# Eastern Kern Air Pollution Control District



# Rule 410.9

WOOD PRODUCTS SURFACE
COATING OPERATIONS

FINAL STAFF REPORT

March 13, 2014

Prepared by 

### Cherita Young Air Quality Engineer I

Eastern Kern Air Pollution Control District 2700 “M” Street, Suite 302 Bakersfield, California 93301 (661) 862-5250  www.kernair.org

### Table of Contents

I. BOARD AD OPTION .......................................................................... 1

II. INTROD UCTION ............................................................................... 1

III. RACT BA CKGRO UND ...................................................................... 1

IV. RULE DEVE LOPMENT ..................................................................... 2

V. APPLICAB ILITY................................................................................. 3

VI. REQUIR EMENTS.............................................................................. 4

VII. EXEMPT IONS ................................................................................... 5

VIII. ADMINISTRATI VE REQUIREM ENTS............................................... 6

IX. TEST ME THODS............................................................................... 6

X. RULE CONSISTE NCY ANAL YSIS.................................................... 6

XI. VOC RED UCTIONS .......................................................................... 7

XII. ECONOMIC IMPACTS ...................................................................... 8

XIII. ENVIRONMEN TAL IMPAC TS ........................................................... 9

XIV. SOCIOECONO MIC IMPAC TS........................................................... 9

TABLE 1 WOOD PRODUCTS MANUFACTURING SIC.................... 3

TABLE 2 VOC CO NTENT LI MITS..................................................... 4

TABLE 3 VOC CO NTENT LI MITS..................................................... 5

TABLE 4 AVERAGE CALIFO RNIA EMI SSIONS............................... 8

APPENDIX A RULE 410.9, WOOD PRODUCTS
SURFACE COATING OPERATIONS

APPENDIX B RESPONSE TO COMMENTS410.9 Final Staff Report

I. BOARD ADOPTION

Rule 410.9, Wood Products Surface C oating Operations was adopted by the
Eastern Kern Air Pollution Control Distric t (District)’s Governing Board on March 13, 2014 at its regular Board m eeting in Rosamond California.

Rule 410.9 became effectiv e and enforceable upon adoption. A copy of the Rule
has been submitted to the California Air Re sources Board (ARB) for their review
and then to be forwarded to the U.S. En vironmental Protection Agency (EPA) for
inclusion into the State Im plementation Plan (SIP).

II. INTRODUCTION

Rule 410.9 is designed to reduce vola tile organic compound (VOC) emissions from wood product coatings, and from t he cleaning, storage, and disposal of organic solvents and waste solvent materi als associated with the use of wood product coatings. Rule 410.9 will also provide administrativ e requirements for recording and measuring VOC emissions.

On November 6, 2013 the District held a public rule development workshop at the Mojave Veteran's Building in Mojave, CA. At this workshop District staff presented proposed Draft Rule 410.9, Wood Products Surface Coating Operations. The District submitted copies of the proposed rule to ARB and EPA for an initial review prior to the wor kshop. A 30-day public review and comment period followed the workshop.

District received comments and sugges ted changes from EPA, ARB, and industry. District considered all comments and suggested changes.

Appendix A is a copy of Adopted Rule 410.9, Wood Products Surface Coating Operations.

Appendix B is the District’s Response to Comments following the November 6, 2013 public workshop held at the Mojave Veteran’s Center in Mojave, CA.

III. RACT BACKGROUND

The Clean Air Act (CAA) as amended in 199 0 requires that St ate Implementation Plans (SIP's) for certain ozone nonattainment areas be revised to require implementation of Reasonably Available Control Technology (RACT) to limit VOC emissions. The U.S. 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 . Section 183(a)(3) and Section 183(g)(3)of the CAA required the EPA Administrator to issue a Control

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Techniques Guideline (CTG) that present s feasible RACT control measures for VOC emissions from coatings and solvents used in Wood coatings

.

The CTG is intended to provide State and local air pollution control authorities with an information base for proceeding with analyses of RACT for their own regulations. The CTG contains a re view of current knowledge and data concerning the technology, impacts, and co sts associated with various emission control techniques. Where applicable, the EPA recommends that States adopt requirements consistent wit h the presumptive RACT. However, these measures are only a recommendation; States may develop their own RACT requirements

that consider economic and technical circumstances. No Federal law or regulation precludes States from requiring more stri ngent controls than those
recommended as RACT.

IV. RULE DEVELOPMENT

Rule 410.9 applies to wood product su rface coating and adhesion operations. Surface coatings are designed to protec t wooden surfaces from the environment, heat, abrasion, and chemicals. There are th ree types of coatings included in the coating application process which are:

1. An enhancement of the grain using a stain to add color to the wood;

2. Application of a sanding sealer prior to the coating operations; and

3. Application of a clear topcoat to form a transparent or translucent solid protective film.

Surface coating adhesion operations ut ilize compounds to adhere (join) wood and other materials to wood products. Surface coating and adhesion processes utilize the following processes: surface preparation, coating application, drying, and clean-up.

