# Eastern Kern Air Pollution Control District



# Rule 410.4A

MOTOR VEHICLE AND MOBILE EQUIPMENT
REFINISHING OPERATIONS

FINAL STAFF REPORT

March 13, 2014

Prepared by



### Jeremiah Cravens Air Quality Specialist II

Reviewed by 

### Glen Stephens, P.E.

Air Pollution Control Officer

Eastern Kern Air Pollution Control District 2700 “M” Street, Suite 302 Bakersfield, California 93301 (661) 862-5250  www.kernair.org

### Table of Contents

I. BOARD AD OPTION .................................................................................. 1

II. INTROD UCTION ....................................................................................... 1

III. MOTOR VEHICLE AND MOBILE EQUIPMENT COATINGS .................... 2

IV. MOTOR VEHICLE REFI NISHING EMI SSIONS ........................................ 2

V. VOC EMISSION S REDUCTION S.............................................................. 3

VI. APPLICAB ILITY......................................................................................... 3

VII. CHANGES IN CATEGOR IES AND DEFI NITIONS.................................... 3

VIII. EXCLUDED CATEGORI ES AND DEFINI TIONS....................................... 4

IX. EXEMPT IONS ........................................................................................... 7

X. CHANGES IN REQUIREM ENTS............................................................... 7

XI. VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS ............... 10

XII. SOL VENTS.............................................................................................. 12

XIII. ADMINISTRATIVE REQUIREMEN TS..................................................... 12

XIV. TEST ME THODS..................................................................................... 12

XV. ECONOMIC IMPACTS ............................................................................ 12

XVI. ENVIRONMENTA L IMPACTS ................................................................. 13

XVII. SOCIOECONO MIC IMPAC TS................................................................. 14

TABLE 1: NEW CA TEGORY NA MES ....................................................... 5

TABLE 2: VOC CONT ENT LIMI TS.......................................................... 11

APPENDIX A AMENDED RULE 410.4A, MOTOR VEHICLE AND
MOBILE EQUIPMENT REFINISHING OPERATIONS
CLEAN VERSION

APPENDIX B AMENDED RULE 410.4A, MOTOR VEHICLE AND
MOBILE EQUIPMENT REFINISHING OPERATIONS
STRIKEOUT UNDERLINE VERSION

APPENDIX C RESPONSE TO COMMENTS410.4A Final Staff Report

I. BOARD ADOPTION

Rule 410.4A, Motor Vehicle and Mobile Equipment Refinishing Operations was amended by the Eastern Kern Air Pollution Control District (District)’s Governing Board on March 13, 2014 at its regular Board meeting in Rosamond California.

Amended Rule 410.4A became effective and enforceable upon adoption. A copy
of the Rule has been submitted to the Ca lifornia Air Resources Board (ARB) for

their review and then to be forwarded to the U.S. Envir onmental Protection Agency (EPA) for inclusion into t he State Implementation Plan (SIP).

II. INTRODUCTION

Rule 410.4A was originally adopt ed May 6, 1991 and amended April 6, 1995, March 7, 1996, and March 13, 2014. This staff report presents an extensive
revision of the Rule. Amended Rule 410.4A limits volatile organic compound (VOC) emissions from coatings and solvent s used in production, repair, refinish, or maintenance operations where moto r vehicles, mobile equipment, or associated parts and component s are coated. A majori ty of the amendments are
based on the California Air Resources Board (ARB) Suggested Control Measure (SCM) for Automotive Coatings. The SCM is designed to promote uniformity amongst air district's that use it as a template for amending their motor vehicle and mobile equipment refinishing/coating rules.

On November 6, 2013 the District held a public rule development workshop at the Mojave Veteran's Building in Mojave, CA. At this workshop District staff presented proposed revisions to Rule 410.4A, Motor Vehicle and Mobile Equipment Refinishing Operations. The District submitted copies of the proposed revision to ARB and EPA for an init ial review prior to the workshop. A 30-day public review and comment period followed the workshop.

District received comments and sugges ted changes from EPA, ARB, and industry. District considered a ll comments and suggested changes.

Appendix A is Amended Rule 410.4A, Mo tor Vehicle and Mobile Equipment Refinishing Operations.

Appendix B shows all changes made to Ru le 410.4A, Motor Vehicle and Mobile Equipment Refinishing Operations in strikeout underline form.

Appendix C is the District’ s Response to Comments fo llowing the November 6, 2013 public workshop held at the Mojave Veteran’s Center in Mojave, CA.

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III. MOTOR VEHICLE AND MOBI LE EQUIPMENT COATINGS

Motor vehicle and mobile equipment coatings are coatings that are applied to motor vehicles and mobile equipment. Su ch coatings are sold as components that must be mixed to be applied. The main coating categor ies include primers, color coatings, and clear coatings. These three broad coating categories account for approximately 84 percent of the sales reported in California. Remaining sales consist of a variety of coat ings such as pretreatment coatings or adhesion promoters intended for use on bare metal or plastics.

Motor vehicle and mobile equipment coat ings are typically used to refinish, repair, or restore vehicles such as: aut omobiles, vans, trucks, truck trailers, buses, motorcycles, golf carts, tanks, armo red personnel carriers, trains, railcars, mobile cranes, bulldozers, and street cl eaners. Aerosol coatings (e.g., spray paint) or original equipment manufactur er coatings are not considered motor vehicle and mobile equipment coatings for applicable intent and purposes of this

rule.

IV. MOTOR VEHICLE REFINISHING EMISSIONS

Coatings used in motor vehicle and m obile equipment refinishing operations represent a moderate sour ce of volatile organic compound (VOC) emissions throughout California. VOC emissions are precursors to the formation of ozone and particulate matter (PM), which are Ca lifornia’s most serious air quality problems. VOCs react photochemically wi th oxides of nitr ogen (NOx) to form ozone. Ozone is a strong oxidizer that irritates the human respiratory system, increases airway hyperreactivity, incr eases airway inflammation, and damages plant life and property. Ex posure to ozone can be associ ated with hospitalization for cardiopulmonary causes, asthma episode s, restrictions in physical activity, and premature death.

VOC emissions from motor vehicle and mobile equipment coatings can also lead to the formation of particula te matter (PM), which consists of very small liquid and solid particles suspended in t he air. PM of concern incl ude particles smaller than 10 microns in size (PM 10 ), as well as the subset of fine particles smaller than 2.5 microns in size (PM 2.5 ). When inhaled, PM 10 and PM 2.5 can travel deep into the lungs and reduce human pulmonary function.

When motor vehicle and mobile equipment coatings are applied, the solvents that hold the coatings in suspensi on evaporate into the atmosphere and
contribute to VOC emissions.

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V. VOC EMISSIONS REDUCTIONS

Motor vehicle and mobile equipment coatings contain solvents which evaporate when they are applied. Most of the so lvents used in these coatings are VOCs.
Rule 410.4A is intended to reduce VOC emissions by establishing limits on the
VOC content of motor vehi cle and mobile equipment coating categories. VOC limits are expressed in grams of VOC per liter of coat ing, less water and exempt compounds, and vary with each coating cat egory. In general VOC limits are met by replacing some of the solvents in motor vehicle and mobile equipment coatings with water, exempt co mpounds such as solvents with low photochemical reactivity, increasing the amount of solids, such as resins and pigments, or with a combi nation of these approaches.

Average annual statewide VOC emissions from automotive c oatings, excluding solvent usage for surface preparati on and cleanup, are estimated to be approximately 20.7 tons per day (tpd) or about two percent of the total statewide stationary source VOC emissions. ARB has calculated that statewide implementation of the autom otive refinishing SCM would lower VOC emissions from automotive coatings by about 13.4 tpd. This produces approximately a 65% reduction in VOC emissions from automotive coatings.

VI. APPLICABILITY

Provisions of Rule 410.4A are applicable to motor vehicle and mobile equipment refinishing operations as defined in th is staff report and to any person who supplies, sells, offers for sale, manufacture s, distributes, uses, applies, or solicits the use or application of any automotive coating or a ssociated solvent within the

District.

VII. CHANGES IN CATEGORIES AND DEFINITIONS

To enhance clarity, enforcement , and to limit the types of products that qualify for inclusion into each specific category of Ru le 410.4A, Section IV, Definitions of the rule provides definitions for revised and ne w terms that are not self-explanatory.

Definitions for the following item s have been revised in 410.4A:

 Electrostatic Spray Application

 Exempt Compounds

 High-Volume, Low-Pressure (HVLP)

 Metallic/Iridescent Topcoat

 Mobile Equipment

 Pretreatment Coating  Primer

 Specialty Coating

 Spot/Panel Repair

 Touch-Up Coating

 Volatile Organic Compound

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Definitions for the following items have been added to 410.4A

 Adhesion Promoter

 Aerosol Coating Product

 APCO

 Assembly Line

 Associated Parts and Components

 Automotive Coating

 Automotive Coating Component

 Automotive Refinishing Facility

 California Air Resources Board

 Cleaning Operations

 Clear Coating

 Coating

 Color Coating

 Emission Control System  EPA

 Motor Vehicle

 Multi-Color Coating

 Single-Stage Coating

 Solvent

 Spray Booth

 Surface Preparation

 Temporary Protective Coating

 Transfer Efficiency

 Truck Bed Liner Coating

 Underbody Coating

 Uniform Finish Coating

 VOC Content

VIII. EXCLUDED CATEGOR IES AND DEFINITIONS

Definitions for the following items hav e been deleted from Rule 410.4A because they were found unnecessary. Products fr om deleted categories default to the most closely related category if not called-out in a definition.

