement that, when used with specifications published by the manufactur er, establishes that gun is being operated as specified in Subsection G.16.

F. Violations

Failure to comply with any provision of this rule, including recor dkeeping requirements,

shall constitute a violation of this rule.

G. Definitions

For the purposes of this rule, the following definitions shall apply:

1. "Active Solvent Losses": The active solvent losses are the emissions during all steps of a spray gun equipment cleaning operation and are expr essed in units of grams of solvent loss per cleaning cycle.

2. "Aerosol Coating Product"; A pressurize d coating product containing pigments or resins that dispenses product ingredie nts by means of a propellant, and is packaged in a disposable can for hand held application, or for use in specialized equipment for ground traffi c/marking applications.

3. "Binders": Nonvolatile polymeric organic material s (resins) which form the surface film in coating applications.

4. "Clear Topcoat": A final coating which contains binders, but not opaque pigments, and is specifically formulated to form a transparent or translucent solid protective film.

5. "Cleanup": The removal of uncured coating from any surface.

6. "Coating": A material which is applie d to a surface and which forms a film in order to beautify and/or protect such surface.

7. "Dip Coat": Dip an object into a vat of coating material and drain off any excess coating.

8. "Electrostatic Application": Charging of atomized paint droplets for deposition by electrostatic attraction.

9. "Exempt Organic Compounds": As defined in Rule 2, Definitions, of these Rules.

10. "Filler": A composition that hardens on dryi ng used to fill pores, cracks, or holes in a wood product prior to finishing.7/06 Rule 74.30 : 8 11. "Flow Coat": Coat an object by flowin g a stream of coating over an object and draining off any excess coating.

12. "Grams of ROC per Liter of Coa ting, Less Water and Exempt Organic Compounds": The weight of ROC per combined volume of ROC and coating solids calculated using the following equation:

Grams of ROC per Liter of Coating, Less Water and Exempt Organic Compounds = Ws - Ww - Wes

Vm - Vw - Ves

Where: Ws = weight of volatile compounds in grams Ww = weight of water in grams Wes = weight of exempt organic compounds in grams

Vm = volume of material in liters

Vw = volume of water in liters Ves = volume of exempt organic compounds in liters

13. "Grams of ROC per Liter of Material ": The weight of ROC per volume of

material shall be calculated by the following equation:

Grams of ROC per Liter of Material = Ws - Ww - Wes

Vm

Where: Ws = weight of volatile compounds in grams Ww = weight of water in grams Wes = weight of exempt organic compounds in grams

Vm = volume of material in liters

14. "Gun Washer": Electrically or pneumatica lly operated system that is designed to clean spray application equipment while enclosed. A gun washer may also be considered a gun cleaning system that consists of spraying solvent into an enclosed container using a snug fitting.

15. "High-solids Stains": Stains containing more than 1 pound of solids per gallon, by weight, and can include wiping stains, glazes, and opaque stains.

16. "High Volume-Low Pressure (HVLP)": Equipment used to apply coatings by means of a spray gun designed to be operated and operate d between 0.1 and 10 pounds per square inch gauge (psig) air pressure measured dynamically at the center of the air cap and at the air horns.

17. "Ink": A fluid, containing dyes and/or co lorants, used to make markings but not used to protect surfaces.7/06 Rule 74.30 : 9 18. "Low Emission Spray Gun Cleaner": An y properly used spray equipment cleanup device which has passive so lvent losses of no more than 0.6 grams per hour and

has active solvent losses of no more than 15 grams per operating cycle as defined by the test method in Subsection E.4.

19. "Low-solids Stains": Stains containi ng 1 pound of solids per gallon, or less, by weight.

20. "Mold-seal Coating": The initial coating applied to a new mold or repaired mold to provide a smooth surface that, when coated with a mold release coating, prevents products from sticking to the mold.

21. "Multi-colored Coating": A coating whic h exhibits more than one color when applied, and which is packaged in a single container and applied in a single coat.