In an effort to maintain rule consisten cy within the area, Distr ict staff reviewed the following SIP approved rules fr om adjacent air districts:

 Antelope Valley Air Quality Managem ent District (AVAQMD), Rule 1136;

 San Joaquin Air Pollution Control District (SJVAPCD), Rule 4606.

 South Coast Air Quality Management District (SCAQMD), Rule 1136; and

In order to promote regulat ory uniformity throughout Kern County, Rule 410.9 is primarily based on SJVAPCD's Rule 46 06, Wood Products and Flat Wood Paneling Products Coating Oper ations amended October 16, 2008.

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V. APPLICABILITY

Requirements of Rule 410. 9 shall apply to commercial wood produc ts coating operations. This rule will not apply to residential (noncommercial) operations.

Wood product manufacturing and rework faci lities are generally covered by the Standard Industrial Classification (SIC) c odes listed in Table 1 below. Facilities classified under other SIC codes may be subj ect to the Rule if the facility meets the definition of a major source an d the definition of a wood product manufacturing facility.

TABLE 1
WOOD PRODUCT MANUFACTURING SIC CODES

SIC Code Description

2400 Lumber and Wood Products, Except

Furniture

2430 Millwork, Veneer, Plyw ood, and Structural

Wood

2431 Millwork, doors, and molding

2435 Hardwood Veneer and Plywood

2436 Softwood Veneer and Plywood

2440 Wood Containers

2490 Miscellaneous Wood Products

2491 Wood Preserving

2492 Particleboard

2493 Reconstituted Wood Products

2499 Wood Products, Not Elsewhere Classified

2510 Household Furniture

2511 Wood Household Furniture, Except Upholstered

2512 Wood Household Furniture, Upholstered

2517 Wood Television, Radio, phonograph, and Sewing Machine Cabinets

2521 Wood Office Furniture

2541 Wood Office and Store Fixtures, Partitions, Shelving, and Lockers

2512 Wood Household Furniture, Upholstered

3940 Dolls, Toys, Games and Sporting and

Athletic

3995 Burial Caskets

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VI. REQUIREMENTS

Section V of Rule 410.9 contains the compliance requirements associated with wood product coatings oper ations, which include:

 Table of Standards - VOC Content Limits

 Coating Applicati on Equipment Cleaning

 Coating Strippers

 Storage and Disposal of VOC Containing Materials

 Application Equipment Requirements

 VOC Emission Control System

 Prohibition of Solicitation

Table of Standards

With the exception of the exemptions listed in Section IV of Rule 410.9, an operator shall not apply to any wood produc t, any coating, aerosol, or adhesive with a VOC content as applie d, that exceeds the applic able limit specified in

Tables 2 or Table 3.

TABLE 2
VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION

VOC Content Limits Express ed in Grams per Liter Less Water and Exempt Compounds

Content Category VOC Limit g/l VOC Limit lb/gal

1. Clear Topcoat 275 2.3

2. Clear Sealers 240 2.3

3. Filler 275 2.3

4. High-Solids Stain 240 2.0

5. Ink 500 4.2

6. Mold-Seal Coating 750 6.3

7. Multi-Colored Coating 275 2.3

8. Pigmented Coating 275 2.3

9. Sanding Sealer 240 2.3

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TABL E 3
VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION

VOC Content Limits Express ed in Grams per Liter of Material, as Applied

VOC Content Category VOC Limit g/l VOC Limit lb/gal

1. Low-Solids Stain 120 1.0 2. Stripper 350 2.9

Coating Substitutions

Wood coatings are known to contain hazar dous air pollutants such as xylenes, toluene, ethyl benzene, ethylene glycol monobutyl ether and ot her glycol ethers, methyl ethyl ketone (MEK), methyl isobut yl ketone (MIBK), methanol, styrene and formaldehyde. No-HAP and Low-HAP c oatings contain no to low level hazardous air pollutants (HAPS), such as waterborne, high-solids UV cured and powder coatings. Waterborne and high so lids materials are generally used for coating substitutions.

Such coatings are suitable for certain app lications, but not all. Paint suppliers and the wood product industry generally have targeted high volume materials for reformulation efforts. Therefore, lowe r VOC formulations may not available for most of the low volume specialty coating categories.

Equipment Changes

The principal technique used by the w ood products industry to control VOC emissions from coating application and cl eaning is product substitution, which

eliminates or reduces t he generation of emissions. Emission reduction is obtained using less energy and producing le ss waste than using a control device

to achieve the same emission reductions.

The wood products industry has implem ented several equipment changes that directly reduce the level of VOC emi ssions. While there are equipment changes
that effect emissions from every process, the three changes predominantly used in the industry are high volume, low pressure spray (HVLP), electrostatic application, and hand rolling.

VII. EXEMPTIONS

Rule 410.9 details a number of VOC containing product s that are exempt from the VOC content requirement s listed in Table 2 and Table 3. These exemptions

include:

 Residential noncommercial operations.

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 Small wood products coating operations (< 20 gallons usage/year).

 Coating of wooden musical instruments.

 The application of coatings by temp late (to add designs, letters or numbers to wood products).

 Refinishing, replacement, and custom replica furniture c oating operations.

 Aerosol-spray coatings us ed for touch up and repair.