 Antiglare Coating

 Basecoat/Clearcoat System

 Camouflage Coating

 Color Match

 Extreme Performance Coating

 Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt Compounds

 Grams of VOC per liter of Material  Group I Vehicle

 Group II Vehicle

 Large/Heavy Duty Truck

 Light and Medium Du ty Truck or Van

 Multistage Topcoat

 Primer Sealer

 Primer Surfacer

 Reducer/T hinner

 Three-Stage Coating System

Definitions for Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt Compounds and Grams of VOC per liter of Material have been replaced
with the definition VOC Content

.

Table 1 displays the new category name th at each existing or deleted product will now fall under. If a coating does not meet any of the definition for a specific category listed in Table 1, it will fall into the category labeled “Any other coating type” and the VOC limit of 250 grams per liter (g/l) will apply. Limits are expressed in grams of VO C per liter of coating thinned to the manufacturer’s maximum recommendation, excluding t he volume of any water and exempt compounds.

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TABL E 1
NEW CATEGORY NAMES

New Category Existing/Deleted Category

Adhesion Promoter:  Adhesion promoter

Cavity Wax:  Cavity Wax

Deadener:  Deadener

Clear Coating:  Antiglare Coating

 Basecoat/Clearcoat System

 Extreme Performance Coating

 Heat Resistant

 Impact Resistant Coating

 Low-Gloss Coatings

 Multistage Topcoat

Color Coating:  Antiglare Coating

 Basecoat/Clearcoat System

 Camouflage Coating

 Extreme Performance Coating

 Heat Resistant

 Multi-Stage Topcoat System

 Multi-Color Topcoat

 Multi-Color Multi-Stage

Gasket/Gasket Sealing Material:  Gasket/Gasket Sealing Material

Lubricating Wax/Compound  Lubricating Wax/Compound

Multi-Color Coating:  Multi-Color Coatings

 Multi-Color Multi-stage

 Multi-Color Topcoat

 Three-Stage Coating System

Pretreatment Coating:  Pretreatment

 Pretreatment Coating

 Pretreatment Wash Primer

Primer:  Extreme Performance Coating

 Heat Resistant

 Precoat

 Primer

 Primer Sealer

 Primer Surfacer

 Water Hold-Out Coating

 Weld-Thru Coatings

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TABLE 1 continued

New Category Existing/Deleted Category

Primer:  Extreme Performance Coating

 Heat Resistant

 Precoat

 Primer

 Primer Sealer

 Primer Surfacer

 Water Hold-Out Coating

 Weld-Thru Coatings

Sealer  Sealer

Single-Stage Coating:  Antiglare Coating

 Extreme Performance Coating

 General Topcoat

 Heat Resistant

 Impact Resistant Coating

 Iridescent Topcoat

 Metallic Topcoat

 Nonmetallic Topcoat

 Noniridescent Topcoat

 Solid Color Topcoat

 Topcoat (aka All Other Topcoats)

Specialty Coating  Adhesion Promoters

 Uniform Finish Blenders Elastomeric

Materials

 Gloss Flatteners

 Bright Metal Trim Repair

 Antiglare/Safety Coatings

 Cut In or Jambing Clear Coatings

Temporary Protective Coating:  Temporary Protective Coating

Truck Bed Liner Coating:  Impact Resistant Coating

Trunk Interior Coating  Trunk Interior Coating

Underbody Coating:  Extreme Performance Coating

 Impact Resistant Coating

 Rubberized Asphaltic Underbody

Uniform Finish Coating:  Finish Blenders

Any other coating type:  Bright Metal Trim Repair Coating

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I X. EXEMPTI ONS

The Exemptions Section of the amended Rule has been moved from Section III to Section V, immediately after Defini tions and before Requ irements. None of the previous exemptions have been remo ved but the following exemptions have

been added:

 Any automotive coating or associated solven t that is offered for sale, sold, or supplied in 0.5 fluid ounce or smaller containers intended to be used by the general public to repair tiny surface imperfections.

 An y automotive coating or associated solven t that is offered for sale, sold, or
manufactured for use outside of the Dis trict or for shipment to other manufacturers for reformulation or repackaging.

 Any coating applied to motor vehicl es or mobile equi pment, or their associated parts and compon ents, during manufacture on an assembly line.

 Surface Preparation and Equipment Cleanup Requirement s, shall not apply to the use of surface prepar ation solvents to clean plas tic parts just prior to coating or VOC-containing material s for the removal of wax and grease provided that non-aerosol, hand-held sp ray bottles are used with a maximum solvent VOC content of 780 g/L and the total volume of the solvent does not exceed 20 gallons per year per facility. Records of solvent usage shall be kept in accordance with Section VII.C.4 of this Rule.

X . CHANGES IN REQUIREMENTS

The following requirements hav e been added to Rule 410.4A:

 Most Restrictive VOC Limit : If anywhere on the container of any automotive coating, or any label or sticker affixed to the container, or in any sales, advertising, or technical literature supplied by a person, any representation is made that indicates that the coating m eets the definition
of or is recommended for use for mo re than one of the coating categories
listed in Table of Standards , then the lowest VOC c ontent limit shall apply.

 Spray gun : If a spray gun is used, the end user must demons trate that the gun meets the HVLP definition in Se ction IV.V in design and use. A satisfactory demonstration must be based on the manufacturer's published technical material on the design of the gun and by a demons tration of the operation of the gun using an ai r pressure tip gauge from the manufacturer of the gun.

 Surface Preparation : VOC content of surface preparation solvent shall not exceed 25 g/l (0.2 lb/gal), as calc ulated pursuant to Section IV.RR.3, unless Section V.E applies.

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 Sell-Thro ugh/Existing Stock of Coatings : A coating manufactured prior to amendment date of this rule, that co mplied with the VOC Content limit(s) in effect at that time, may be sold, supplied, or offered for sale for 12 months after rule adoption date. Su ch a coating may be applied at any time, both before and after adoption dat e, provided manufacture DateCode and VOC Content is clearly printed on coating container.

The following requirements of Rule 410.4A have been revised:

 VOC Content Limits has been revised from: Except as provided by Subsection IV.C., effective on the dates specified , no person shall refinish, or spot/panel repair any Group I vehicle, or where color match is required, any Group II vehicle, Mobile Equipmen t, or parts and components of such vehicles or equipment, using a coati ng with VOC content in excess of the
followi ng limits as applied

. To: No person shall apply a coating to any motor vehicle, mobile equipment, or its associated parts and components, with a VOC regulatory cont ent, as calculated pursuant to Section IV.RR.1, in excess of the limits expressed in Table of Standards, except as provided in Sections VI.C and VI.J.

 Alternate Emission Cont rol has been revised from: In lieu of complying with VOC content limits specified in subsections IV.A. and IV.B., air pollution control equipment with a capture efficiency of at least 85% and a control efficiency of at least 90% may be used. To: Alternate Emission Control: In lieu of complying with VOC content limits specified in Table of Standards, an emission control system with a capture efficiency of at least 90% and a control efficiency of at l east 90% may be used if it has been approved in writing by the Air Poll ution Control Officer (APCO). Any approved emission control system must be maintained and used in proper working condition at all times. Us e of a VOC emission control system

shall not result in emissions in excess of those that would have been emitted had the operator complied wit h the provisions of Section V.A.

 Application has been revised from: No person shall coat any Group I or Group II Vehicle, or Mobil e Equipment, or parts and components of such vehicles and equipment, unless one of the following methods is used

. To: Coating Application Methods: No per son shall apply any coating to any motor vehicle, mobile equipment, or associated parts and components unless one of the following app lication methods is used.

Section VI.E does not apply to underbody coatings, graphic arts operations, truck bed liner coatings, or any coating use of less than one (1) fluid ounce (29.6 milliliters).

 Other application m ethod demonstrated to achieve at least 65% transfer efficiency, for example, fl ow or continuous coating. Has been revised to: Any alternative coating application method which has been demonstrated

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to achieve at least 65% transfer effi ciency or the equivalent efficiency of an HVLP and approved, in wr iting, by the EPA and APCO.

 Storage and Disposal has been revised from: Regardless of VOC content,
all VOC

- containing materials used in solv ent cleaning operations, such as solvents, and cloth and paper moisten ed with solvents, shall be stored in

non

- absorbent, non

- leaking containers kept cl osed at all times except when filling or emptying. To: Regardless of VOC content, all automotive coating components, automot ive coatings, and solvents, shall be stored in non-absorbent, vapor-tight containers kept closed at all times except when filling or emptying.

 Prohibition of Sale, No person shall offe r for sale or sell within the District any coating if such product is prohibited by any provisions of this Rule. This pr ohibition shall apply to sale of any coating to be applied at any physical location within the District.

