UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Eastern Kern Air Pollution Control District

Rule 410.9, Wood Products Surface Coating Operations

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

April 2016
Agency: Eastern Kern Air Pollution Control District (EKAPCD)

SIP Approved Rule: No other versions of EKAPCD Rule 410.9 have been 

SIP approved.

Subject of this TSD: Rule 410.9 – Wood Products Surface Coating

Operations

Adopted – March 13, 2014

Submitted – July 25, 2014

BACKGROUND – Rule 410.9 is a new rule designed to reduce volatile organic 

compound (VOC) emissions from wood product coatings, and from the cleaning, 

storage, and disposal of organic solvents and waste solvent materials associated 

with the use of wood product coatings. Rule 410.9 also provides administrative 

requirements for recording and measuring VOC emissions. EKAPCD is in 

marginal non-attainment for the 8-hour ozone national ambient air quality 

standard (NAAQS, see 40 CFR 81). According to the District’s Staff Report

associated with this rule, EKAPCD Rule 410.9 is modelled after San Joaquin 

Valley Unified Air Pollution Control District (SJVUAPCD) Rule 4606, “Wood 

Products and Flat Wood Panel Product Coating Operations” which has been 

approved into the State Implementation Plan (SIP) most recently in 2009.

1 The 

District Staff Report also explains that the staff reviewed other SIP approved rules

–Antelope Valley Air Quality Management District (AVAQMD) Rule 1136, and 

South Coast Air Quality Management District (SCAQMD) Rule 1136—to maintain 

consistency.2

RULE SUMMARY - EKAPCD Rule 410.9 limits the amount of VOC contained in 

various wood product coatings. It also controls VOC emissions by establishing 

operational requirements on wood products coatings as well as solvent cleaning 

operations and storage and disposal of solvents and waste solvent materials 

associated with such coating. The rule also describes related administrative 

requirements for recording and measuring emissions. 

Rule 410.9 is organized into the following sections:

1. Purpose

2. Applicability

3. Definitions

4. Exemptions

5. Requirement

6 Administrative Requirements

7. Test Methods

1 EKAPCD Rule 410.9, Wood Products Surface Coating Operations Final Staff Report March 13, 

2014. p2

2 Ibid.

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8. Compliance Schedule

EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule. 

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the federal Clean Air Act (CAA) §110(a)(2)(A) requirement 

for enforceability. 

2. Stringency - SIPs must require Reasonably Available Control Technology 

(RACT) for each category of sources covered by a Control Technique 

Guideline (CTG) document as well as each major source in ozone 

nonattainment areas (see CAA §§ 182(b)(2) and 182(f)). EPA’s Control 

Technique Guideline (CTG) titled, “Control of Volatile Organic Compound 

Emission from Wood Furniture Manufacturing Operations” (EPA-453/R-96-

007, April 1996), EPA’s CTG titled, “Control Techniques Guidelines for 

FWPC” (EPA-453/R-06-004, September 2006), SJVUAPCD Rule 4606,

“Wood Products and Flat Wood Paneling Products Coating Operations,” 

and SCAQMD Rule 1136, “Wood Products Coating,” were used to help 

evaluate the RACT requirements of CAA §§182(b)(2) and §182(f). 

3. SIP Relaxation - CAA §110(l) prohibits EPA from approving any SIP 

revision that would interfere with any applicable requirement concerning 

attainment and reasonable further progress (RFP) or any other applicable 

requirement of the CAA. In addition, CAA §193 prohibits the modification of 

any SIP-approved control requirement in effect before November 15, 1990, 

in a nonattainment area.

EPA EVALUATION 

1. Enforceability - The rule requirements and applicability are clear, and the

monitoring, recordkeeping, reporting and other provisions sufficiently ensure 

that affected sources and regulators can evaluate and determine 

compliance with Rule 410.9 consistently. 

2. Stringency - Regarding wood furniture manufacturing, we have determined 

that the submitted Rule 410.9 satisfies RACT because Rule 410.9 

requirements are at least as stringent as the 1996 CTG and more stringent 

than SIP-approved SJVUAPCD Rule 4606 because it has no exemptions 

for refinishing coatings and some of the VOC limits are lower than those of 

Rule 4606. Regarding flat wood paneling coating (FWPC), some limits are 

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less stringent that those in EPA’s 2006 CTG. However, District staff3

confirm that there are no FWPC operations in EKAPCD, and therefore

RACT is not needed for FWPC. A review of industries doing wood products 

coating in the EKAPCD using the California Air Resources Board’s (CARB) 

Facility Search Tool by Standard Industrial Classification (SIC) codes did 

not reveal any sources of VOC emission due to the coating of wood 

products.

3. SIP Relaxation - We propose to determine that our approval of the submittal 

would comply with CAA §§110(l) and 193 because (1) the proposed SIP 

revision would not interfere with the on-going process for ensuring that 

requirements for RFP and attainment of the NAAQS are met, and (2) the 

emission limits in the submitted rule will ensure equivalent or greater 

emission reductions of VOCs.

RULE DEFICIENCIES – We have identified no deficiencies with Rule 410.9 for 

EPA to propose less than full approval. 

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – EPA 

has the following recommendations if Rule 410.9 is amended.

1. Consistent with the 1996 CTG, we recommend the addition of an operator 

training program for work practices.

2. EPA recommends that Rule 410.9 establish VOC content limits for FWPC

consistent with EPA’s 2006 CTG and SJVUAPCD Rule 4606, “Table 3 

VOC Content Limits for Flat Wood Paneling Products Coating Operation.”

EPA ACTION -

The rule fulfils the relevant CAA §110 and part D requirements. Therefore, EPA 

staff recommends a full approval of Rule 410.9.

3 Verified by a telephone conversation between Arnold Lazarus (EPA) and Cherita Young 

(EKAPCD) on 10/30/14.

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REFERENCES 

1. EKAPCD Rule 410.9, “Wood Products Surface Coating Operations,”

adopted March 13, 2014.

2. EKAPCD Rule 410.9, “Wood Products Surface Coating Operations,” Final 

Staff Report March 13, 2014.

3. SJVUAPCD Rule 4606, “Wood Products and Flat Wood Panelling Products 

Coating Operations,” EPA Approved - October 15, 2009 (74 FR 52894).

4. Control Techniques Guidelines “Control of Volatile Organic Compound 

Emissions from Wood Furniture Manufacturing Operations” (EPA-453/R96-007, April 1996).

5. Control Techniques Guidelines “Control Techniques Guidelines for Flat 

Wood Paneling Coatings” (EPA-453/R-06-004, September 2006).

6. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

7. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf).

8. “Determinations of Attainment by the Attainment Date, Extensions of the 

Attainment Date, and Reclassification of Several Areas Classified as 

Marginal for the 2008 Ozone National Ambient Air Quality Standards” 80 

FR 51992,” August 27, 2015.

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