EL DORADO COUNTY AIR QUALITY MANAGEMENT DISTRICT

RULE 236 - ADHESIVES
(Adopted: July 25, 1995)

236.1 GENERAL

1. PURPOSE: To limit emissions of volatile organic compounds from the use of commercial and industrial adhesives.
2. APPLICABILITY: The rule is applicable to any person who supplies, sells, offers for sale, manufactures, solicits the application of, or uses adhesives and/or adhesive primers. This rule does not apply to household adhesives that are subject to Article 2, Consumer Products, Sections 94507-94517, Title 17, California Code of Regulations.
3. EXEMPTION, LOW USAGE OF NONCOMPLIANT ADHESIVES:
   1. The provisions of Sections 236.3 A. and 236.3 B. shall not apply to adhesives, adhesive primers, and adhesive bonding primers with separate formulations that are used in volumes of less than 10 gallons each per facility per year.
   2. The provisions of this rule shall not apply to any facility that uses less than one pint of adhesives in any one day.
4. EXEMPTION, CONTAINERS: The provisions of Section 236.3 A. of this rule shall not apply to adhesives which are sold or supplied by the manufacturers or suppliers in the following containers:
   1. Tubes that have a capacity of eight liquid ounces or less; or
   2. Any other container, except aerosol spray cans, that has a capacity of 5 liquid ounces or less.
5. EXEMPTION, SPECIFIC OPERATIONS AND ADHESIVES: The requirements of this rule shall not apply to the following:
   1. The provisions of Sections 236.3 A., 236.3 B.1., and 236.3 B.2. shall not apply to the following:
      1. Adhesives used in tire repair; or
      2. Adhesives and/or adhesive application processes in compliance with Rule 231 GRAPHIC ARTS OPERATIONS.
   2. The provisions of Sections 236.3 E. and 236.5 A. shall not be apply to adhesives that contain less than 20 g/l of VOC per liter of adhesives, less water and exempt compounds.
   3. Section 236.3 shall not apply to research and development programs and quality assurance labs, provided that the following records are retained in accordance with Section 236.5 A. of this rule:
      1. The date when the adhesives are used, and the type of application(s).
      2. The amount of adhesives used and the VOC content of such adhesives.
      3. The amount of solvents used and VOC content of such solvents.
   4. Section 236.3 shall not apply to solvent welding operations used in the manufacturing of medical devices, such as, but not limited to, catheters, heart valves, blood cardioplegia machines, tracheotomy tubes, blood oxygenators, and cardiatory reservoirs.
6. EXEMPTION OF AEROSOLS FROM TRANSFER EFFICIENCY REQUIREMENTS: The provisions of Section 236.3 E. shall not apply to adhesives and primers dispensed from aerosol cans.