Has been revised to: Prohibition of Sale or Manufacture: No person shall manufacture, blend, repackage for sale, supply, sell, offer for sale or distribute within the District any coat ing with a VOC content in excess of the limits specified in Section VI.A.

Notwithstanding the provisions of this section, a person may manufacture, blend, repackage for sale, supply, sell, o ffer for sale, or distribute a coating
with a VOC content in exce ss of the limits specified in section VI.A under the following circumstances and prov ided all of the requirements of
section VII.C.6 are also met:

1. The coating is used exclusivel y within an emission control system as allowed in Section IV.C, or

2. Coating is exempt un der one or more of the pr ovisions of Section V.A.

 Prohibition of Specification : No person shall solicit or require for use or specify application of a coating on a Group I Vehicle or Group II Vehicle

and Mobile Equipment or its parts and components, if such use or application results in a viol ation of provisions of th is Rule. This prohibition shall apply to all written or oral cont racts under terms of which any coating subject to provisions of this Rule i s to be applied to any vehicle, mobile equipment or part or compon ent at any physical location within the District.

Has been revised to: No person shall solicit or require the use of, or specify the application or use of any coating or solvent on a motor vehicle or mobile equipment, or its associated parts and components, if such use or application results in a violation of this Rule. This prohibition shall apply to all written or oral contracts, in cluding but not limited to, job orders, under the terms of which any coating or solvent subject to provisions of this Rule is to be applied. This prohibition shall not apply to coatings or

solvents that meet the criteria specified in Section VI.H.

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The following requirements of R ule 410.4A have been deleted:

 VOC Content Limits : Except as provided by Subs ection IV.C., effective on the dates specified, where color ma tch is not required, no person shall refinish or spot/panel repair any Group II vehicle, or Mobi le Equipment, or parts and components of such vehicle o r equipment using a coating with a
VOC content in excess of t he following limits as applied.

 1. Surface Cleaning : No material shall be used containing VOC in excess of 200 grams per liter (1.7 lb/gal) of material to remove dirt, oils, or

other contaminan ts prior to application of surface coatings or

adhesives.

2. Stripping : No material shall be used containing VOC in excess of 200 grams per liter of material to strip any coating.

4. Cleaning of Polyester Resin Application Equipment : Solvents used for cleaning polyester resin application equipment shall comply with one of the limits specified below:

a. Solvent shall have a VOC content of 200 grams or less per liter (1.7 lb/gal); or

b. Solvent shall have a VO C content of 1100 gram s or less per liter (9.2 lb/gal) and a VOC composite par tial pressure of 1.0 mm Hg or less at 20/C (68/F).

 1. Specialty Coatings : No person shall use any specialty coating with a VOC content in excess of 840 g/l (7.0 lbs/gal), excluding water and exempt compounds. Where use of specialty coatings, except antiglare/safety coatings, exceeds one gallon per day, use of such coatings shall not exceed 5.0 percent of all coatings applied on a daily

basis.

X I. VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS

The previous version of Rule 410.4A (3 /7/96) had two sets of VOC limits for automotive coatings commonly referred to as Group I and Group II vehicles. Coatings used on passenger cars typically have higher VOC limits than coatings used on large vehicles such as trucks and buses. Amended Rule 410.4A eliminates Group I and Group II vehicles categories an d establishes one set of VOC limits for passenger vehicles, heavy- duty vehicles, and mobile equipment.

The previous Rule also had composite VOC limits for mult i-stage systems that apply to the total VOC content of the color coat and clear coat combined.

Amended Rule 410.4A elimin ates composite VOC limit s for multi-stage systems and replaces them with specific VOC limits for clear coatings and color coatings.

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Amended Rule 410.4A establishes VO C content limits for the following seventeen automotive coating categories: Cavity Wax, Adhesion Promoter, Cavity Wax, Clear Coating, Color Coating, Deadener, Gasket/Gask et Sealing Material, Lubricating Wax/Compound, Multi-Color Coating, Pr etreatment Coating, Primer, Sealer, Single-Stage Coating, Specialty Coatin g, Temporary Protective Coating, Truck Bed Liner C oating, Underbody Coating, Uniform Finish Coating, and Any other coating type. These autom otive coating categories were chosen because they are similar to those in exis ting California air di strict automotive refinishing rules.

Table 2 details the maximum VOC cont ent limit for each of the seventeen automotive coating categories. Limits are expressed in grams of VOC per liter of coating thinned to the manufacturer’s maximum recommendation, excluding the volume of water and any exempt compound. If a coating is represented in such a way that indicates it can be used in more than one coating category listed in Table 1, then the lowest, mo st restrictive, VOC conten t limit will apply. If a coating does not meet any of the definit ions of a specific category then that coating will default to the “Any other coating type” category and a VOC limit of 250 grams per liter (g/l) will apply.

TABLE 2
VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS Content expressed in Grams per Liter (Pounds per Gallon) Less Water and Exempt Compounds

Coating Category VOC Limit

Adhesion Promoter 540 (4.5) Cavity Wax 650 (5.4) Clear Coating 250 (2.1) Color Coating 420 (3.5)

Deadener 650 (5.4) Gasket/Gasket Sealing Material 200 (1.7) Lubricating Wax/Compound 700 (5.8) Multi-Color Coating 680 (5.7) Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Sealer 650 (5.4) Single-Stage Coating 340 (2.8) Specialty Coating 540 (4.5) Temporary Protective Coating 60 (0.5) Truck Bed Liner Coating 200 (1.7) Trunk Interior Coating 650 (5.4) Underbody Coating 650 (5.4) Uniform Finish Coating 540 (4.5) Any other coating type 250 (2.1)

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X II. SOLVENT S

For purpose of this rule, solvents are defi ned as any liquid containing an organic compound or combination of organic co mpounds used as diluent, thinner, dissolver, viscosity reducer, cleaning agent, or other similar uses. These liquids are principally derived from petroleum and include petroleum distillates, chlorinated hydrocarbons, chlorofluor ocarbons, ketones, and alcohols. Solutions, emulsions, and dispersions of water and soap, or water and detergent, are not considered organic solvents. Soaps and detergents are considered

water based surfactants.

Solvents used for cleaning of coatings application equipment remains the same
with a VOC content limit of 950 grams or less per liter (7 .9 lb/gal) of material and with a VOC composite partial pressure of 35 mm Hg or less at 20/C (68/F). The District has retained this limit largel y because the equipment cleaning methods require solvents to be contained in a closed system. However, surface preparation solvents have a revised VOC limit that shall not exceed 25 g/l (0.2 lb/gal).

The 25 g/l limit is the lowest VOC cont ent limit that is technologically and commercially feasible and has been sinc e January 1, 2009. 25 g/l VOC content can be achieved through the use of exem pt compounds. Many air districts require solvents in various coating oper ation rules to meet the 25 g/l VOC

content limit.

XII I. ADMINISTRATIVE REQUIREMENTS

Rule 410.4A contains an extensive revi sion of the Administrative Requirements section. Please see Section VII, Administ rative Requirements of Appendix A for complete details and Section VII, Administ rative Requirements of Appendix B for strikeout underline changes.

XIV. TEST METHODS

Rule 410.4A contains an extensive revision of the Test Methods section. Please see Section VIII, Test Methods of Append ix A for complete details and Section VIII, Test Methods of Appendix B for strikeout underline changes..

XV. EC ONOMIC IMPACTS

Economic impacts are quantified to the extent feasible, but economic impact analyses can be inherently imprecise by nature, especially given the unpredictable behavior of companies in a hi ghly competitive market. Therefore, some projections are necessarily qua litative or semi- quantitative, based on general observations about the motor vehicle coatings industry.

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Economic impact analysis for Amended Rule 410.4A provides a general picture of the economic impacts that a typica l bus inesses might encounter. However, staff recognizes that individual companies may experience impacts different than those projected in this analysis.

Information provided in this economic analys is is based on ARB’s findings in their October 2005, Staff Report for the Proposed SCM for Automotive Coatings. The data is associated with statewide implement ation of the Motor Vehicle Coatings
SCM.

ARB estimates overall cost-effectiveness of the Motor Vehicle Coatings SCM to be approximately $1.43 (in current dollars ) per pound of VOCs reduced. This cost-effectiveness is comparable in magni tude to that repor ted for other ARB consumer product regulations and meas ures, which generally have fallen within a range of no cost to about $6.90 per pound of VOCs reduc ed. For example, the SCM for architectural coatings had an average cost-effectiveness of $3.20 per pound of VOCs reduced.

ARB found that most automotive refinishi ng facilities and coatings manufacturers
would be able to absorb the cost of the proposed SCM with no significant adverse impacts on their profitability. This finding is indicated by ARB’s estimated change in “Return on Owner’s Equity” (ROE) analysis. The analysis found an average decrease in the state- wide ROE of about 0.07 percent for coatings manufacturers and 15 percent for automotive refinishing facilities.