 Specific types of finishes (imitati on wood grain, crackle lacquers, and faux and leaf finishes).

 Architectural coatings

VIII. ADMINISTRATIVE REQUIREMENTS

Rule 410.9 contains an extensive list of the Administrative Requirements. Please see Section VI, Administrative Requirem ents of Appendix A for complete details.

IX. TEST METHODS

Rule 410.9 contains a number of specific test methods that must be followed in order to ensure compliance with the ru le. See Section VII of Appendix A.

X. RULE CONSISTENCY ANALYSIS

Pursuant to Section 40727.2 of the Califor nia Health and Safety Code, prior to adopting, amending, or repealing a rule or regulation, the District is required to perform a written analysis that identifies and compares the air pollution control elements of Rule 410.9 with the corresponding elements of existing or proposed District and EPA rules, regulations, and guide lines that apply to the same source category. Rule elements that were analyzed are emission limits or control efficiency, operating parameters and work practices, monitoring and testing, and recordkeeping and reporting requirements.

Results of Consistency Analysis

District Rules

Facilities subject to Rule 410.9 could also be subject to the following rules:

Rule 410, Organic Solvents Rule 410.2, Disposal and Evaporation of Solvents Rule 410.3, Organic Solvent Degreasing Operations Rule 410.7, Graphic Arts Rule 411, Storage of Organic Liquids Rule 422, New and Modified Stationary Source Review Rule Rule 423, National Emissions Standar ds for Hazardous Air Pollutants

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EPA Rules and Regulations

A. EPA-Control Technique Guidelines (CTG)

1. CTG EPA-453/R-96-007 1996/04 applies to Control of Volatile Organic Compound Emissions from Wood Fu rniture Manufacturing Operations located in marginal, moderate, serious or severe ozone nonattainment areas that has the potential to em it greater than or equal to 25 tons/y ear of VOC, and equal to greater than 10 tons/year of VOC fo r extreme ozone nonattainment areas. Rule 410.9 is more stringent than t he CTG limits (CTG was developed in 1996). Therefore, District Rule 410. 9 is more stringent than the CTG.

2. CTG EPA 453/R-06-004 applies to Control Techniques Guidelines Flat Wood Paneling Coatings operations located in marg inal, moderate, serious or

severe ozone nonattainment areas that have the potential to emit greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of
VOC for extreme ozone nonattainment areas.

This CTG applies to the use of the fo llowing flat wood coatings: fillers, sealers, “groove” coats, primers, stains, basecoats, inks, and topcoats. The CTG identifies design and work practice standards for flat wood paneling, such as roll coating. The CTG also identifies add-on controls such as oxidizers and solvent recovery systems.

Rule 410.9 identifies solvent VOC c ontent limits or a control system with efficiencies of at least 90% capture and 90% control, and that would not allow more emissions than if compliant material s were utilized. For printed interior wall panels made of hardwood pl ywood and thin particleboard the recommended limitation is 2.9 kg of VOC per 100 sq. meters of coated surface; the natural finish hardwood plyw ood panel limit is 5.8 kg per 100 sq. meters; class II finish for hardboard pane ling is 4.8 kg per 100 sq. meters.

B. EPA - Alternative Control Technology (ACT)

Currently no EPA ACT guidance docum ent for wood products coating operations.

C. Standards of Performance fo r New Stationary Sources (NSPS)

Currently no NSPS guidance document for wood products coating operations.

XI. VOC REDUCTIONS

ARB emissions inventory s hows state-wide VOC emissions of 8.29 tons of VOC per day for this industry.

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TABL E 4 Annual Average Emissions for California (2009)

Category tons/day

Wood Furniture and Fabricated Products Coatings Coatings 6.91

Primer 0.13

Varnishes/Shellacs 0.03 Enamel Topcoats 0.09 Lacquer Topcoats 0.28 Oil Based Coatings 0.31 Water Based Coatings 0.01

Flatwood Products Coatings 0.00

Sealers 0.03

Stains 0.00

Varnishes/Shellacs 0.01 Topcoats 0.05

Basecoats 0.01 Water Based Coatings 0.00 Preparation Solvents Cleanup Solvents - Coatings 0.43

Total 8.29

Rule 410.9 provides a variety of VOC limits on primers, c oatings, adhesives, and sealants used in the manufacturer and refinishing of wood products and components. These are the primary contro l requirements in the rule (see Section V of Rule 410.9). Although Rule 410.9 onl y applies to a small number of sources located within the District, some degree of VOC emissions reductions will be accomplished and contribute to the Distr ict's goal of achieving attainment.

XII. ECONOMIC IMPACTS

Pursuant to California Health & Safety Code (CH&SC) §40920.6(a), the District is required to analyze the cost effectiveness of new rules or rule amendments that implement Best Available Re trofit Control Technology (BARCT) or all feasible measures. Rule 410.9 employs federal RA CT requirements but not BARCT or all feasible measures, and is therefore not s ubject to the cost effectiveness analysis

mandate.