236.2 DEFINITIONS

1. ACRYLONITRILE-BUTADIENE-STYRENE (ABS): A plastic made by reacting monomers of acrylonitrile, butadiene, and styrene and normally identified with an ABS marking.
2. ADHESIVE: Any substance that is used to bond one surface to another surface by attachment.
3. ADHESIVE BONDING PRIMER: An adhesive applied to a surface to improve the bond of subsequent adhesives and sometimes to inhibit corrosion.
4. ADHESIVE PRIMER: A coating applied to a substrate, prior to the application of an adhesive, to provide a bonding surface.
5. ADHESIVE PRIMER FOR PLASTIC: A material applied to a plastic substrate before applying an adhesive in order to obtain better adhesion.
6. ADHESIVE PROMOTER: A coating applied to a substrate in a monomolecular thickness to promote wetting and form a chemical bond with the subsequently applied material.
7. ADHESIVE SOLID: The nonvolatile portion of an adhesive that remains after heating a sample of the material at 110C for one hour.
8. AEROSOL ADHESIVE: A mixture of rubber, resins, and liquid and gaseous solvents and propellants packaged in a disposable container for hand-held application.
9. AEROSOL SPRAY CAN: A hand-held, pressurized, non-refillable container which expels adhesives from the container in a finely divided spray when a valve on the container is depressed.
10. AIR-ASSISTED AIRLESS SPRAY: Paint spray application system using fluid pressure to atomize the paint and lower air pressure to adjust the shape of the fan pattern.
11. ANY OTHER PRIMER: A coating or adhesive applied to a substrate to improve adhesion of subsequently applied adhesive, except adhesive primer and adhesive bonding primer.
12. CARPET PAD INSTALLATION: The installation of carpet pad or cushion, used beneath a carpet, onto a floor or comparable surface.
13. CERAMIC TILE INSTALLATION: The installation of ceramic tile products.
14. CERAMIC TILES: A ceramic surfacing unit made from clay or a mixture of clay and other materials.
15. CHLORINATED POLYVINYL CHLORIDE (CPVC): A plastic which is a polymer of the chlorinated polyvinyl monomer that contains 67% chlorine and is normally identified with a CPVC marking. 
16. COATING SOLID: The nonvolatile portion of a coating that remains after heating a sample of the material at 110C for one hour.
17. COMPUTER DISKETTE MANUFACTURING: The process where the fold-over flaps are glued to the body of a vinyl jacket.
18. COVE BASE INSTALLATION: The installation of cove base (or wall base), generally made of vinyl or rubber, onto a wall or vertical surface at floor level.
19. DRY WALL INSTALLATION: The installation of gypsum dry wall to studs or solid surfaces.
20. EXEMPT COMPOUNDS: The following compounds are exempt from the definition of VOC in Section 236.2 WW.
    1.  methane
    2. carbon dioxide
    3. carbon monoxide
    4. carbonic acid
    5. metallic carbides or carbonates
    6. ammonium carbonate
    7. 1,1,1-trichloroethane
    8. methylene chloride
    9. trichlorofluoromethane (CFC-11)
    10. dichlorodifluoromethane (CFC-12)
    11. chlorodifluoromethane (HCFC-22)
    12. trifluoromethane (HFC-23)
    13. trichlorotrifluoroethane (CFC-113)
    14. dichlorotetrafluoroethane (CFC-114)
    15. chloropentafluoroethane (CFC-115)
    16. dichlorotrifluoroethane (HCFC-123)
    17. 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124)
    18. pentafluoroethane (HFC-125)
    19. 1,1,2,2-tetrafluoroethane (HFC-134)
    20. tetrafluoroethane (HFC-134a)
    21. dichlorofluoroethane (HCFC-141b)
    22. chlorodifluoroethane (HCFC-142b)
    23. 1,1,1-trifluoroethane (HFC-143a)
    24. 1,1-difluoroethane (HFC-152a)
    25. Parachlorobenzotriflouride (PCBTF)
    26. Volatile cyclic and linear methyl siloxanes (VMS)
    27. The following four classes of perfluorocarbon compounds:
        1. Cyclic, branched, or linear, completely fluorinated alkanes.
        2. Cyclic, branched, or linear, completely fluorinated ethers, with no unsaturations.
        3. Cyclic, branched, or linear, completely fluorinated tertiary amines with no unsaturations.
        4. Sulfur-containing perfluorocarbons with no unsaturations and with sulfur bonds only to carbon and fluorine.
21. FACILITY: Any permit unit or grouping of permit units or other air contaminant-emitting activities which are located on one or more contiguous properties within the District, in actual physical contact or separated solely by a public roadway or other public right-of-way, and are owned or operated by the same person (or by persons under common control). Such above-described groupings, if not contiguous, but connected only by land carrying a pipeline, shall not be considered one facility.
22. FIBERGLASS: Fine filaments of glass.