If all costs of the proposed SCM are absor bed by automotive refinishing facilities,
the decrease in ROE exceeds the 10 percent threshold typically used to indicate a potential for adverse impacts on profitab ility. However, ARB expects the costs incurred by manufacturers and automotive re finishing facilities to be passed on to
consumers. If the entire cost of the proposed SCM were passed on to consumers, the average pr ice for a repair would incr ease by about $11. This represents an increase of about 0.5% for a $2,200 repair.

It is expected that most businesses will pass on their increased costs to consumers. Therefore, no noticeable ch ange in employment, business creation, elimination, expansion, or business competitiveness in California will be adversely affected. In addition , ARB's economic analysis has found no significant adverse fiscal impacts on any local or State agencies.

XVI. ENVIRONMENTAL IMPACTS

Both the California Environmental Quality Act (CEQA) and ARB policy require an evaluation of the potential adverse envir onmental impacts of proposed projects. Based on the information provided in AR B’s October 2005 Staff Report for the Proposed SCM for Automotive Coatings, District has determined that no significant adverse environmental impacts should occur as a result of adopting

Amended Rule 410.4A.

EKAPCD Draft 3/13/2014 13410.4A Final Staff Report

EKAPCD Draft 3/13/2014 14 The primary environmental benef it of Amended Rule 410.4A is a reduction in the formation of tropospheric (ground level) ozone, PM10 and PM2. 5. It has long been known that exposure to gro und level ozone, PM10 and PM2.5 have adverse impacts on public health. Am ended Rule 410.4A will help protect public health by reducing the public’s exposure to these potentially harmful emissions.

Additionally, automotive coat ings contain several known TACs such as toluene, xylenes, and methyl ethyl ketone (MEK) . Current use of these compounds account for approximately 27 percent of the VOC emissions from automotive refinishing coatings. To some ex tent these TACs can be reduced by reformulation to lower VOC coatings. District Rule 102 (Definitions) lists Tertiary Butyl Acetate (t-butyl acetate) TBAC or TBAc as an exempt organic compound that is not a VOC for pur poses of VOC emissions lim itations or VOC content requirements. It is esti mated that TBAC could be used to substitute toluene, xylenes, and MEK by as much as 50 per cent, thereby substantially reducing
VOC emissions.

Pursuant to the Section 15061, Subsections (2) & (3) of the CEQA Guidelines, staff will prepared and file a Notice of Ex emption for this project upon adoption.

XVI I. SOCIOECONOMIC IMPACTS

CHSC Section 40728.5 exempt s districts with a population of less than 500,000 persons from the requirement to asse ss the socioeconomic impacts of adopting rules. Eastern Kern County popula tion is below 500,000 persons.

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## APPENDIX A:

AMENDED RULE 410.4A

MOTOR VEHICLE AND MO BILE EQUIPMENT

REFINISHING OPERATIONS410.4A Final Staff Report – Amended Rule

RULE 410.4A Motor Vehicle and Mobile Equipment Refinishing Operations - Adopted 5/6/91, Amended 4/6/95, 3/7/96, 3/13/14 I. Purpose

The purpose of this rule is to limit volatile organic compound (VOC) emissions from coatings and solvents used in production, repair , refinish, or maintenance operations where motor vehicles, mobile equipment, or a ssociated parts and components are coated.

II. Applicability

The provisions of this Rule are enforceable upon amendment date and shall apply to any person who supplies, sells, offers for sale, manufactures, distributes, uses, applies, or solicits the use or application of any automotiv e coating or associated solvent within the

District.

III. Severability

Each provision of this rule sha ll be deemed severable, and in the event that any provision of this rule is held to be invalid, the remainder of this rule shall con tinue in full force and

effect.

IV. Definitions

A. Adhesion Promoter : A coating, which is labeled a nd formulated to be applied to uncoated plastic surfaces to facilitate bonding of subseque nt coatings, and on which, a subsequent coating is applied.

B. Aerosol Coating Product : A pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held application, or for use in specialized equipment for ground traffic/marking applications.

C. APCO : Air Pollution Control Officer of th e Eastern Kern Air Pollution Control

District.

D. Assembly Line : An arrangement of industrial eq uipment and workers in which the product passes from one specialized operati on to another until complete, by either

automatic or manual means.

E. Associated Parts and Components : Structures, devices, pi eces, modules, sections, assemblies, subassemblies, or elements of mo tor vehicles or mobile equipment that are designed to be a part of moto r vehicles or mobile equipment but which are not attached to motor vehicles or mobile equipment at the time of coating the structure, device, piece, module, section, assembly, subassembl y, or element. “Associated parts and components” does not in clude circuit boards.

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F. Autom otive Coating : Any coating or coating component used or recommended for use in motor vehicle or mobile equipment re finishing, service, maintenance, repair, restoration, or modification, except metal plating activities. Any reference to automotive refinishing or automotive coating made by a person on the container or in product literature constitutes a recommendati on for use in motor vehicle or mobile equipment refinishing.

G. Automotive Coating Component : Any portion of a coating, including, but not limited to, a reducer or thinner, t oner, hardener, and additive, which is recommended by any person to distributors or end-users for us e in an automotive coating, or which is supplied for or used in an automotive coat ing. The raw materials used to produce the components are not considered automotive coating components.

H. Automotive Refinishing Facility : Any shop, business, locatio n, or parcel of land where motor vehicles or mobile equipment or th eir associated parts and components are coated, including autobody collision repair shops. “Automotive Refinishing Facility” does not include the original equipment manuf acturing plant where the motor vehicle or mobile equipment is completely assembled.

I. California Air Resources Board (CARB or ARB) : Air Resources Board of the California Environmental Protection Agency.

J. Cleaning Operations : The removal of loosely held uncur ed adhesives, inks, coatings, or contaminants, including, but not limited to, dirt, soil, or grease, from motor vehicles, mobile equipment, associated parts and components, substr ates, parts, products, tools, machinery, equipment, or general work areas.

K. Clear Coating : Any coating that contains no pigm ents and is labeled and formulated for application over a color coating or clear coating.

L. Coating : A material which is applied to a surf ace and forms a film in order to beautify, preserve, repair, or protect such a surface.

M. Color Coating : Any pigmented coating, excluding adhesion promoters, primers, and multi-color coatings, that requires a subsequent clear coating and which is applied over a primer, adhesion promoter, or colo r coating. Color coatings include metallic/iridescent color coatings.

N. Electrodeposition : Applying an electrically-charged dip coating onto object to be

coated.

O. Electrostatic Spray Application : Any method of spray applic ation of coatings where an

electrostatic attraction is create d between the part to be coat ed and the paint particles.

P. Emission Control System : Any combination of capture systems and control devices

used to reduce VOC emissions from automotive coating operations.

Q. EPA : The United States Environmental Protection Agency.

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R. Exem pt Compounds : As defined in District Rule 102, Definitions, “Exempt Compounds”.

S. Graphic Arts Operation : Application of logos, letters, num bers or graphics to a painted surface with or without use of a template.

T. High-Volume, Low-Pressure (HVLP) : Spray equipment permanently labeled as such and which is designed and operated between 0.1 and 10 pounds per square inch, gauge, (psig) air atomizing pressure measured dynami cally at the center of the air cap and at the air horns and with liquid supply pressure less than 50 psig.

U. Metallic/Iridescent Topcoat : Coating as applied cont aining more than 5 g/1 (0.042 lb/gal) of visible metal or iridescent particle s, where such particles are visible in the

dried film.

V. Mobile Equipment : Equipment drawn or capable of being driven on a roadway, including, but not limited to a: truck body, truck trailer, util ity body, camper shell, mobile crane, bulldozer, c onstruction and farm heavy equipment, concrete mixers, street cleaner, golf cart, all terrain vehicl es, implements of husbandry, military tank or other tracked military vehicle and hauling equipment used inside and around airports, depots, and industrial and commercial plants.

W. Motor Vehicle : As defined in Rule 102, Definitions.

X. Multi-Color Coating : Any coating that exhibits more than one color in the dried film after a single application, is packaged in a single container, and hi des surface defects on areas of heavy use, and which is app lied over a primer or adhesion promoter.

Y. Precoat : Coating applied to bare metal primarily to deactivate metal surface for

corrosion resistance and adhesion.

Z. Pretreatment Coating : Coating containing a minimum of 0.5% acid by weight and not more than 16 percent solids by weight necessary to provide surface etching and is labeled and formulated for application dire ctly to bare metal surfaces to provide

corrosion resistance and adhesion.

AA. Primer : Any coating, which is labeled and formul ated for application to a substrate to provide 1) a bond between the substrate and s ubsequent coats, 2) corrosion resistance, 3) a smooth substrate surface, or 4) resistan ce to penetration of subsequent coats, and on which a subsequent coating is applied. Primers may be pigmented.

BB. Refinish : Coating of vehicles, their parts a nd components, or mobile equipment, including partial body collision repairs, for the purpose of protecti on or beautification and subsequent to the original coating app lied at an Original Equipment Manufacturing (OEM) plant coating assembly line.

CC. Single-Stage Coating : Any pigmented coating, excl uding primers and multi-color coatings, labeled and formulated for app lication without a subsequent clear coat. Single-stage coatings include single-stage metallic/iridescent coatings.

