October 14, 2010 (Effective July 1, 2011) Placer County APCD 238

- 1 Rules and Regulations 

### RULE 238 FACTORY COATING OF FLAT WOOD PANELING

Adopted 11

- 03

- 94 (Amended 2

- 09

- 95, 6

- 08

- 95, 8

- 14

- 97, 02

- 18

- 04

, 10

- 14

- 10 [Effective 7

- 1

- 11] )

CONTENTS

100 GENERAL

101 PURPOSE

102 APPLICABILITY

103 EXEMPTIONS

200 DEFINITIONS

201 ADHESIVE

202 CAPTURE EFF ICIENCY

203 COATING

204 CONTROL DEVICE EFFICIENCY

205 DIP COATER

206 ELECTROSTATIC SPRAY APPLICATION

207 EMISSION CONTROL SYSTEM

208 EXEMPT COMPOUNDS

209 FLATWOOD PANELING

210 FLOW COATER

211 HAND APPLICATION METHODS

212 HARDBOARD

213 HARDWOOD PLYWOOD

214 HIGH VOLUME, LOW PRESSURE (HVLP) SPRAY EQUIPMENT

215 INK

216 LOW SOLIDS COATING

217 NATURAL FINISH HARDWOOD PLYWOOD PANELS

218 NON

- HEAT

- SET INK

219 PANEL

220 PRINTED INTERIOR PANELS

221 ROLL COATER

2 22 SEMI

- TRANSPARENT STAIN

2 23 SIMULATED WOOD MATERIALS

2 2 4 STAIN

2 25 THIN PARTICLEBOARD

2 26 TILEBOARD

22 7 TINT

2 28 VOC CONTENT

2 29 VOLATILE ORGANIC COMPOUND (VOC)

2 3 0 WOOD FLAT STOCK

300 STANDARDS

301 GENERAL REQUIREMENTS

302 APPLICATION EQUIPMENT REQUIREMENTS

303 CLEANUP AND STORAGE PROCEDURES

400 ADMINISTRA TIVE REQUIREMENTS

401 OPERATION AND MAINTENANCE PLANOctober 14, 2010 (Effective July 1, 2011) Rules and Regulations 238

- 2 Placer County APCD 500 MONITORING AND RECORDS

501 COATING LIST

502 RECORDKEEPING

503 RECORDKEEPING OF STAINS AND TINTS

504 EMISSION CONTROL SYSTEM RECORDS

505 RETENTION OF RECORDS

506 TEST METHODSOctober 14, 2010 (Effective July 1, 2011) Placer County APCD 238

- 3 Rules and Regulations 100 GENERAL

101 PU RPOSE: The purpose of this Rule is to limit the emission of volatile organic compounds (VOC) from the factory application of coatings and inks to flatwood paneling as defined in

Section 209 , and to wood flat stock, as defined in Section 23 0

.

102 APPLICAB ILITY:

102. 1 Business Category: The provisions of this rule shall apply to any person who applies in a shop or factory facility, coatings or inks used to coat any products defined in

Section 209 or 231 , or who manufactures, blends, sells, repac kages, dis tributes

, or specifies such coatings and inks

. Standard Industrial Code (SIC) classifications covering these coating processes are 2431, 2435, 2436, 2492 and 2499.

103 EXEMPTIONS:

103.1 Exemption, Furniture

, and Cabinet Components: Surface coating of wo od flat stock

intended to be used as furniture or cabinet component s , is subject to Rule 236,

WOOD PRODUCTS COATING OPERATIONS , and is exempt from all provisions of

this rule.

103.2 Exemption, Non

- Shop Architectural Coatings: The coating of stationary st ructures and their appurtenances in a non

- shop operation is subject to Rule 218,

ARCHITECTURAL COATINGS , and is exempt from all provisions of this rule.

103.3 Exemption, Adhesives: The use of adhesives to manufacture fla twood panels or

wood flat stock is subject to Rule 235, ADHESIVES

, and is exempt from all provisions of this rule.