22. "New Wood Product": A wood product or simulated wood pr oduct which has not been previously coated and from which cu red coatings have not been removed. A wood product or simulated w ood product from which uncured coatings have been removed to repair flaws in initial coatings applica tion is a new wood product.

23. "Passive Solvent Losses": The passive solvent losses are the emissions from spray gun cleaning equipment when the equipment sits idle between cleaning cycles and are a result of natural evaporation from the equipment.

24. "Pigmented Coatings": Opaque coa tings which contain binders and colored pigments which are formulated to hide th e wood surface, either as an undercoat or
topcoat.

25. "Reactive Organic Compound (ROC)": As defined in Rule 2, Definitions, of these rules. The term "volatile organi c compound (VOC)" is equivalent to ROC.

26. ROC Composite Par tial Pressure": The sum of the partial pressures of the compounds defined as ROCs. ROC composite partial pressure is calculated as

follows:



## ( ) ( ) ( )

PP W VP

MW

W

MW W

MW W

MW c i i

i i n

w

w e

e e n i

i i n =       +       +       =

= = 

# ∑ ∑ ∑ 1

1 1

Where:

W i = Weight of the "i"th ROC compound, in grams

W w = Weight of water, in grams

W e = Weight of the "e"th exempt organic compound, in grams

MW i = Molecular weight of the "i"th ROC compound, in g/(g-mole)7/06 Rule 74.30 : 10 MW w = Molecular weight of water, in g/(g-mole)

MW e = Molecular weight of the "e"th ex empt organic compound, in g/(g-mole)

PP c = ROC composite partial pre ssure at 20 C, in mm Hg

VP i = Vapor pressure of the "i"th ROC compound at 20 C, in mm Hg.

27. "Refinishing Operation": The steps nece ssary to remove cured coatings and to repair, preserve, or restore a wood product.

28. "Repair Coating": A coating used to recoat portions of a product which has sustained mechanical damage to the coating following normal painting operations.

29. "Roll Coater": A series of mechanical rollers that forms a thin coating film on the surface of roller, which is applied to a substrate by moving the substrate

underneath the roller.

30. "Sealer": A coating, containing binders , which seals the wood prior to application of the subsequent coatings.

31. "Simulated Wood Materials": Materials, such as formi ca, glass, metal, plastic, etc., that are made to give a wood-lik e appearance or are processed like a wood product.

32. "Stencil Coating": An ink or a pigmente d coating which is rolled or brushed onto a template or stamp in or der to add identifying lette rs and/or numbers to wood products.

33. "Stripper": A liquid used to remove cured coatings, cured inks, and/or cured

adhesives.

34. "Surface Preparation": Cleaning of a s ubstrate to remove dirt, oils, and other contaminants. Surface preparation does not include stripping. Surface preparation is typically done prior to the application of surface coatings, adhesive bonding materials, or sealants.

35. "Toner": A wash coat which contains binde rs and dyes or pigments to add tint to

a coated surface.

36. "Touch up Coating": A coating used to cover minor coa ting imperfections appearing after the ma in coating operation.

37. "Transfer Efficiency": The ratio of th e weight of coating solids deposited on an object to the total weight of coating solids used in a coating application step, expressed as a percentage.7/06 Rule 74.30 : 11 38. "Wash Coat": A coating that contains no more than 1.0 pound of solids per gallon, by weight, which is used to seal wood surfaces, prevent undesired staining, and control penetration.

39. "Wood Products": Those surface-coated room furnishings including cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, and art objects; and any other coated objects made of solid wood, and/or wood composition, and/or

made of simulated wood material used in combin ation with solid wood or wood composition.

40. "Wood Product Coating Application Opera tions": A combination of coating application steps which may include use of spray guns, flash-off areas, spray booths, ovens, conveyors, and/or other equipment operated for the purpose of applying coating materials.