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DD. Solvent : As defined in Rule 410.3, Organi c Solvent Degreasing Operations.

EE. Spray Booth : Any power ventilated structure of varying dimensions and construction provided to enclose or accommodate a spraying operation and which meets the Uniform Fire Code. A spray booth shall conf ine and limit, by dry or wet filtration, the escape to the atmosphere of overspray particulate matter, exhaust through filters or other air pollution control device appr oved by the APCO and provide adequate ventilation, air velocity, and safety features, as require d by the Uniform Fire Code.

FF. Specialty Coating : Coating necessary for unusual job performance requirements, including, but not limited to, adhesion promot ers, uniform finish blenders elastomeric materials, gloss flatteners, bright metal trim repair, anti-glare/safety coatings, and cut in or jambing clear coatings.

GG. Spot/Panel Repair : Non-assembly line process of re pairing and restoring a portion of a motor vehicle, or associated parts or compone nts of less than 1 square foot (929 square centimeters).

HH. Surface Preparation : The use of VOC containing solv ents applied with cloth, sponge, or other medium for the purpose of removing dust, grease, and other contaminants from a surface just prior to ap plication of a coating.

II. Temporary Protective Coating : Any coating which is labeled and formulated for the purpose of temporarily protecting areas fr om overspray or mechanical damage.

JJ. Topcoat : Coating applied over a primer or an original equipment ma nufacturer finish for the purpose of protection or appearance.

KK. Touch-Up Coating : A coating used to cover minor coating imperfections appearing after the main coating operation.

LL. Transfer Efficiency : The amount of coating solids a dhering to the object being coated divided by the total amount of coating so lids sprayed, expressed as a percentage.

MM. Truck Bed Liner Coating : Any coating, excluding clear, color, multi-color, and single stage coatings, labeled and formulated for a pplication to a truck bed to protect it from

surface abrasion.

NN. Underbody Coating : Any coating labeled and formulated for application to wheel wells, the inside of door pane ls or fenders, the undersid e of a trunk or hood, or the

underside of the motor vehicle.

OO. Uniform Finish Coating : Any coating labeled and form ulated for application to the area around a spot repair for the purpose of blending a repaired area’s color or clear coat to match the appearance of an adjacent area’s existing coating.

PP. Utility Body : Special purpose service compartmen t or unit to be bolted, welded, or affixed onto an existing cab and chassis. Such compartment may serve as storage for equipment or parts.

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QQ. Volatile Organic Compound (VOC) : Any compound containing at least one atom of carbon, excluding Exempt Compounds as li sted in Rule 102 Definitions.

RR. VOC Content:

1. VOC regulatory for Coatings : VOC in grams per liter of coating, excluding water and exempt compounds, and shall be cal culated by the following equation:

VOC regulatory content = Wv - Ww - Wec

Vm - Vw – Vec

2. VOC actual for Coatings : VOC in grams per liter of material shall be calculated using the following equation:

VOC actual content = Wv - Ww - Wec

Vm

3. VOC content for Solvents : VOC in grams per liter of material shall be calculated by the following equation:

VOC content = Wv - Ww - Wec

Vm

Where: VOC content = amount of volatile organic compounds in grams/liter Wv = weight of volatiles in grams Ww = weight of water in grams Wec = weight of exempt compounds in grams Vm = volume of material (coating or solvent, as applicable) in liters

Vw = volume of water in liters Vec = volume of exempt compounds in liters

V. Exemptions

A. Requirements of this Rule shall not apply to the fo llowing operations:

1. Graphic Arts Operations as defined in Section IV.S.

2. Any automotive coating or associated so lvent that is offered for sale, sold, or supplied in 0.5 fluid ounce or smaller containe rs intended to be used by the general public to repair tiny surface imperfections.

3. Coating operations employing hand-held non- refillable aerosol cans, 18 oz. or less, provided the area to be covered does not ex ceed nine square feet per vehicle to repair minor surface damage and imperfections.

4. Any automotive coating or associated solv ent that is offered for sale, sold, or

manufactured for use outside of the District or for shipment to other manufacturers for reformulation or repackaging.

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5. Any coating applied to motor vehicles or mobile equipment, or their associated parts and components, during ma nufacture on an assembly line.

B. Requirements of Section VI.D (Spray Booth) shall not apply to:

1. Touch-up coating operations as defined in Section IV.KK, not exceeding nine square feet per vehicle.

2. Coating of motor vehicle engine compar tments, engine components, and suspension components, provided such component s are replaced in the vehicle.

3. Application of primers, primer surfacers and precoats not exceeding nine square feet per vehicle, provided VOC cont ent does not exceed 250 g/l and coatings

contain no lead or chromium compounds.

4. Application of coatings to a vehicle, due to shape or size, not reasonably contained in a spray booth. To qualify for this ex emption a person shall comply with the following requirements:

a. Submit a written request on a case by case basis to the APCO describing vehicle(s) to be coated, size of spray booth, physical size of vehicle(s) (length, width, and height), number of vehicle(s) to be coated, time required to paint vehicle(s), estimated volume of coating(s) to be used, date when vehicle(s) or mobile equipment is to be coated, and VOC content of each coating used;

b. Such request shall be submitted ten cal endar days prior to surface coating a motor vehicle or mobile equipment outside a spray booth. The APCO shall provide a written determination to the re quester within five calendar days of proposed surface coating of the motor vehicle or mobile equipment; and

c. The APCO may grant written approval for a specified time period, not to exceed

one year.

C. Coating operations and/or facilities exempt from this Rule shall comply with all other applicable District prohibitory Rules.

D. Provisions of Sections VI .C. through VI.G. and Section VII. shall not apply to coating of one vehicle per twelve month period, by th e registered owner of the vehicle being painted, provided the surface coating does not contain lead or ch romium compounds.

E. Section VI.F, Surface Preparation and Equipment Cleanup Requirements, shall not apply to the use of surface pr eparation solvents to clean plastic parts just prior to coating or VOC-containing materials for the removal of wax and grease provided that nonaerosol, hand-held spray bottles are used with a maximum solvent VOC content of 780 g/l and the total volume of the solvent does not exceed 20 gallons per year per facility. Records of solvent usage shall be kept in accordance with Section VII.C.4 of

this Rule.

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VI. Requirements

A. VOC Content Limits : No person shall apply a coati ng to any motor vehicle, mobile equipment, or its associated parts and com ponents, with a VOC regulatory content, as calculated pursuant to Section IV.RR.1, in excess of the limits expressed in Table of Standards, except as provided in Sections VI.C and VI.J.

TABLE OF STANDARDS

VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS Content expressed in Grams per Liter (Pounds per Gallon) Less Water and Exempt Compounds

Coating Category VOC Limit

Adhesion Promoter 540 (4.5)

Cavity Wax 650 (5.4)

Clear Coating 250 (2.1)

Color Coating 420 (3.5)

Deadener 650 (5.4)

Gasket/Gasket Sealing Material 200 (1.7)

Lubricating Wax/ Compound 700 (5.8)

Multi-Color Coating 680 (5.7)

Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Sealer 650 (5.4)

Single-Stage Coating 340 (2.8)

Specialty Coating 540 (4.5)

Temporary Protective Coating 60 (0.5)

Truck Bed Liner Coating 200 (1.7)

Trunk Interior Coating 650 (5.4)

Underbody Coating 650 (5.4)

Uniform Finish Coating 540 (4.5)

Any other coating type 250 (2.1)

B. Most Restrictive VOC Limit : If anywhere on the container of any automotive coating, or any label or sticker affixed to the container, or in any sa les, advertising, or technical literature supplied by a person, any representation is made that indicates that the coating meets the definition of or is reco mmended for use for more than one of the coating categories listed in Tabl e of Standards, then the lowest VOC content limit shall apply.

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C. Alternate Emission Control : In lieu of complying with VOC content limits specified in Table of Standards, an emission control syst em with a capture efficiency of at least 90% and a control efficiency of at least 90% may be used if it has been approved in writing by the Air Pollution C ontrol Officer (APCO). A ny approved emission control system must be maintained and used in prope r working condition at all times. Use of a VOC emission control system sh all not result in emissions in excess of those that would have been emitted had the operator complied with the provisions of Section V.A.

D. Spray Booth : All surface coatings subject to this Rule sh all be applied within a permitted, properly maintained, and operational paint spray booth located at a site with proper city or county zoning.

E. Coating Application Methods : No person shall apply any co ating to any motor vehicle, mobile equipment, or associated parts and components unless one of the following application methods is used:

1. Brush, dip, flow, or roll coating conducted in accordance with manufacturer's

recommendations.

2. Electrostatic or electrodeposition ap plication conducted in accordance with

manufacturer's recommendations.

3. HVLP spray equipment operated in accordance with manufacturer's

recommendations.

4. Spray gun: If a spray gun is used, the e nd user must demonstrate that the gun meets

the HVLP definition in Section IV.T in design and use. A satisfactory

demonstration must be based on the manuf acturer's published technical material on the design of the gun and by a demonstration of the operation of the gun using an air pressure tip gauge from the manufacturer of the gun.