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EKAPCD 3/13/2014 9 XIII. ENVIRONMENTAL IMPACTS

Both the California Environmental Quality Act (CEQA) and ARB policy require an evaluation of the potential adverse envir onmental impacts of proposed projects. The intent of Rule 410.9 is to protec t public health by reducing the public’s exposure to potentially harmful VOC emi ssions. An additional consideration is the impact that the rule may have on t he environment. District has determined that no significant adverse environmental impacts should occur as a result of adopting Rule 410.9.

Pursuant to the Section 15061, Subsections (2) & (3) of the CEQA Guidelines, staff will prepared and file a Notice of Ex emption for this project upon adoption.

XIV. SOCIOECONOMIC IMPACTS

CHSC Section 40728.5 exempt s districts with a populati on of less than 500,000 persons from the requirement to asse ss the socioeconomic impacts of adopted rules. Eastern Kern County popu lation is below 500,000 persons.

Remainder of Page Intentionally Left Blank

## APPENDIX A

RULE 410.9

WOOD PRODUCTS SURFACE
COATING OPERATIONS410.9 Final Staff Report

RULE 410.9 Wood Products Surface Coating Operations – Adopted 3/13/2014

I. Purpose

The Purpose of this Rule is to limit Vola tile Organic Compound (VOC) emissions from wood product surface coatings. This Rule speci fies wood coatings, storage, cleanup and disposal of organic solvents and waste solven t materials associated with the use of wood product coatings.

II. Applicability

Provisions of this Rule shall apply to surface coating of wood products.

III. Definitions

A. Air Dried : A process whereby the coated object is cured or dried at ambient

temperature or at a te mperature below 194°F.

B. Application Equipment : A device, including, but not lim ited to, a spray gun, brush, and roller, used to apply adhe sives, coatings, or inks.

C. ASTM : American Society for Testing and Materials.

D. Baked : A process whereby the coated object is heated above ambient temperature to a temperature at or above 194°F fo r the purpose of curing or drying.

E. Brush Coating : The manual application of coa tings using brushes or rollers.

F. Capture Efficiency : In percent, is the ratio of the weight of the VOC in the effluent stream entering the control device to the weight of VOC emitted from wood product coating operations, both measured simu ltaneously, and can be calculated by the following equation:

Capture Efficiency = [Wc/We] x 100 Where: Wc = weight of VOC entering control device We = weight of VOC emitted

G. Clear Sealer : A coating containing binders, but not opaque pigments, which seals the wood product prior to application of the subsequent coatings.

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

I. Coating : A material which is applied to a surface and which forms a film in order to beautify and/or protect such surface.

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J. Com posite Wood : A manufactured material consisting of tightly compressed wood fibers bonded with resins which includes, but is not limited to, particleboard, fiberboard

and hardboard.

K. Cured Adhesive , Cured Coating, or Cured Ink: an a dhesive, coating, or ink that is dry

to the touch.

L. Degreaser : A tank, tray, drum or other containe r in which objects to be cleaned are exposed to a solvent or solvent vapor in order to remove contaminants. The objects to be cleaned include, but are not limited t o, parts, products, tools, machinery, and equipment. An enclosed spray application equipment cleaning system is not a degreaser.

M. Dip Coating : The process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn after allowing the excess coating

to drain.

N. Dissolver : An organic solvent that is added to an adhesive, coating, or ink in order to melt or to liquefy solid particles.

O. EPA : United States Environmental Protection Agency

P. Filler : A material which is applied to a wood product, and whose prim ary function is to build up, or fill the voids and imperfections in the wood product to be coated. This shall not include composite wood edge filler.

Q. Grams of VOC per Liter of Coating, Less Water and Exempt Compounds : The weight of VOC content per combined volume of VOC and coating solids and can be calculated by the following equation:

Ws - Ww - Wec Grams of VOC per liter of coating, less water and exempt compounds = Vm - Vw – Vec

Where:

Ws = weight of volatile compounds (grams)

Ww = weight of water (grams)

Wec = weight of exempt compounds (grams)

Vm = volume of material (liters)

Vw = volume of water (liters)

Vec = volume of exempt compounds (liters)

R. High Gloss Coating : Any coating which achieves at least 85% reflectance on a 60 degree gloss meter when tested by ASTM Method D-523-08.

S. High-Solid Stains : Stains containing more than 1 pound of solids per gallon of material, and include wiping st ains, glazes, and opaque stains.

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T. High-Volume, Low-Pressure (HVLP) Spray Equipment : Spray equipment permanently labeled as such and which is designed and operated between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing pre ssure measured dynamically at the center of the air cap and at the air hor ns and with liquid supply pressure less than 50 psig.

U. Ink : A fluid that contains dyes and/or colora nts and is used to make markings but not to protect surfaces.

V. Liquid Leak : A visible solvent leak from a containe r at a rate of more than three drops per minute, or a visible liquid mist.

W. Low-Solid Stain : A stain containing 1 pound, or less, of solids per gallon of material.

X. Maintenance Cleaning : The cleaning of tools, form s, molds, jigs, machinery, and equipment (except coating application equi pment, ink application equipment, or adhesive application equipmen t), and the cleaning of work areas where maintenance or manufacturing occurs.

Y. Mold-Seal Coating : the initial coating applied to a new mold or repaired mold to provide a smooth surface which, when coated with a mold release coating, prevents products from sticking to the mold.

