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 EFFICIENCY

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

222 SEMI-TRANSPARENT STAIN

223 SIMULATED WOOD MATERIALS

224 STAIN

225 THIN PARTICLEBOARD

226 TILEBOARD

227 TINT

228 VOC CONTENT

229 VOLATILE ORGANIC COMPOUND (VOC)

230 WOOD FLAT STOCK

300 STANDARDS

301 GENERAL REQUIREMENTS

302 APPLICATION EQUIPMENT REQUIREMENTS

303 CLEANUP AND STORAGE PROCEDURES

400 ADMINISTRATIVE REQUIREMENTS

401 OPERATION AND MAINTENANCE PLAN
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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 METHODS
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Placer County APCD 238 - 3 Rules and Regulations

100 GENERAL

101 PURPOSE: 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 230.

102 APPLICABILITY:

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, repackages, distributes, 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 wood flat stock 

intended to be used as furniture or cabinet components, 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 structures 

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 flatwood 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 Volume: Businesses using less than 55 gallons per year of

coatings, inks and VOC-containing cleanup solvents or strippers, (singularly or in 

combination) are exempt from the provisions of this rule, except for Recordkeeping, 

Section 502.

103.7 Exemption, Aerosol 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 

recordkeeping. 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 products, 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.
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Rules and Regulations 238 - 4 Placer County APCD

202 CAPTURE EFFICIENCY: Expressed in percent, capture efficiency is the ratio of the weight 

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 

subsection 506.2, and can be calculated by the following equation:

 Wc

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

 We

Where: Wc = Weight of VOC entering the control device

We = 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, filler, 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 device 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 subsection 506.3, and can be 

calculated by the following equation:

(Wc - Wa)

Control Device Efficiency = -------------- X 100

 Wc

Where: Wc = Weight of VOC entering the control device

Wa = Weight of VOC discharged from the control device

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

coating.

206 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 emissions of VOC from flatwood 

paneling 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 

emission 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 102, 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, tileboard and wallboard.

210 FLOW COATER: To coat an object by flowing a stream of coating over an object and 

draining off any excess coating.
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Placer County APCD 238 - 5 Rules and Regulations

211 HAND APPLICATION METHODS: The 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.

212 HARDBOARD: A panel manufactured primarily from inter-felted ligno-cellulosic fibers which 

are consolidated under heat and pressure in a hot press.

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

214 HIGH VOLUME, LOW PRESSURE (HVLP) SPRAY EQUIPMENT: Spray equipment used to 

apply coatings by means of a gun which is designed to be operated 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.

215 INK: Any fluid or viscous composition used in printing impressing or transferring an image 

onto a panel.

216 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.

217 NATURAL FINISH HARDWOOD PLYWOOD PANELS: Panels whose original grain pattern 

is enhanced by essentially transparent finishes frequently supplemented by fillers and toners.

218 NON-HEAT-SET INK: An ink which dries by oxidation and absorption into the substrate 

without the use of heat from dryers or ovens.

219 PANEL: A flat piece of wood or wood product usually rectangular and used inside homes 

and mobile homes for wall decorations.

220 PRINTED INTERIOR PANELS: Panels whose grain or natural surface is obscured by fillers 

and basecoats upon which a simulated grain or decorative pattern is printed.

221 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.

222 SEMI-TRANSPARENT STAIN: A stain 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.

223 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.

224 STAIN: A semitransparent or opaque coating labeled and formulated to change the color of 

a surface, but not conceal the grain pattern or texture.

225 THIN PARTICLEBOARD: A manufactured board 1/4 inch or less in thickness made of 

individual wood particles which have been coated with a binder and formed into flat sheets by 

pressure.

226 TILEBOARD: Paneling that has a colored waterproof surface coating.

227 TINT: A colorant added in small quantities to a stain to achieve a particular color for a 

finished product.

228 VOC CONTENT:
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228.1 Regulatory VOC Content: The weight of VOC per combined volume of VOC and 

coating solids, measured in accordance with subsection 506.1, and calculated by the 

following equation:

 Wv - Ww - Wec

 G1 = ---------------------------------

 Vm - Vw - Vec 

Where: G1 = Weight of VOC in grams per liter of coating, less water and exempt 

compounds

Wv = Weight of volatile compounds, in grams

Ww = Weight of water, in grams

We c = Weight of exempt compounds, in grams

Vm = Volume of coating material, in liters

Vw = Volume of water, in liters

Vec = Volume of exempt compounds, in liters

(To convert G1 to pounds per gallon, multiply by 0.008345)

228.2 Actual VOC Content: The weight of VOC in grams, per liter of total material, 

measured in accordance with subsection 506.1, and calculated by the following 

equation:

 Wv - Ww - Wec

 GL = ---------------------------------

 Vm

Where: GL = Weight of VOC per liter of low solids coating material, less water 

and exempt compounds

Wv = Weight of volatile compounds, in grams

Ww = Weight of water, in grams

Wec = Weight of exempt compounds, in grams

Vm = Volume of coating material, in liters

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

229 VOLATILE ORGANIC COMPOUND (VOC): Any chemical compound containing at least one 

atom of carbon, except for the Exempt Compounds listed in Rule 102, DEFINITIONS.

230 WOOD FLAT STOCK: Interior panels containing wood including but not limited to redwood 

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 

subsections 301.1 or 301.2:

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

VOC Limits shall be used:
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Placer County APCD 238 - 7 Rules and Regulations

Coating Materials and 

Inks

Maximum Allowable VOC content,

as applied

All coatings and inks except 

for low solids 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 solids 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 228.2

(Actual VOC Content)

301.2 Install and operate on the line(s), an emission control system as defined in Section 

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

accordance with Section 207, and that has been approved pursuant to Section 401.

302 APPLICATION EQUIPMENT REQUIREMENTS: A person or facility shall not apply coatings 

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 roller;

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 

solvents 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 label 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 used 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, bowls, and other parts during washing, rinsing, and 

draining procedures. Equipment used shall minimize the evaporation of organic 
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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.

303.4 Spillage of VOC-containing materials shall be minimized. Spills shall be cleaned up 

immediately.

303.5 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.

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

303.7 Mixing vessels for VOC-containing materials must be closed except when in use.

303.8 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 existing 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 operating 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 maintenance 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 maintain 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 and 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 and 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 information as applicable:

503.1 Name, description, container size and actual VOC content of any tints used to color 

stains for factory coating of wood products.
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Placer County APCD 238 - 9 Rules and Regulations

503.2 For persons using tints to color stains, usage is limited to one pint of tint in any 

operating day. Records of any tint use shall be maintained on a monthly basis and 

submitted to the Placer Air Pollution Control District when requested.

504 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 emissionproducing activities. 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, with the exception of sources subject to the 

requirements of Rule 507, FEDERAL OPERATING PERMIT PROGRAM. These sources 

shall retain records at least five years. Records shall be made available for inspection by the 

Air Pollution Control Officer upon request.

506 TEST METHODS:

506.1 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 Method 24A 

and Section 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 Efficiency, January 9, 

1995". Individual capture efficiency test runs subject to the U.S. EPA technical 

guidelines shall be determined by:

506.2.1 40 CFR 51, Appendix M, Methods 204-204F; or

506.2.2 The South Coast Air Quality Management District “Protocol 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: Efficiency 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 applicable. 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.

506.4 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.
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