103.4 Exemption From Requirements of Other District Rules: Any coating, ink or cleanup

material

, which contains compounds that are subject to the VOC provisions of this

rule , is exempt from the provisions of Rule 219, ORGANIC SOLVENTS

.

103.5 Exemption

, Residential, Non

- Commercial Operations: Residential, non

- commercial flatwood coating operations are exempt from all provisions of this rule.

103.6 Partial Exemption, Low Vol ume: Businesses using less than 55 gallons per year o f coatings, inks and VOC

- containing cleanup solvents or strippers, (sing ularly or in combination) are exempt from the provisions of this rule, except for Recordkeeping,

Section 502.

103.7 Exemption, Ae rosol Spray Coatings for Touch

- Up: Aerosol spray coatings for touch up and repair are exempt from all provisions of this rule.

103.8 Exemption, Tints : Tints applied to stains in quantities not to exceed one pint of tint in any operating day, are exempt from all provisions of this rule, except for

record keeping

. Records shall be maintained and reported as specified in Section

503.

103 .9 Exemption

, Other: The application of coatings by template in order to add designs, letters, or numbers to wood product s, is exempt from all provisions of this rule.

200 DEFINITIONS

201 ADHESIVE: Any substance that is applied for the primary purpose of bonding surfaces together.October 14, 2010 (Effective July 1, 2011) Rules and Regulations 238

- 4 Placer County APCD 202 CAPTURE EFFICIENCY: Expressed in percent, capture efficiency is the ratio of the weigh t of the VOC in the effluent stream entering a control device to the weight of the VOC emitted from flatwood paneling coating operations, both measured simultaneously in accordance with

subs ection 506 .2 , and can be calculated by the following equation:

W

c Capture Efficiency = ------- X 100

W

e

Where: W

c = Weight of VOC entering the control device

W

e = Weight of VOC discharged from the coating operations

203 COATING: Any coating applied on any flatwood paneling or wood flat stock including but not limited to water repellant preservative, semitransparent stains, opaque stains, f iller, or clear
top coat.

204 CONTROL DEVICE EFFICIENCY: Expressed in percent, control device efficiency is the ratio of the weight of the VOC removed by the control dev ice from the effluent stream entering the control device to the weight of VOC in the effluent stream entering the control device, both measured simultaneously in accordance with subs ection 506 .3 , and can be calculated by the following equation:

(W

c - W

a ) Control Device Efficiency = -------------- X 100

W

c

Where: W

c = Weight of VOC entering the control device

W

a = Weight of VOC discharged from the control device

205 DIP COATER: T o dip an object into a vat of coating material and drain off any excess coating

.

2 06 ELECTROSTATIC SPRAY APPLICATION: Any method of spray application of coatings where an electrostatic attraction is created between the part to be coated and the paint particles.

207 EMISSION CONTROL SYSTEM: A system for reducing emi ssions of VOC from flatwood

pan eling coating operations. It consists of (1) a capture device or system which collects all drying oven exhaust and fugitive emissions from the line and transports them to the control device, and (2) a VOC control device which destroys the VOC or otherwise limits the

emis sion of VOC to the atmosphere. The individual efficiencies are calculated in accordance

with Sections 202 and 204.

The overall efficiency of the emission control system is calculated by the following equation:

Capture Efficiency X Control Device Efficiency Overall Efficiency = ---------------------------------------------------------------------------- 100

208 EXEMPT COMPOUNDS: For the purposes of this rule, exempt compounds are as defined in

Rule 1 02, DEFINITIONS.

209 FLATWOOD PANELING: Printed interior panels made of hardwood plywood and thin particle board, natural finish hardwood plywood, hardwood paneling, baseboard, wood flat
stock, veneers, doors, door skins, wood flat product skins, tileboa rd and wallboard.

2 10 FLOW COATER: T o coat an object by flowing a stream of coating over an object and draining off any excess coating.October 14, 2010 (Effective July 1, 2011) Placer County APCD 238

- 5 Rules and Regulations 2 11 HAND APPLICATION METHODS: T he application of coatings, sealants, or adhesives by manually held, non

- mechanically

- operated equipment. Such equipment includes paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe daubers, rags, and sponges.