Z. Multi-Colored Coating : a coating which exhibits more than one (1) color when applied and which is packaged in a single co ntainer and applied in a single coat.

AA. Non-Absorbent Container : A container made of non-por ous material that does not allow the migration of solvents through it.

BB. Non-Atomized Solvent Flow : Solvents in the form of a liquid stream without the introduction of any propellant.

CC. Pigmented Coating : A final opaque coating which contains binders and colored pigments, and is specifically formulated to hide the wood surface and form a solid protective film.

DD. Potential to Emit : The maximum capacity of a facili ty to emit any air pollutant under its physical and operational design. Any physical or opera tional limitation on the capacity of the facility to emit an ai r pollutant, including air pollution control equipment and restrictions on hours of operation, emissions , or on the type or amount of material combusted, stored, or processed, sh all be treated as part of its design if the limitation is enforceable by the EPA Administrator.

EE. Roll Coating : The application of coatings from a paint trough to a flat surface by a

mechanical series of rollers.

FF. Sanding Sealer : A coating containing binders, which seals the wood prior to application of the s ubsequent coatings.

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GG. Stripper : Solvent used to remove material such as cured adhesives, cured inks, cured or dried paint, cured or dried paint resi due or temporary protective coating.

HH. Surface Preparation : The removal of contaminants from a surface prior to the application of coatings, inks, or adhesives or before proceeding to the next step of a manufacturing process.

II. Transfer Efficiency : A ratio of the amount of coa ting solids adhering to the object being coated to the total am ount of coating solids used in the application process, expressed as a percentage.

JJ. Thinner : A solvent that is used to dilute co atings to reduce visc osity, color strength, and solids, or to modify drying conditions.

KK. Touch Up : That portion of the coating operati on which is incidental to the main coating process but necessary to cover minor imperfections or to achieve coverage as required.

LL. Volatile organic Compound (VOC) : As defined in Rule 102, Definitions.

MM. Wood Products : Surface-coated room furnishings which include cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, and any other coated objects made of wood, composite wood, simula ted wood material used in combination with wood or composite wood; and/or paper laminated on composite wood.

IV. Exemptions

Requirements of this Rule shall not apply to the fo llowing operations:

A. Residential noncommercial operations.

B. Small wood products coating opera tions (< 20 gallons usage/year).

C. Coating of wooden musical instruments.

D. The application of coatings by template (to add designs, letters or numbers to wood products).

E. Aerosol-spray coatings used for touch up and repair.

F. Specific types of finishes (imitation wood grain, crackle lacquers , and faux and leaf finishes).Architectural coatings.

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V. Requirement

A. With the exception of the exemptions lis ted in Section IV of Draft Rule 410.9, an operator shall not apply to any wood product, any coating, aerosol, or adhesive with a VOC content as applied, that exceeds the applicable limit specified in Table 1 or Table

2.

TABLE 1

VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION
VOC Content Limits Expre ssed in Grams per Liter Less Water and Exempt Compounds

Content Category VOC Limit g/l VOC Limit lb/gal

1. Clear Topcoat 275 2.3

2. Clear Sealers 240 2.3

3. Filler 275 2.3

4. High-Solids Stain 240 2.0

5. Ink 500 4.2

6. Mold-Seal Coating 750 6.3

7. Multi-Colored Coating 275 2.3

8. Pigmented Coating 275 2.3

9. Sanding Sealer 240 2.3

TABLE 2

VOC CONTENT LIMITS FOR WOOD PRODUCT COATING OPERATION
VOC Content Limits Expre ssed in Grams per Liter of Material, as Applied

VOC Content Category VOC Limit g/l VOC Limit lb/gal

1. Low-Solids Stain 120 1.0
2. Stripper 350 2.9

No person shall use any stri pper on wood products unless:

1. The reactive organic compound content is 350 grams per liter (2.9 lb/gal) of material or less; or

2. The reactive organic compound composite part ial pressure of the stripper is 2 mm Hg (0.04 psia) or less at 20 o C (68 o F).

B. Most Restrictive VOC Limit : If anywhere on the container of any wood coating, or any label or sticker affixed to the container, or in any sales, adve rtising, or technical literature supplied by a person, any representation is made that indicates that the coating meets the definition of or is reco mmended for use for more than one of the coating categories listed in Table 1 or Tabl e 2, then the lowest VOC content limit shall apply.

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C. Alternate Emission Control : In lieu of complying with VOC content limits specified in Table of Standards, an emission control syst em with a capture efficiency of at least 90% and a control efficiency of at least 90% may be used if it has been approved in writing by the Air Pollution C ontrol Officer. Any approved emission control system must be maintained and used in pr oper working condition at all times.

D. Equipment Requirements : Spray application of wood coatings sha ll only be performed by the following: electrostatic equipment, high-volume, low pressure (HVLP) spray equipment, hand roller, flow coat, roll coater , dip coat, paint brush, detailing or touchup

guns,

E. Surface preparation and Equipment Cleanup Requirements : No person shall conduct preparation or equipment cleanup for activities subject to provisions of this Rule unless the following VOC limits are met and methods are used:

1. VOC content of surface preparation solvent shall not ex ceed 25 g/l (0.2 lb/gal), as calculated pursuant to Section III.Q., unl ess such cleaning oper ation is performed

within the control of an APCO approved VOC emission control system that meets the requirements of Section V.C.