5. Any alternative coating a pplication method which has been demonstrated to achieve at least 65% transfer efficiency or th e equivalent efficiency of an HVLP and approved, in writing, by APCO.

Section VI.E does not apply to underbody coat ings, graphic arts operations, truck bed liner coatings, or any coating use of less than one (1) fluid ounce (29.6 milliliters).

F. Surface Preparation and Equipment Cleanup Requirements : No person shall conduct surface preparation or equipment cleanup for act ivities subject to provisions of this Rule unless the following VOC limits are met and methods are used:

1. VOC content of surface preparation solvent shall not ex ceed 25 g/l (0.2 lb/gal), as calculated pursuant to Section IV .RR.3, unless Section V.E applies.

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2. Coatings Application Equipment Cleaning : Solvents used for cleaning of coatings application equipment shall comply with both limits specified below:

a. Solvent shall have a VOC content of 950 grams or less per liter (7.9 lb/gal) of material; and

b. Solvent shall have a VOC composite pa rtial pressure of 35 mm Hg or less at 20/C (68/F).

3. Cleaning Devices and Methods Requirements : No person shall perform solvent cleaning operations unless one of the fo llowing cleaning devices or methods is

used:

a. Wipe cleaning;

b. Spray bottles or containers with a maximum capacity of 16 fluid ounces from which solvents are applied wit hout a propellant-induced force;

c. Cleaning equipment having a clos ed solvent container during cleaning operations, except when depositing and removing objects to be cleaned, and closed during nonoperation except during maintenance and repair of the cleaning equipment itself;

d. Remote reservoir cold cleaner operate d in conformance with District Rule 410.3, Organic Solvent Degreasing Operations;

e. System totally enclosing spray guns , cups, nozzles, bowls, and other parts during washing, rinsing, a nd draining procedures;

f. Non-atomized solvent fl ow method collecting cleaning solvent in a container or a collection system closed except fo r solvent collection openings and, if necessary, openings to avoid excessive pre ssure build-up inside the container; or

g. Solvent flushing method discharging cl eaning solvent into a container closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the cont ainer. Discharged solvent from such equipment shall be collected into contai ners without atomizing into open air. Solvent may be flushed through the system by air or hydraulic pressure, or by pumping.

G. Storage and Disposal : Regardless of VOC content, al l automotive coating components, automotive coatings, and solvents, shall be stored in non-absorbent, vapor-tight containers kept closed at all tim es except when filling or emptying.

H. Prohibition of Sale or Manufacture : No person shall manufacture, blend, repackage for sale, supply, sell, offer for sale or distribute within the District any coating with a VOC content in excess of the limits specified in Section VI.A.

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Notwithstanding the provisions of this section, a person m ay manufacture, blend, repackage for sale, supply, sell, offer for sale, or distribute a coating with a VOC content in excess of the limits specifi ed in section VI.A under the following circumstances and provided all of the requi rements of section V II.C.6 are also met:

1. The coating is used exclusively within an emission control system as allowed in Section VI.C, or

2. Coating is exempt under one or more of the provisions of Section V.A.

I. Prohibition of Specification : No person shall solicit or require the use of, or specify the application or use of any coating or solvent on a motor vehicle or mobile equipment, or its associated parts and components, if such use or application resu lts in a violation of this Rule. This prohibition shall apply to al l written or oral cont racts, including but not limited to, job orders, under the terms of which any coating or solvent subject to provisions of this Rule is to be applied. Th is prohibition shall not apply to coatings or solvents that meet the criteria specified in Section VI.H.

J. Sell-Through/Existing Stock of Coatings : A coating manufactured prior to amendment date of this rule, that complied with the VOC Content limit(s) in effect at that time, may be sold, supplied, or offered for sale for 12 months after rule adoption date. Such a coating may be applied at any time, both before and after adoption date, provided

manufacture Date-Code and VOC Content is clearly prin ted on coating container.

VII. Administrative Requirements

A. Compliance Statement Requirement

1. For each individual automotive coating or automotive coating component, the manufacturer and repackag er shall include the following information on product data sheets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in grams per liter; b. The weight percentage of vola tiles, water, and exempt compounds; c. The volume percentage of water and exempt compounds; and d. The density of the material (in grams per liter).

2. For each individual ready to spray mi xture (based on the manufacturer’s and repackager’s stated mix ratio), the manuf acturer and repackager shall include the following information on product data sh eets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in grams per liter; b. The weight percentage of vola tiles, water, and exempt compounds; c. The volume percentage of water and exempt compounds; and d. The density of the material (in grams per liter).

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3. The manufacturer and repackager of solven ts subject to this rule shall include the VOC content as supplied, calculated pursu ant to section IV.RR.3, expressed in grams per liter, on product data sheets, or an equivalent medium.

B. Labeling Requirements

1. The manufacturer and repackager of automotive coatings or automotive coating components shall include on all containers the applicable use category(ies), and the VOC actual for coatings and VOC regulatory for coatings, as supplied, expressed in grams per liter.

2. The manufacturer and repackager of solven ts subject to this rule shall include on all containers the VOC content for solvents, as supplied, expressed in grams per liter.

C. Record Keeping Requirements

Any person who uses coatings or solvents, subj ect to this rule, shall maintain and have the following available on site at all times:

1. A current list of all VOC containing products in use that includes any data necessary to evaluate compliance, in cluding but not limited to, the following information as applicable:

a. Material name and manu facturer's identification; b. Application method; c. Material type (coating as listed in Table of Standards) and specific use instructions; d. Specific mixing instructions; e. VOC actual and VOC regulatory for co atings, as applied, or VOC content for

solvent.

2. Daily coating and solvent use records, in cluding the following information for each:

a. Volume of each coating/solvent mix ratio; b. VOC content in grams/liter (or pounds/gallon) as applied/used; c. Volume of each coating/solvent in liters (or gallons) applied/used; d. Type and amount of solvent used for cleanup and surface preparation.

If purchase records are used to determine the amount of solvents used, then records and manifests of the amounts of solvents dispos ed of or sent to a recycler must also be maintained and made available to the APCO upon request.

3. Current manufacturer specification sheets, mate rial safety data sheets, technical data sheets, or air quality data sheets, whic h list the VOC actual for coatings and VOC regulatory for coatings of each ready-to-s pray coating (based on the manufacturer’s stated mix ratio), and VOC content of each solvent.

4. Purchase records identifying the coating t ype (as listed in Table of Standards), name, and volume of coatings and solvents.

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5. Alternate Emissions Control Records : Any person using an emission control system shall maintain daily records of ke y system operating parameters which will demonstrate continuous operation and comp liance of the emission control system during periods of VOC emission produci ng activities. “Key system operating parameters” are those parameters necessary to ensure or document compliance with Section VI.C., including, but not limited to, temperatures, pressure drops, and air

flow rates.

6. Record Keeping Requirements for Prohibition of Sale : Any person claiming an exception specified in Section VI.H shall keep a detailed log of each automotive coating component and automotive coati ng manufactured, blended, repackaged for sale, supplied, sold, offered for sale, or distributed showing:

a. The quantity manufactured, blended, rep ackaged for sale, supplied, sold, offered for sale, or distributed, includi ng size and number of containers; b. The VOC regulatory for coatings; c. The VOC actual for coatings; d. To whom they were supplied, sold, offere d for sale, or distributed, or for whom they were manufactured, blended, or re packaged for sale including the name, address, phone number; and e. The specific exception being utilized under Section VI.C.

7. Record Retention : Records required by this Rule shall be retained for a minimum of three years and made availa ble to the APCO upon request.

VIII. Test Methods

The following test methods are incorporated by re ference herein, and sha ll be used to test emission sources subject to the prov isions of this rule. A source is in violation of this rule if any measurement by any of the listed appli cable test methods exceeds any standard of

this rule.

A. Acid Content : Measure of acid cont ent shall be determined by using ASTM D1613-03 “Standard Test Method for Acidity in Volati le Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products” (October 2003).

B. Analysis of Samples : Samples of VOC as specified in this Rule shall be analyzed by EPA Method 24 as set forth in Appendix A of Title 40 of the Code of Federal Regulations (40 CFR) Part 60, “Determinati on of Volatile Matt er Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings”. Analysis of halogenated exempt compounds shal l be conducted using CARB Method 422, “Determination of Volatile Organic Compounds in Emissions from Stationary Sources” (September 12, 1990).

C. Alternative Test Methods : The use of other test methods which are determined to be equivalent or better and approved, in writing, by the AP CO, ARB, and EPA may be used in place of the test me thods specified in this rule.

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Appendix A A-13 Draft 3/13/2014 D. Control and Capture Efficiency : Capture and control effi ciency of emission control systems shall be determined as specified in EPA’s “Guidelines for Determining Capture Efficiency,” (January 9, 1995) and 40 CFR 51, Appendix M, Methods 204-204f as applicable. Total organic emissions of em ission control systems shall be determined using EPA Method 25, 25A or 25B.

E. Determination of Emissions : Emissions of VOC shall be measured by EPA Method 25, 25A, or 25B, as applicable and analysis of halogenated exempt compounds shall be conducted using CARB Method 432, “Determi nation of Dichloromethane and 1,1,1- Trichloroethane in Paints and Coatings” (September 12, 1998).