21 2 HARDBOARD: A panel manufactured primarily from inter

- felted ligno

- cellulosic fibers which

are consolidated under heat and pressure in a hot press.

21 3 HARDWOOD PLYWOOD: Plywood whose surface layer is a veneer of hardwood.

21 4 HIGH VOLUME, LOW PRESSURE (HVLP) SPRAY EQUIPMENT: Spray equipment used to apply coatings by means of a gun which is designed to be o perated and which is operated between 0.1 and 10 pounds per square inch, gauge , (psig) air atomized pressure, measured dynamically at the center of the air cap and at the air horns.

21 5 INK: Any fluid or viscous composition used in printing impressing or transferring an image onto a panel.

21 6 LOW SOLIDS COATING: A coating or ink containing 120 grams or less of solids per liter (1.0 pounds or less of solids per gallon) of coating material.

21 7 NATURAL FINISH HARDWOOD PLYWOOD PANELS: Panels whose origi nal grain pattern is enhanced by essentially transparent finishes frequently supplemented by fillers and toners.

21 8 NON

- HEAT

- SET INK: An ink which dries by oxidation and absorption into the substrate without the use of heat from dryers or ovens.

21 9 PA NEL: A flat piece of wood or wood product usually rectangular and used inside homes

and mobile homes for wall decorations.

2 20 PRINTED INTERIOR PANELS: Panels whose grain or natural surface is obscured by fil lers and basecoats upon which a simulated gra in or decorative pattern is printed.

2 21 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.

22 2 SEMI

- TRANSPARENT STAIN: A s tain containing dyes and/or semi

- transparent pigments which are formulated to enhance wood grain and change surface color, but not to conceal surface grain, and include sap stain and non

- grain raising stains

. Semi

- transparent stains with greater than one ( 1) pound of solids per gallon of coating shall be considered opaque

stains.

22 3 SIMULATED WOOD MATERIALS: Materials, such as plastic, glass, metal, etc., that are made to give a wood

- like appearance, or are processed like a wood product.

22 4 STAIN: A s emitransparent or opaque coating labeled and formulated to change the color of a surface, but not conceal the grain pattern or texture.

22 5 THIN PARTICLEBOARD: A manufactured board 1/4 inch or less in thickness made of individual wood particles which hav e been coated with a binder and formed into flat sheets by

pressure.

22 6 TILEBOARD: Paneling that has a colored waterproof surface coating.

22 7 TINT: A colorant added in small quantities to a stain to achieve a particular color for a finished product.

22 8 VOC CONTENT :October 14, 2010 (Effective July 1, 2011) Rules and Regulations 238

- 6 Placer County APCD 228.1 R egulatory VOC Content : The weight of VOC per combined volume of VOC and coating solid s, measured in accordance with subs ection 506 .1, and calculated by the following equation:



### W

v 

### - W

w 

### - W

ec 

### G 1 

### =

-------------- ------------------- 

### V

m 

### - V

w 

### - V

ec

Where: G 1 = Weight of VOC in grams per liter of coating, less water and exempt compounds

W

v = Weight of volatile compounds, in grams

W

w = Weight of water, in grams

W

e c = Weigh t of exempt compound s, in grams

V

m = Volume of coating material, in liters

V

w = Volume of water, in liters

V

ec = Volume of exempt compounds, in liters

(To convert G 1 to pounds per gallon, multiply by 0.008345)

22 8.2 Actual VOC Content : The weight of VOC in grams, per l iter of total materia l,

measured in accordance with subs ection 506 .1, and calculated by the following equation :



### W

v 

### - W

w 

### - W

ec 

### G L 

### =

--------------------------------- 

### V

m

Where: 

### G L = Weight of VOC per liter of low solids coating material

, less water and exempt compounds

W
v = Weight of volatile compounds, in grams

W
w = Weight of water, in grams

W ec = Weigh t of exempt compounds, in grams

V
m = Volume of coating material, in liters

(To convert G L to pounds per gallon, multiply by 0.00834 5)

2 29 VOLATILE ORGANIC COMPOUND (VOC): Any chemical compound containing at least one atom of carbon, except for the Exempt Compounds listed in Rule 102, DEFINITIONS

.