2. Cleaning of Coatings Application Equipment : Solvents used for cleaning of coatings application equipment shall co mply with both limits specified below:

a. Solvent shall have a VOC content of 950 grams or less per liter (7.9 lb/gal) of material; and

b. Solvent shall have a VOC composite pa rtial pressure of 35 mm Hg or less at 20/C (68/F).

3. Cleaning-Devices and Methods : No person shall pe rform solvent cleaning operations unless one of the following cleaning devices or methods is used:

a. Wipe Cleaning;

b. Spray bottles or containers with a maximum capacity of 16 fluid ounces from which solvents are applied wit hout a propellant induced force;

c. Cleaning equipment having a clos ed solvent container during cleaning operations, except when depositing and removing objects to be cleaned, and closed during nonoperation except during maintenance and repair of the cleaning equipment itself;

d. Remote reservoir cold cleaner operate d in conformance with District Rule 410.3, Organic Solvent Degreasing Operations;

e. System totally enclosing guns, cups , nozzles, bowls, and other parts during washing, rinsing, and draining procedures;

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f. Non-atomized solvent fl ow method collecting cleaning solvent in a container or a collection system closed except fo r solvent collection openings and, if necessary, openings to avoid excessive pr essure build-up inside the container;

or

g. Solvent flushing method discharging solven t into a closed cont ainer, except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the containe r. Discharged solvent from such equipment shall be collected in containe rs without atomizing into open air. Solvent may be flushed through the system by air or hydraulic pressure, or by pumping.

VI. Administrative Requirements

A. Labeling Requirements : Each manufacturer of any wood product coating subject to this Rule shall display information listed in Subsections VI.A.1. through VI.A.3. on coating container (or label) in which coating is so ld or distributed or an accompanying data

sheet

1. Date Code : date coating was manufactured, or da te code representing date, shall be indicated on label, lid or bo ttom of container. If manufact urer uses a date code for any coating, manufacturer shal l file an explanation of each code with the Executive

Officer of the CARB.

2. Thinning Recommendations : statement of manufac turer's recommendation regarding thinning of coating shall be indicated on label or lid of container. This requirement does not apply to thinning of architectural coatings with water. If thinning of coating prior to use is no t necessary, recommendation must specify coating is to be a pplied without thinning.

3. VOC Content : Each container or accompanying data sheet of any coating subject to this Rule shall display either maximu m or actual VOC content of coating, as supplied, as well as maximum thinning as recommended by manufacturer. VOC content shall be displayed in grams of VOC per liter (or pounds per gallon) of coating. VOC content displayed shall be calculated using product formulation data, or shall be determined using test methods in Subsection VII.

B. Record Keeping Requirements

An operator is required to maintain the co ating manufacturer's specifications, either listed on the coating container, product data sheet, or Safety Data Sheet (SDS),

available for review and shall maintain daily records which show the following information as applicable:

1. A current list of VOC contai ning products in use contai ning all data necessary to evaluate compliance, including the fo llowing information, as applicable:

a. Material name and manufacturer's identification;

Appendix A A-7 3/13/14410.9 Final Staff Report

b. Application method;

c. Material type and specific use instructions;

d. Specific mixing instructions;

e. Maximum VOC content of coating as applied, including thinning solvents; hardeners, etc., excluding wa ter and exempt compounds; and

f. Coating composition and density.

2. Daily coating and solvent use records, including the following information for each:

a. Volume used of each component and mix ratio;

b. VOC content in grams/liter (or pounds/gallon) as applied/used; and

c. Volume in liters (o r gallons) applied/used.

3. Capture and control equipment operating records, if appli cable, including:

a. Periods of operation corresponding to use records kept for Subsection VI.B.2. showing control equipment was used as necessary;

b. Key system operating parameters showi ng operation as required to comply with

this Rule and as inte nded by manufacturer; and

c. Date performed, and description of all control system maintenance.

Records required by the proposed Rule shall be retained for a minimum of three (3) years and made available on site during normal business hours to the APCO, ARB, or EPA upon request.

VII. Test Methods

A. Analysis of Samples - Samples of VOC as sp ecified in this Rule shall be analyzed by

U.S. EPA Method 24 Determination of Vo latile Matter Content, Water Content, Density, Volume Solids, and Weight Solid s of Surface Coatings and analysis of halogenated exempt compounds shall be conducted using CARB Method 432 - Determination of Dichloromethane and 1,1,1-Trichloroethane in Pain ts and Coatings ,

or ASTM D-4457-85 Standard Te st Method for Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints and Coa tings by Direct Injection into a Gas Chromatograph.

B. Determination of Emissions - Emissions of VOC shall be measured by U.S. EPA Method 25, 25A, or 25B, as applicable.

Appendix A A-8 3/13/14410.9 Final Staff Report

C. Determ ination of Capture Efficiency - Wh ere add-on control equipment is utilized, capture efficiency shall be determined in accordance with 40 CFR Appendix M –

Methods 204-204F.