F. Exempt Organic Compound Content of Coatings : The exempt organic compound content of coatings or solvents shall be determined using ASTM Method D 6133- 02, Standard Test Method for Acetone, p-Chlorobe nzotrifluoride, Methyl Acetate, or tButyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw Materials by Direct Injection into a Chromatograph. Exempt organic compound content, other than as determined above , shall be determined by using CARB Method 422, CARB Method 432, or South Coast AQMD Method 303-91, “Determination of Exempt Compounds” (February 1993).

G. HVLP Equivalency : Spray Equipment HVLP equivalency shall be determined by using South Coast Air Quality Management District’s “Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient Spray Guns” (September 26, 2002).

H. Metallic Content : The metallic content of a coating shall be determined by South Coast Air Quality Management Dist rict Test Method 318-95, " Determination of Weight Percent Elemental Metal in Coatings by X-ray” (July 1996).

I. Transfer Efficiency : Spray equipment transfer efficiency shall be determined by using South Coast Air Quality Management Dist rict Method "Spray Equipment Transfer Efficiency Test Procedure for Equipment User", (May 24, 1989).

J. VOC Composite Partial Pressures : VOC composite partial pressures shall be determined using either manufacturer's in formation regarding formulation or using ASTM Methods E169-04, Standard Practices for General Techniques of UltravioletVisible Quantitative Analysis or E260-96, St andard Practice for Packed Column Gas Chromatography for determination of mole fractions and then summing products of each VOC component's vapor pressure and its mole fraction. For materials containing no non-VOC components, VOC composite partial pressure can be measured directly by

ASTM Method D2879-10 Standard Test Met hod for Vapor Pressure-Temperature Relationship and Initial Decomposition Te mperature of Liquids by Isoteniscope.

K. VOC Emissions from Spray Gun Cleaning Systems : VOC emissions shall be determined using South Coast AQMD "General Test Method for Determining Solvent Losses from Spray Gun Cleaning Systems" (October 3, 1989).

## APPENDIX B:

AMENDED RULE 410.4A

MOTOR VEHICLE AND MO BILE EQUIPMENT

REFINISHING OPERATIONS

STRIKEOUT UNDERLINE VERSION410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-1 Draft 3/13/2014 RULE 410.4A Motor Vehicle and Mobile Equipment Refinishing Operations - Adopted 5/6/91, Amended 4/6/95, 3/7/96 , 3/13/14

I. Purpose

The purpose of this rule is to limit volatile organic compound (VOC) emissions from coatings and solvents used in production, re pair, refinish, or maintenance operations where motor vehicles, mobile equipment, or associated parts and components are coated.

II. Applicability

The provisions of this Rule are enforceable upon amendment date and shall apply to any person who supplies, sells, offers for sale, manufactures, distributes, uses, applies, or solicits the use or application of any automotiv e coating or associated solvent within the

District.

III. Severability

Each provision of this rule sha ll be deemed severable, and in the event that any provision of this rule is held to be invalid, the remainde r of this rule shall c ontinue in full force and

effect.

II IV . Definitions

A. Adhesion Promoter: A coating, which is labeled and formulated to be applied to uncoated plastic surfaces to facilitate bonding of subseque nt coatings, and on which, a subsequent coating is applied.

B. Aerosol Coating Product: A pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held application, or for use in specialized equipment for ground traffic/marking applications.

C. APCO: Air Pollution Control Officer of the Eastern Kern Air Pollution Control

District.

A

. Antiglare Coating : coating not reflecting light. D. Assembly Line: An arrangement of i ndustrial equipment and workers in which the product passes from one specialized operati on to another until complete, by either

automatic or manual means.

E. Associated Parts and Com ponents: Structures, devices , pieces, modules, sections, assemblies, subassemblies, or elements of motor vehicles or mobile equipment that are designed to be a part of motor vehicles or mobile equipment but which are not attached to motor vehicles or mobile equi pment at the time of coating the structure, device, piece, module, section, assembly, s ubassembly, or element. “Associated parts and components” does not include circuit boards.

F. Automotive Coating: Any coating or coating component used or recommended for use in motor vehicle or mobile equipment refinishing, service, maintenance, repair,410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-2 Draft 3/13/2014 restoration, or modification, except metal plating activities. Any reference to automotive refinishing or automotive coating made by a person on the container or in product literature constitutes a recommendati on for use in motor vehicle or mobile equipment refinishing.

G. Automotive Coating Component: Any porti on of a coating, including, but not limited to, a reducer or thinner, t oner, hardener, and additive, which is recommended by any person to distributors or end-users for us e in an automotive coating, or which is supplied for or used in an automotive coat ing. The raw materials used to produce the components are not considered automotive coating components.

H. Automotive Refinishing Facility: Any shop, business, location, or parcel of land where motor vehicles or mobile equipment or their associated parts and components are coated, including autobody collision re pair shops. “Automotive Refinishing Facility” does not include the original equipment manufacturing plant where the motor vehicle or mobile equipment is completely assembled.

B. Basecoat/Clearcoat System : topcoat system composed of pigmented basecoat

followed by transparent clearcoat. A basecoat/c learcoat system's Volatile Organic Compound (VOC) content shall be calculat ed using the following formula:

VOC bc/cc = VOC bc + 2 VOC

cc

3

Where: VOC bc/cc = sum of VOC content as applie d in basecoat (bc) and clearcoat (cc)

system. VOC bc = VOC content as applied of any given basecoat.

2 VOC cc = two times VOC content as applied of any given clearcoat.

C

. Camouflage Coating : applied on military vehicle or mobile equipment intended to conceal such equipment from detection.

I. California Air Resources Board (CARB or ARB): Air Resources Board of the California Environmental Protection Agency.

D

. Catalyst : substance enhancing a reacti on between chemical compounds.

J. Cleaning Operations: The removal of loos ely held uncured adhesives, inks, coatings, or contaminants, including, but not limited to, dirt, soil, or grease, from motor vehicles, mobile equipment, associated parts and components, substrates, parts, products, tools, machinery, equipment, or general work areas.

K. Clear Coating: Any coating that contains no pigments and is labeled and formulated for application over a color coating or clear coating.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-3 Draft 3/13/2014 L. Coating: A material which is applied to a surface and forms a film in order to beautify, preserve, repair, or protect such a surface.

M. Color Coating: Any pigmented coating, excluding adhesion promoters, primers, and multi-color coatings, that requires a subsequent clear coating and which is applied over a primer, adhesion promoter, or co lor coating. Color coatings include metallic/iridescent color coatings.

E

. Color Match : ability of a repair coating to blend in to an existing coating so colo r differences are not visible.

F N . Electrodeposition : applying Applying an electrically-charg ed dip coating onto object to be coated.

G O . Electrostatic Spray Application : Any method of spray appl ication of coatings

where an electrostatic attraction is created be tween the part to be coated and the paint particles. spraying an electrically

- charged coating onto an object.

P. Emission Control System: Any combinati on of capture systems and control devices

used to reduce VOC emissions from automotive coating operations.

Q. EPA: The United States Environmental Protection Agency.

H R . Exempt Compounds : As defined in District Rule compounds identified as exempt under the definition of volatile organic compounds 102, Subsection L. Definitions, “Exempt Compounds”.

I

. Extreme Performance Coating : coating used on surface of Group II Vehicle, Mobile Equipment, or their parts or components, in tended, during use, to be exposed to any of the following during use:

1. Industrial grade detergen ts, cleaners, or abrasi ve scouring agents,

2. Unprotected shipboard conditions, or

3. Corrosive environmental conditions.

J

. Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt Compounds : weight of VOC per combined volum e of VOC and coat ing solids shall

be calculated using the following equation:

Grams of VOC per Liter of Coating Applied, Excluding Water and Exempt Compounds = Ws

- Ww

- Wec

Vc

- Vw

–Vec

Where: Ws = weight of VOC in grams Ww = weight of water in grams Wec = weight of exempt compounds in grams Vc = volume of coating in liters410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-4 Draft 3/13/2014 Vw = volume of water in liters Vec = volume of exempt compounds in liters

K

. Grams of VOC per liter of Material : weight of VOC per volume of material using the following equation:

Grams of VOC per Liter of Mate rial = Ws

- Ww

- Wec

Vm

Where: Ws = weight of VOC in grams Ww = weight of water in grams Wec = weight of exempt compounds in grams

Vm = volume of material in liters

L S . Graphic Arts Operation : application Application of logos, letters, numbers or graphics to a painted surface with or w ithout use of a template.

M. Group I Vehicle : passenger car, large/h eavy duty truck cab a nd chassis, light and medium duty truck or van, or motorcycle.

N. Group II Vehicle : bus.

O T . High-Volume, Low-Pressure (HVLP) Spray : Spray equipment permanently labeled as such and which is designed and operated applying coating using a gun operating between 0.1 and 10 pounds per square inch, gauge, ( psig ) air atomizing

pressure measured dynamically at the center of the air cap and at the air horns and with liquid supply pressure less than 50 psig.