23. FOAM: A rigid or spongy cellular mass with gas bubbles dispersed throughout.
24. GLUE: A hard gelatin obtained from hides, tendons, cartilage, bones, etc., of animals. Through general use, the term "glue" is synonymous with the term "adhesive."
25. HAND APPLICATION METHODS: The application of adhesive by manually held equipment. Such equipment includes paint brush, hand roller, trowel, spatula, dauber, rag, sponges, and mechanically- and/or pneumatic-driven syringes without atomization of the materials.
26. HIGH-VOLUME, LOW-PRESSURE (HVLP) SPRAY: Equipment used to spray a coating by means of a gun that operates between 0.1 and 10 pounds per square inch gauge (psig) air pressure.
27. INDOOR CARPET INSTALLATION: The installation of a carpet that is in an enclosure and is not exposed to ambient weather conditions during normal use.
28. LOW-SOLIDS ADHESIVE: An adhesive which has less than one pound of solids per gallon of material.
29. LOW-SOLIDS ADHESIVE PRIMER: An adhesive primer which has less than one pound of solids per gallon of material.
30. OUTDOOR CARPET INSTALLATION: The installation of carpet that is not in an enclosure and is exposed to ambient weather conditions during normal use.
31. PANEL INSTALLATION: The installation of plywood, pre-decorated hardboard (or tileboard), fiberglass reinforced plastic, and similar predecorated or non-decorated panels to studs or solid surfaces.
32. PERSON: Any individual, firm, association, organization, partnership, business, trust, corporation, company, contractor, supplier, installer, user or owner, or any state or local governmental agency or public district or any other officer or employee thereof. PERSON also means the United States or its agencies to the extent authorized by Federal law.
33. PLASTIC CEMENT WELDING: The use of adhesives made of resins and solvents which are used to dissolve the surfaces of plastic, except ABS, CPVC, and PVC plastic, to form a bond between mating surfaces.
34. PLASTIC FOAM: A foam constructed of plastics.
35. PLASTICS: Various synthetic materials chemically formed by the polymerization of organic (carbon-based) substances. Plastics are usually compounded with modifiers, extenders, and/or reinforcers. They are used to produce pipe, solid sheet, film, or bulk products.
36. POLYURETHANE FOAMS: Plastic foams, as defined in "Whittington's Dictionary of Plastics," and may be either rigid or flexible.
37. POLYVINYL CHLORIDE (PVC): Plastic which is a polymer of the chlorinated vinyl monomer that contains 57 percent chlorine and is normally identified with a PVC marking.
38. POROUS MATERIAL: A substance which has tiny openings, often microscopic, in which fluids may be absorbed or discharged.
39. PROPELLANT: A fluid under pressure which expels the contents of a container when a valve is opened.
40. ROLL COATER: A series of mechanical rollers that form a thin coating or adhesive film on the surface roller, which is applied to a substrate by moving the substrate underneath the roller.
41. RUBBER FLOORING INSTALLATION: The installation of flooring material in which both the back and the top surface are made of synthetic rubber, and which may be in sheet or tile form.
42. RUBBER FOAM: A foam constructed of natural or synthetic rubber.
43. SOLVENT WELDING: The softening of the surfaces of two substrates by wetting them with solvents and/or adhesives, and joining them together with a chemical and/or physical reaction(s) to form a fused union.
44. SUBFLOOR INSTALLATION: The installation of subflooring material over floor joists; and includes the construction of any load bearing joints in joists or trusses.
45. THIN METAL LAMINATING: A process of bonding multiple layers of metal to metal or metal to plastic in the production of electronic or magnetic components in which the thickness of the bond line(s) is less than 0.25 mil.
46. TIRE REPAIR: The expanding of a hole, tear, fissure, or blemish in a tire casing by grinding or gouging; applying adhesive; and, filling the hole or crevice with rubber.
47. VCT: Vinyl composition tile.
48. VISCOSITY: The property of a fluid or semifluid that enables it to develop and maintain an amount of shearing stress dependent upon the velocity of flow and then to offer continued resistance to flow.
49. VOLATILE ORGANIC COMPOUNDS (VOC): Compounds containing at least one atom of carbon, except for the exempt compounds listed in Section 236.2 T.
50. WOOD FLOORING INSTALLATION: The installation of a wood floor surface, which may be in the form of parquet tiles, planks, or strip-wood.
51. WOOD PARQUET FLOORING: Wood flooring in tile form constructed of smaller pieces of wood which have been joined together in a pattern to form the tile.
52. WOOD PLANK FLOORING: Solid or laminated wood in plank form.