D. Measurement of Acid Content - Acid conten t of Pre-Treatment Wash Primers shall be conducted and reported in accordance with ASTM D1613-06 Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates used in Paint, Varnish, Lacquer, and Related Products.

E. Demonstration of Transfer Efficiency - Transf er efficiency shall be demonstrated using South Coast Air Quality Management Dist rict Method "Spray Equipment Transfer Efficiency Test Procedure for Equipment User".

F. Determination of VOC Composite Partial Pr essures - VOC composite partial pressures shall be determined using either manufactur er's information regarding formulation or using ASTM methods E168-06 – Standard Prac tices for General Techniques of Infrared Quantitative Analysis, E169-93 – Standard Practices for General Techniques of Ultraviolet- Visible Quantitative Analysis, or E260-96 – Standard practice for Packed Column Gas Chromatography for determina tion of mole fractions and then summing products of each VOC component's vapor pres sure and its mole fraction. For materials containing no non-VOC component s, VOC composite partial pr essure can be measured directly by ASTM Method D2879-10 – Standa rd Test Method for Vapor PressureTemperature Relationship and Initial D ecomposition Temperature of Liquids by Isonteniscope.

G. Determination of VOC Emissions From Sp ray Gun Cleaning Systems - VOC emissions from spray gun cleaning systems shall be made using South Coast Air Quality Management District "Gener al Test Method for Determin ing Solvent Losses from Spray Gun Cleaning Systems".

H. When more than one test method or set of test methods is specified for any testing, a violation of any requirement of this rule established by any one of the specified test

methods or set of test methods shall constitute a violation of this rule."

VIII. Compliance Schedule

A. New Sources

1. Owners or Operators of any facility propos ing to install wood coating operations and required to comply with Section V of this rule shall obtain an Authority to Construct (ATC) in accordance with Rule 210.1 prior to installation or operation of any wood coating operation.

2. Owners or Operators of any facility with wood coating operations exempt by

Section IV of this rule sh all maintain records of wood coatings use, in accordance with Section VI, B upon initial operations.

Appendix A A-9 3/13/14410.9 Final Staff Report

Appendix A A-10 3/13/14 B. Existing Sources

1. Owners or Operators of any facility with wood coating operations required to comply with Section V of this rule shall obtain a valid Permit to Operate (PTO) or an Authority to Construct (ATC). Owner or operator shall apply for an ATC within 180 days from the adoption of this Rule.

2. Owners or Operators of any facility with wood coating operations exempt by

Section IV of this rule sh all maintain records of wood coatings use within 180 days of this rule being adopted.

3. Owners or operators with valid PTO(s), re quired to comply with Section V of this rule shall be in full compliance w ithin 12 months of rule adoption.

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## APPENDIX B

RULE 410.9

WOOD PRODUCTS SURFACE
COATING OPERATIONS

RESPONSE TO COMMENTS410.9 Final Staff Report - Response to Comments

Appendix B B- 1 3/13/2014 On November 6, 2013 the District held a public rule development workshop at the Mojave Veteran's Building in Mojave, Ca lifornia to present proposed Draft Rule 410.9, Wood Products Surface Coating Operations. The District submitted copies of the proposed Draft Rule to the Air Resour ces Board (ARB) and the Region IX office
of the U.S. Environmental Protection Agency (EPA) in October, 2013 for an initial 30-day review.

Upon completion of review EPA offe red comments and suggested changes to District staff regarding proposed Draft Rule 410.9. ARB did not provide comments or suggested changes but responded to the District that they would wait to review the rule upon submission of the final draft.

Industry representatives pr esent at the 11/6/2013 works hop asked various questions regarding the proposed amendments and s ubmitted written comments within 30- days following the workshop. Appendix B addresses comments, questions, and suggested changes regarding amended Rule 410.9.

Appendix B is separated into two sect ions based on EPA comments and suggested changes and industry/public comments and questions.

I. EPA COMMENTS

The following changes were made to the 8/8/2013 proposed versi on of Draft Rule 410.9 in response to EPA comments.

Section I, Purpose

1. EPA recommended adding " Volatile Organic Compound (VOC)" to Section I, Purpose because it is the first instance of this term.

District revised per suggestion.

Section III, Definitions

1. EPA suggested: The definition for Coating is mi xed with the definition for CFR and should be deleted, as there is already a definition of Coating.

District removed the term CFR and its definition has been removed.

2. EPA suggested: The definition of Dip Coating be updated to be consistent with
other districts. Other definitions of "Dip Coating" indi cate that there is draining of excess material. Consider amending to: "The process in which a substrate is immersed in a solution (or dispersion) containing the coating material, and then withdrawn after allowing the excess coating to drain."

District revised per suggestion.410.9 Final Staff Report - Response to Comments

Appendix B B- 2 3/13/2014 3. EPA suggested: An update of the AS reference in high gloss coating to ASTM

method D-523-08.

District revised per suggestion.

4. EPA suggested: Revising or removing the definit ion of Pretreatment Coating because it is not applicable to wood surfaces.

District removed Pretreatm ent Coating definition.