2 3 0 WOOD FLAT STOCK: Interior panels containing wood including but not limited to red wood stocks, plywood panels, particle boards, composition hardboards, and any other panels containing solid wood or wood product.

300 STANDARDS

301 GENERAL REQUIREMENTS: Any person applying coatings or inks to flatwood paneling products subject to this rule shall comply with either of the following requirements listed in

subs ections 301.1 or 301.2:

301.1 Coating Materials and Inks: Only c oatings and inks that comply with the following

VOC Limits shall be used :October 14, 2010 (Effective July 1, 2011) Placer County APCD 238

- 7 Rules and Regulations Coating Materials and

Inks Maximum Allowabl e VOC content, as applied

All coatings and inks except

for l ow s olids coatings and inks (below). 250 grams or less of VOC per liter (2.1 pounds VOC per gallon) less water and exempt compounds, as calculated in

accordance with Section 228 .1 (Regulatory

VOC Content)

Low s olids coatings and

inks 120 grams or less of VOC per liter (1.0 pounds VOC per gallon) of material as

calculated in accordance with Section 22 8.2 (Actual VOC Content)

301.2 Install and operate on the line(s), an e mission c ontrol s ystem as defin ed in Section

207 , that operates at an overall efficiency of at least 95 %, as calculated in

accordance with Section 20 7 , and that has been approved pursuant to Section 401.

302 APPLICATION EQUIPMENT REQUIREMENTS: A person or facility shall not apply coat ings to wood products subject to the provisions of this rule unless the coating is applied with properly operating equipment, in accordance with proper operating procedures, and by the use of one of the following methods:

302.1 Electrostatic application ;

302.2 High volume, low pressure (HVLP) spray ;

302.3 Hand ro ller;

302.4 Flow coat ;

302.5 Roll coater ;

302.6 Dip coat ;

302.7 Paint brush ;

302.8 Detailing or touch

- up guns

.

303 CLEANUP AND STORAGE PROCEDURES: Any person or facility using VOC

- containing

so lvents for cleanup or related uses shall observe the following procedures:

303.1 All solvent, including waste solvent and waste solvent residues, shall be stored in

closed , non

- absorbant, non

- leaking, containers at all times

. Each container shall

have a l abel indicating the name of the solvent or material it contains.

303.2 If recovery of waste solvent by distillation is performed, solvent residues shall not contain more than 10 percent solvent by volume after distillation.

303.3 Solvents shall not be us ed for the cleanup of spray equipment including paint lines unless an enclosed system or other system that has been approved in writing for use by the Air Pollution Control Officer is used for cleanup. The system must enclose spray guns, cups, nozzles, bow ls, and other parts during washing, rinsing, and draining procedures. Equipment used shall minimize the evaporation of organicOctober 14, 2010 (Effective July 1, 2011) Rules and Regulations 238

- 8 Placer County APCD compounds to the atmosphere

. Spray equipment may be cleaned without the use of an enclosed system if cleaning solutions are used that do not contain VOCs.

30 3

. 4 Spillage of VOC

- containing materials shall be minimized

. Spills shall be cleaned up immediately.

30 3

. 5 VOC

- containing materials shall be stored and disposed of in closed containers

. Storage and disposal containers must be kept closed, except when depositing or removing the materials

. Disposal shall be conducted in a manner that the VOC are not emitted to the atmosphere.

30 3

. 6 VOC

- containing materials shall be conveyed in closed containers or pipes.

30 3

. 7 Mixing vessels fo r VOC

- containing materials must be closed except when in use.

30 3

. 8 VOC emissions shall be minimized during cleaning of storage, mixing, and conveying equipment.

