ATTACHMENT C

COUNTY OF SAN DIEGO

AIR POLLUTION CONTROL DISTRICT

COMPARATIVE ANALYSIS OF 

PROPOSED AMENDMENTS TO 

RULE 67.11 – WOOD PRODUCTS COATING OPERATIONS

STATUTORY REQUIREMENTS

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

Code Section 40727 requires findings of necessity, authority, clarity, consistency, nonduplication, and reference. As part of the consistency finding to ensure proposed rule 

requirements do not conflict with or contradict other Air Pollution Control District (District) 

or federal regulations, Health and Safety Code Section 40727.2(a) requires the District to 

perform a written analysis identifying and comparing the air pollution control standards and 

other provisions of proposed amended Rule 67.11 with existing or proposed District rules and 

guidelines and existing federal rules, requirements, and guidelines applying to the same 

source category.

ANALYSIS

Proposed amended Rule 67.11 applies to all wood products coating operations and associated 

cleaning operations emitting volatile organic compounds (VOCs). The U.S. Environmental 

Protection Agency (EPA) has published a Control Techniques Guidelines (CTG) for Wood 

Furniture Manufacturing Operations applicable to wood coating operations emitting 25 tons 

per year or more of VOC. 

In addition, District New Source Review (NSR) Rule 20.2 - Non-Major Stationary Sources, 

also applies to any new or modified wood products coating operation that would be subject to 

amended Rule 67.11. Rule 20.2 requires that any non-major new or modified emission unit 

that has a post-project potential to emit of 10 pounds/day or more of VOC be equipped with 

Best Available Control Technology (BACT). For wood product coating operations, BACT is 

identified as either use of an add-on emission control system, or if such system is 

demonstrated to be not cost-effective, compliance with the requirements of Rule 67.11. 

Proposed amended Rule 67.11 will take effect one year after the date of rule adoption. Since 

amended Rule 67.11 contains VOC content limits for various wood coatings and cleaning and 

stripping materials that are more stringent than the existing rule, these limits will become the 

new BACT requirements.

CONCLUSION

As shown in Table 1, there are no conflicts or contradictions between proposed amended Rule 

67.11 and EPA's Control Technique Guidelines. Furthermore, there are no contradictions 

between the proposed amended rule and the District’s NSR Rule 20.2 BACT requirements.
Comparative Analysis – Rule 67.11 C - 2

TABLE 1 – COMPARATIVE ANALYSIS

Items for 

Comparison

Proposed Amended

Rule 67.11

SD APCD Best Available 

Control Technology (BACT)

CTG for Wood Furniture 

Manufacturing Operations

Applicability All wood product coating 

operations and associated 

stripping, surface 

preparation and coating 

application equipment 

cleaning.

Sources that emit > 10 lb/day 

of VOC.

Wood product coating 

operations emitting 25 tons per 

year or more of VOC.

Exemptions Exempt from rule:

1. Wood coating operations 

using 20 gallons or less of 

coatings per consecutive 12 

months.

2. Wood coating operations 

with VOC emissions of 150 

lbs or less per consecutive 

12 months.

3. Use of non-refillable 

handheld aerosol spray 

containers.

Exempt from equipment 

application standard: air 

brushing and touch-up 

operations.

Exempt from emission 

standards: coatings applied 

to wooden musical 

instruments.

No exemptions No exemptions

VOC Content 

Standards

VOC content limits for 

various categories of wood 

coatings and solvents.

For operations using < 10 

gal/day – use of water-based 

coatings when compatible 

with the operation and 

compliance with all other 

provisions of Rule 67.11, for 

the rest of the operation.

For operations using 10 

gal/day or more – a case-bycase determination of 

applicable add-on control 

requirements based on the 

District’s cost-effectiveness 

guidance is required.

VOC content limits for various 

categories of wood coatings 

and solvents. 

Add-On 

Emission 

Control 

Requirements

Capture and control 

efficiency >85 % by weight, 

as an alternative to 

complying with VOC 

content limits.

Same as in Rule 67.11– a 

case-by-case determination of 

applicable add-on control 

requirements based on the 

District’s cost-effectiveness 

Control system that will 

achieve an equivalent reduction 

in emissions as achieved by 

complying with the applicable 

VOC limits. 
Comparative Analysis – Rule 67.11 C - 3

guidance is required.

Recordkeeping 1) Records to be kept for 

three years.

2) Maintain current list of 

coating and solvent 

materials used.

3) Monthly records for 

coating materials and 

solvent use records.

Same as in Rule 67.11. 1) Records to be kept for five 

years.

2) Maintain current list of 

coating and solvent materials 

used.

3) Maintain records for the use 

of coating materials and 

solvents.

Test Methods Various methods approved 

by EPA or ARB, including 

VOC content, vapor 

pressure, and capture 

efficiency.

Same as in Rule 67.11. Various methods including 

VOC content, solids content, 

and capture efficiency.

* There are currently no applicable federal New Source Performance Standards (NSPS) to this source category. 

National Emission Standards for Hazardous Air Pollutants (NESHAP) – Wood Furniture Manufacturing 

Operations (NESHAP Subpart JJ) – applies to facilities that emit more than 10 tons/year of any one hazardous 

air pollutant (HAP) or 25 tons/year of a combination of HAPs. There are currently no sources in San Diego

County that are subject to this NESHAP.