Section IV, Exemptions

1. EPA commented: SCAQMD has removed the ex emption for refinishing, replacement and custom replica furnishing coating operations and SJVAPCD does not include this category for exemptio n. Consider removing this exemption as low-VOC formulations are available for this usage.

District removed replacement and custom replica furnishing coating operations exemption.

Section V, Requirements

1. EPA commented: There are no sections addressing Control Systems, Application Requirements, Work Practices or Solv ent Requirements (for both thinning and surface preparation and cleanup). Please ad d such sections to complete this

rule.

District added: Most restrict ive VOC limit, alternate em ission control, equipment requirements, and surface preparation and equipment cl eanup requirements.

2. EPA recommended decreasing the limit of Clear Sealer and Sanding Sealer Section V: Table 1: VCAPCD Rule 74.30, Wood Products Coating, has a limit of 240 grams/liter for Sealers. Consider lo wering the limit for Clear Sealer and Sanding Sealer to 240 grams/liter.

District has decreased the limit to 240 grams/liter.

2. EPA commented: Section V: Table 2: Both SMAQMD Rule 463, Wood Products Coating, and previous-ment ioned VCAPCD Rule 74.30 hav e an alternate limit for strippers which is: "the VOC composite part ial vapor pressure is 2 mm Hg (0.04 psia) or less at 20 degree C (68 degree F), as calculated..." Consider adding this composite partial vapor pressure as an alternative limit for strippers.

District revised per suggestion.410.9 Final Staff Report - Response to Comments

Appendix B B- 3 3/13/2014 Section VI, Administ rative Requirements

Record Keeping requirements

1. EPA commented: There is no subsection V.B.2. This should be VI.B.2.

District revised per suggestion.

Test Method 1. EPA suggested adding the general clause about multiple tests: "When more
than one test method or set of test met hods is specified for any testing, a violation of any requirement of this rule established by any one of the specified
test methods or set of test methods shall constitute a violation of this rule."

District revised per suggestion.

2. EPA recommended: All ASTM test standards should include their titles. For ASTM E260, EPA has approved the 1996 version so this may be used if applicable. Since the partial pressures tests are included here, the partial pressure test for strippers should be included in Section V Table 2.

District revised per suggestion.

3. EPA recommended: Update titles for both the CARB Method 432 and ASTMD4457-85. The reference to the Federal Re gister should be deleted as this is incomplete and should probably be to 40 CFR. Response:

District revised per suggestion.

4. EPA commented: In the measurement of acid cont ent the latest version of ASTM D1613 is 1996. Consider using this if applicable.

District updated ASTM to the latest ve rsion which was found to be 2006.

5. EPA commented: The reference 40 CFR 52.741 should be replaced with "40 CFR Appendix M - Methods 204-204F.

District: 40 CFR 52.741 has been replac ed with 40 CFR Appendix M – Methods

204 – 294F.410.9 Final Staff Report - Response to Comments

Appendix B B- 4 3/13/2014 Compliance Schedule

1. EPA suggested: Clarify the records required for t hese facilities by revising the wording to "Owners or O perators of any facility wit h wood coating operations exempt by Section IV of this rule shall maintain records of wood coatings use, in accordance with Section VI, B upon initial operations."

District revised per suggestion.

II. INDUSTRY/PUBLIC COMMENTS

The following comments were made by indust ry representatives at, and following the 11/6/2013 workshop in Mojave, CA.

American Coatings Association American Coatings Association (ACA) submitted the following written comments regarding Rule 410.9 on 12/6/2013.

Section III, Definitions

1. ACA: Remove the definitions fo r “baked” and “continuous c oating” since these do not pertain to wood coatings. The definitions for “baked” and “continuous coating”.

District has removed the definition

Section IV, Exemptions

1. ACA: To be consistent with the Antel ope Valley and South Coast Wood Product Rules, including separate exemptions for Aerosol-spray coatings and touch up and repair.

District added Aerosol-spray coatings used for touch up and repair to Section IV, Exemptions.

Section VI, Administrative Requirements

Label requirements 1. ACA requested the removal of the proposed labeling pr ovisions found in Section VI(A) (pages A-5 and A-6) of proposed draft rule 410.9.

District removed Labeling provisions “Indus trial Maintenance Coatings”, Clear Brush Lacquers”, “Specialt y Primers, Sealers and U ndercoaters”, “Quick Dry Enamels” and “Non-flat High Gloss Coati ngs”: however, “Date Code”, “Thinning410.9 Final Staff Report - Response to Comments

Appendix B B- 5 3/13/2014 Requirements” and “VOC Content” remain . The option of having requirements

on a data sheet was also added.

Compliance Schedule 1. ACA: Requested a 12 month window from rule adoption to give manufacturers time to reformulate pr oducts and to sell through the current product.

District revised per suggestion.

Edwards Air Force Base Edwards Air force Base (Edwards) s ubmitted the following written comments regarding Rule 41 0.9 on 12/6/2013.

Section VI, Administrative Requirements

Compliance Schedule 1. Edwards: Requested a 12 month wi ndow from rule adoption to give
manufacturers time to re formulate products and to sell through the current product.

District revised per suggestion.

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