400 ADMINISTRATIVE REQUIREMENTS

401 OPERATION AND MAINTENANCE PLAN: A person using an exis ting emission control system as a means of compliance with this rule, pursuant to Section 301.2, shall submit an Operation and Maintenance Plan for the emission control system to the Air Pollution Control Officer for approval

. A person proposing to install a new emission control system as a means of compliance with this rule, shall submit in addition to an Operation and Maintenance Plan, an application for an Authority to Construct, pursuant to Rule 501, GENERAL PERMIT

REQUIREMENTS

. The Plan shall specify o perating and maintenance procedures which will demonstrate continuous operation of the emission control system during periods of

emissions

- producing operations. The Plan shall also specify which records shall be kept to document these operating and mainten ance procedures

. These records shall comply with the requirements of Section 500 . The Plan shall be implemented upon approval of the Air

Pollution Control Officer.

500 MONITORING AND RECORDS

501 COATING LIST: Any person subject to Section 301 shall maint ain at the facility, a current list of coatings and inks in use, which includes all of the data necessary to evaluate compliance

with the standards of this rule.

502 RECORDKEEPING: Any person subject to this Rule shall maintain records on a monthly

basis that provide the following information as applicable:

502.1 Coating types an d mix ratios of components used;

502.2 Quantity of each coating applied ;

502.3 Description of substrate(s) coated ;

502.4 Oven or cure temperature, if applicable ;

502.5 Type a nd amount of solvent used for cleanup and surface preparation

.

503 RECORDKEEPING FOR STAINS AND TINTS: In addition to the requirements in Section 502, any person subject to this rule shall maintain records on a monthly basis that provide the following in formation as applicable:

503.1 Name, d escription, container size and a ctual VOC cont ent of any tints used to color

stains for fa ctory coating of wood products.October 14, 2010 (Effective July 1, 2011) Placer County APCD 238

- 9 Rules and Regulations 503.2 For persons using tints to color stains, usage is limi ted to one pint of tint in any

ope rating day. Records of any tint use shall be m aintained on a monthly basis and

submitted to the Placer Air Pollution Control District when requested

.

50 4 EMISSION CONTROL SYSTEM RECORDS: A person using an emission control system as a means of compliance with this rule pursuant to Section 301.2, shall maintain daily records of key system operating and maintenance procedures which will demonstrate continuous operation and compliance of the emission control system during periods of emission

producing activit ies. Key system operating parameters are those necessary to ensure compliance with the requirements of Section 301.2.

505 RETENTION OF RECORDS: All records maintained pursuant to this rule shall be retained for at least three years from date of entry, wi th the exception of sources subject to the requirements of Rule 507, FEDERAL OPERATING PERMIT PROGRAM

. These sources

shall retai n records at least five years. Records shall be made available for inspection by the Air Pollution Control Officer upon request.

50 6 TEST METHODS :

50 6 .1 Determination of VOC Content: VOC content

, solids content and water content of flatwood paneling coatings shall be determined in accordance with United States Environmental Protection Agency (U.S. EPA) Method 24 or U.S. EPA Meth od 24A

and S ection 228

.

506 .2 Determination of Capture Efficiency: Efficiency of the capture system, calculated in accordance with Section 202, shall be based upon test measurements made in accordance with U.S. EPA “Guidelines for Determining Capture Eff iciency, January 9,

1995"

. Individual capture efficiency test runs subject to the U.S. EPA technical guidelines shall be determined by:

50 6 .2.1 40 CFR 51, Appendix M, Methods 204

- 204F; or

506 .2.2 The South Coast Air Quality Management District “Protoco l for Determination of Volatile Organic Compound (VOC) Capture Efficiency”;

or

506 .2.3 Any other method approved by U.S. EPA, the California Air Resources Board, and the Air Pollution Control Officer.

506 .3 Determination of Control Device Efficiency: E fficiency of the emissions control device, calculated in accordance with Section 204, shall be based upon test measurements made in accordance with (1) U.S. EPA Method 25 or 25A, for VOC concentration, and (2) U.S. EPA Method 2 or 2C for flow rates, as app licable

. U.S. EPA Method 18 or CARB Method 422 “Determination of Volatile Organic Compounds in Emissions from Stationary Sources” may be used to determine emissions of exempt compounds.

50 6

. 4 Multiple Test Methods: When more than one test method or a 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.October 14, 2010 (Effective July 1, 2011) Rules and Regulations 238

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