236.3 STANDARDS

1. GENERAL ADHESIVE REQUIREMENTS: Effective January 1, 1996, a person shall not apply adhesives, adhesive bonding primers, adhesive primers, or any other primer which have a VOC content in excess of 250 grams of volatile organic compounds per liter of coating (less water and exempt compounds), or manufacture, blend or repackage such coating for use within the District, unless otherwise specified in Section 236.3 B.
2. SPECIALTY ADHESIVE REQUIREMENTS: A person shall not apply adhesives, adhesive bonding primers, adhesive primers, or any other primer which have a VOC content in excess of the limits specified below:
   1. For adhesives, adhesive bonding primers, adhesive primers, or any other primer used in the following welding or installation operations:
   2. For adhesives, adhesive bonding primers, or any other primer not regulated by Section 236.3 B.1. and applied to the following substrates, the following limits shall apply. If an adhesive is used to bond dissimilar substrates together the adhesive with the highest VOC content shall be allowed.
3. For low-solids adhesives and low-solids adhesive primers, the appropriate limits in Sections 236.3 B.1. and 236.3 B.2. shall be expressed in Grams of VOC per Liter of Material.
   
   
4. A person shall not apply adhesives from aerosol spray cans unless the VOC content, including the propellant, does not exceed the limits specified below:

1. CONTROL EQUIPMENT REQUIREMENTS: As an alternative to Sections 236.3 A. and 236.3 B., a person may use collection and control systems in association with the adhesive operations regulated by this rule provided that:
   1. The collection system collects at least 90 percent, by weight, of the emissions generated by the adhesive operations, pursuant to Section 236.5 B.4., and
   2. The control system reduces VOC emissions from the emission collection system by at least 95 percent, by weight, pursuant to Section 236.5 B.3.
2. STORAGE AND DISPOSAL: Regardless of their VOC content, all VOC-containing materials used in adhesives application (such as solvents, and cloth and paper moistened with solvents) shall be stored in non-absorbent, non-leaking containers which shall be kept closed at all times except when filling or emptying.
3. APPLICATION EQUIPMENT REQUIREMENTS: A person or stationary source shall not apply any adhesive unless one, or more, of the following application methods is used:
   1. Hand application,
   2. Dip coat,
   3. Flow coat,
   4. Brush or roll coat,
   5. Electrodeposition,
   6. Electrostatic spray,
   7. High-volume low-pressure (HVLP) spray,
   8. Low-volume low-pressure (LVLP) spray, or
   9. Air-assisted airless spray.

236.4 ADMINISTRATIVE REQUIREMENTS

1. OPERATION AND MAINTENANCE PLAN: Any person choosing to use an emissions control device pursuant to Section 236.3 C. must submit an Operation and Maintenance Plan for the emissions control device to the Air Pollution Control Officer for approval. The Plan shall specify operation and maintenance procedures which will demonstrate continuous operation of the emissions control device, pursuant to Section 236.3 C., during periods of emissions-producing operations. The Plan shall also specify which daily records must be kept to document these operation and maintenance procedures. These records shall comply with the requirements of Section 236.5 A. The Plan shall be implemented upon approval by the Air Pollution Control Officer.
2. PROCEDURE FOR PROCESSING OPERATION AND MAINTENANCE PLAN:
   1. APPROVAL OF PLAN: The Air Pollution Control Officer shall determine whether the Operation and Maintenance Plan meets the requirements of Section 236.4 A. not later than 30 days after receipt of the Plan, or within a longer period of time agreed upon by all parties. The Air Pollution Control Officer shall disapprove an Operation and Maintenance Plan if the plan:
      1. Fails to demonstrate continuous operation of the emission control device during periods of emission producing operations, and/or
      2. Does not specify which daily recordkeeping requirements are necessary to document the operation and maintenance procedures set forth in the plan.
      These records, in addition to documenting operation and maintenance procedures, must comply with the recordkeeping requirements of Sections 236.5 A.2. and 236.5 A.3.
   2. REVISION OF PLAN: If the Air Pollution Control Officer does not approve an Operation and Maintenance Plan, the source shall receive written notice of the deficiency, and shall have an additional 30 days from the date of the notification of the deficiency to correct and resubmit the Operation and Maintenance Plan. The decision of the Air Pollution Control Officer regarding the resubmitted Operation and Maintenance Plan shall be final. Failure to correct the deficiency in an Operation and Maintenance Plan upon resubmittal shall constitute a violation of this rule that is subject to the penalties set forth in Health and Safety Code section 42400 et seq.
3. COMPLIANCE SCHEDULE:
   1. Operation and Maintenance Plans for emissions control devices installed as of July 25, 1995, if not previously submitted, must be submitted by March 1, 1996 and receive approval by the Air Pollution Control Officer.
4. CALCULATION FOR DETERMINATION OF VOC CONTENT PER LITER OF ADHESIVE, LESS WATER AND EXEMPT COMPOUNDS: VOC per liter of adhesive, less water and exempt compounds, is the weight of VOC per combined volume of VOC and adhesive solids (excluding any colorant added to the tint bases). The amount of VOC per liter of adhesive, less water and exempt compounds, shall be calculated using the following equation:
   
   
   (W_v - W_w - W_ec) / (V_m - V_w - V_ec) 
   
   Where:
   W_v = weight of all volatile compounds, in grams.
   W_w = weight of water, in grams.
   W_ec = weight of compounds listed as exempt in Section 236.2 I. from the definition of VOC, in grams.
   V_m = volume of coating material, in liters.
   V_w = volume of water, in liters.
   V_ec = volume of compounds listed as exempt in Section 236.2 I., in liters.
   
    
5. CALCULATION FOR DETERMINATION OF VOC CONTENT PER VOLUME OF MATERIAL: VOC per volume of material (excluding any colorant added to the tine bases) shall be calculated using the following equation:
   
   
    (W_v - W_w - W_ec) / (V_m) 
   
   Where:
   W_v = weight of all volatile compounds, in grams.
   W_w = weight of water, in grams.
   W_ec = weight of compounds listed as exempt in Section 236.2 I. from the definition of VOC, in grams.
   V_m = volume of material, in liters.
   
    
6. ANNUAL EXEMPTION STATEMENT: Operations claiming exemption pursuant to Sections 236.1 C., 236.1 E.3., and 236.1 F., shall submit to the Air Pollution Control Officer on an annual basis copies of records retained pursuant to Sections 236.5 A.1. and 236.5 A.2.

236.5 MONITORING AND RECORDS

1. USAGE RECORDS: In addition to any existing permit conditions issued pursuant to Rule 501 GENERAL PERMIT REQUIREMENTS, effective January 1, 1996, any person subject to this rule, including operations claiming exemption under Sections 236.1 C., 236.1 E.3., and 236.1 F. shall comply with the following requirements:
   1. LIST OF MATERIALS: A current list of adhesives in use shall be maintained which includes all of the following items:
      1. The product name/code and type of adhesive.
      2. The VOC content of the adhesive, as determined pursuant to Section 236.5 B.1.
   2. USAGE AMOUNTS:
      1. For persons using materials which comply with the standards specified in Sections 236.3 A. and 236.3 B., or using materials pursuant to Sections 236.1 C., 236.1 E.3., 236.1 F. records shall be maintained on a monthly basis, showing the type and volume of adhesives used.
      2. For persons using materials exceeding the VOC limits specified in Sections 236.3 A. and 236.3 B., and using an emission control system pursuant to Section 236.3 C., records shall be maintained on a daily basis, showing the type and volume of adhesives used.
   3. CONTROL EQUIPMENT: Any person using an emission control system pursuant to Section 236.3 C. shall maintain such records as required by the Operation and Maintenance Plan in Section 236.4 A. on a daily basis.
   4. DURATION OF RECORDS: Such records shall be maintained on-site for a continuous five year period and made available to the Air Pollution Control Officer upon request.
2. TEST METHODS
   1. DETERMINATION OF VOC CONTENT: VOC content of adhesives shall be determined in accordance with EPA Method 24 and Sections 236.4 E. and 236.5 B.2. of this rule. The VOC content of low-solids adhesives and adhesive primers shall be determined using EPA Method 24, Section 236.5 B.2., and Section 236.4 F.
   2. DETERMINATION OF COMPOUNDS EXEMPT FROM VOC DEFINITION: Compounds exempted from the VOC definition, as listed in Section 236.2 T. of this rule, shall be determined in accordance with ASTM D 4457-85 or ARB Method 432. If any of the perfluorocarbons are being claimed as exempt compounds, the person making the claim must state in advance which compounds are present, and the EPA-approved test method used to make the determination of these compounds.
   3. DETERMINATION OF CONTROL EFFICIENCY: Control efficiency of the emissions control device shall be determined by using one or more of the following: EPA Method 18, 25, 25A, 2, and/or 2C. EPA Methods 2 and 2C are alternative methods for measurement of flow rate. EPA Methods 25 and 25A are alternative methods for measuring emission concentrations. EPA Method 18 is an alternative to Methods 25 and 25A, but is usually only for quantification of exempt compounds.
   4. DETERMINATION OF COLLECTION EFFICIENCY: Collection efficiency of the collection system shall be determined in accordance with EPA's technical document, "Guidelines for Determining Capture Efficiency," dated January 9, 1995.