P

. Large /Heavy Duty Truck : truck having a manufacturer's gross vehicle weight rating of over 10,000 pounds.

Q. Light and Medium Duty Truck or Van : truck or van having a manufactur er's gross vehicle weight rating of 10,000 pounds or less.

R U . Metallic/Iridescent Topcoat : coating Coating as applied containing more than 5 g/1 (0.042 lb/gal) of visible me tal or iridescent particles , where such particles are

visible in the dried film.

.

V. S. Mobile Equipment : equipment Equipment drawn or capable of being driven on a roadway, including, but not limited to a: truc k body, truck trailer, utility body, camper shell, mobile crane, bulldozer, construction and farm heavy equipment, concrete mixers, street cleaner, golf cart, all terrain vehicles, implements of husbandry, military tank or other tracked military vehicle and hauling equipment used inside and around airports, depots, and indus trial and commercial plants

.

W. Motor Vehicle: As defi ned in Rule 102, Definitions.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-5 Draft 3/13/2014 T

. Multistage Topcoat : topcoat system consisting of ba secoat/clearcoat system (two

stage) or basecoat/midcoat/clearcoat system (three

- stage).

X. Multi-Color Coating: Any coating that exhibits more th an one color in the dried film after a single application, is packaged in a single container, and hides surface defects on areas of heavy use, and which is app lied over a primer or adhesion promoter.

U Y . Precoat : coating Coating applied to bare metal primarily to deactivate metal

surface for corrosion resistance and adhesion. For compliance with this Rule, any precoat shall be followed by a water

- based primer coat.

V Z . Pretreatment Wash Primer Coating : coating Coating containing a minimum of 0.5% acid by weight and not more than 16 percent solids by weight

, necessary to provide surface etching and is labeled and formulated for application , and applied directly to bare metal surfaces to pr ovide corrosion resistance and adhesion.

W AA . Primer : Any coating, which is labeled and formulated for application to a substrate to provide 1) a bond between the substrate a nd subsequent coats, 2) corrosion resistance, 3) a smoot h substrate surface, or 4) resistance to penetration of subsequent coats, and on which a subse quent coating is applied. Primers may be pigmented. coating applied prior to applicati on of a topcoat for the purpose of

corrosion resistance and adhesion of the topcoat.

X. Primer Sealer : coating applied prior to applicati on of a topcoat for the purpose of

corrosion resist ance, adhesion of the topcoat, co lor uniformity, and to promote the ability of an undercoat to resi st penetration by the topcoat.

Y. Primer Surfacer : coating applied prior to applica tion of a topcoat for the purpose of corrosion resistance, adhesion of t he topcoat, and promoting a uniform surface by filling in surface imperfections.

Z

. Reducer/Thinner : solvent used to thin coating.

AA BB . Refinish : coating Coating of vehicles, their parts and components, or mobile equipment, including partial body collision repairs, for th e purpose of protection or beautification and subsequent to the original coating applied at an Original Equipment Manufacturing (OEM) plant coating assembly line.

CC. Single-Stage Coating: Any pigmented coating, excluding prim ers and multi-color coatings, labeled and formulated for app lication without a subsequent clear coat. Single-stage coatings include single-stage metallic/iridescent coatings.

DD. Solvent: As defined in Rule 410.3, Organic Solvent Degreasing Operations.

EE. Spray Booth: Any power ventilated struct ure of varying dimens ions and construction provided to enclose or accommodate a spraying operation and which meets the Uniform Fire Code. A spray booth shall conf ine and limit, by dry or wet filtration, the escape to the atmosphere of overspray particulate matter, exhaust through filters or other air pollution control device appr oved by the APCO and provide adequate ventilation, air velocity, and safety features, as require d by the Uniform Fire Code.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-6 Draft 3/13/2014 BB FF . Specialty Coating : coating Coating necessary due to for unusual job performance requirements, including, but not limited to, adhesion promoters, uniform finish blenders elastomeric materials, gloss flatteners, bright metal trim repair, and antiglare/safety coatings , and cut in or jambing clear coatings.

.

CC GG . Spot/Panel Repair : non Non -assembly line process of repairing and restoring a portion of a motor vehicle

, or associated parts or com ponents of less than 1 square foot (929 square centimeters) to predamaged co ndition

.

HH. Surface Preparation: The use of VOC cont aining solvents applied with cloth, sponge, or other medium for the purpose of removi ng dust, grease, and other contaminants from a surface just prior to application of a coating.

II. Temporary Protective Coating: Any coati ng which is labeled and formulated for the purpose of temporarily protecting areas fr om overspray or mechanical damage.

DD

. Three

- Stage Coating System : topcoat system composed of pigmented basecoat, semitransparent midcoat, and tr ansparent clearcoat. A three

- stage coating system's

VOC content shall be calculat ed using the following formula:

VOC 3

- stage = VOC bc + VOC mc + 2 VOC cc

4

Where:

VOC 3

- stage = average VOC conten t as applied in a three

- stage coating system.

VOC bc = VOC content as applied of any given basecoat. VOC mc = VOC content as ap plied of any given midcoat.

2 VOC cc = two times VOC content as applied of any given clearcoat.

EE JJ . Topcoat : coating Coating applied over a primer or an original equipment manufacturer finish for the purpos e of protection or appearance.

FF KK . Touch-Up Coating : coating A coating used to cover minor coating imperfections appearing after the main coating operation. applied by brush, airbrush, detail HVLP spray equipment, or hand held , non

- refillable aerosol cans to repair minor surface damage and imperfections, after main coating process, and not exceeding nine square feet per vehicle.

LL. Transfer Efficiency: Th e amount of coating solids a dhering to the object being coated divided by the total amount of co ating solids sprayed, expressed as a

percentage.

MM. Truck Bed Liner Coating: Any coating, excluding clear, color, multi-color, and single stage coatings, labeled and formulated for application to a truck bed to protect

it from surface abrasion.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-7 Draft 3/13/2014 NN. Underbody Coating: Any co ating labeled and formulated for application to wheel wells, the inside of door pane ls or fenders, the undersid e of a trunk or hood, or the

underside of the motor vehicle.

OO. Uniform Finish Coating: Any coating la beled and formulated for application to the area around a spot repair for the purpose of blending a repaired area’s color or clear coat to match the appearance of an adjacent area’s existing coating.

GG PP . Utility Body : special Special purpose service compartmen t or unit to be bolted, welded, or affixed onto an existing cab and chassis. Such compartment may serve as storage for equipment or parts.

HH QQ . Volatile Organic Compound (VOC) : any Any compound containing at least one

atom of carbon , excluding Exempt Compounds as listed in Rule 102 Definitions. except for exempt compounds (see Subsection II.H.).

RR. VOC Content:

1. VOC regulatory for Coatings: VOC in gr ams per liter of coating, excluding water and exempt compounds, and shall be calculated by the following equation:

VOC regulatory content = Wv - Ww - Wec

Vm - Vw – Vec

2. VOC actual for Coatings: VOC in grams per liter of material shall be calculated using the following equation:

VOC actual content = Wv - Ww - Wec

Vm

3. VOC content for Solvents: VOC in grams per liter of material shall be calculated by the following equation:

VOC content = Wv - Ww - Wec

Vm

Where:

VOC content = amount of volatile organic compounds in grams/liter

Wv = weight of volatiles in grams

Ww = weight of water in grams

Wec = weight of exempt compounds in grams

Vm = volume of material (coating or solvent, as applicable) in liters

Vw = volume of water in liters410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-8 Draft 3/13/2014 Vec = volume of exempt compounds in liters

III V. Exemptions

A. Requirements of this Rule shall not apply to the fo llowing operations:

1. Graphic Arts Operations as defined in Subsection II.L Section IV.S.

2. Any automotive coating or associated so lvent that is offered for sale, sold, or supplied in 0.5 fluid ounce or smaller cont ainers intended to be used by the general public to repair tiny surface imperfections.

2 3. Coating operations employing hand-held non-refillable aerosol cans, 18 oz. or less, provided the area to be cove red does not exceed nine square feet per vehicle to repair minor surface damage and imperfections.

4. Any automotive coating or associated solv ent that is offered for sale, sold, or manufactured for use outside of the District or for shipment to other manufacturers for reformulation or repackaging.

5. Any coating applied to motor vehicles or mobile equipment, or their associated parts and components, during ma nufacture on an assembly line.

B. Requirements of Section IV.D VI.D (Spray Booth) shall not apply to:

1. Touch-up coating operations as defined in Section II.FF IV.KK , not exceeding nine square feet per vehicle.

2. Coating of motor vehicle engine compartments, engine components, and suspension components, provided such com ponents are replaced in the vehicle.

3. Application of primers, primer surfacers and precoats not exceeding nine square feet per vehicle, provided VOC cont ent does not exceed 250 g/l and coatings

contain no lead or chromium compounds.

4. Application of coatings to a vehicl e, due to shape or size, not reasonably contained in a spray booth. To qualify fo r this exemption a person shall comply with the following requirements:

a. Submit a written request on a case by case basis to the APCO Control Officer describing vehicle(s) to be coate d, size of spray booth, physical size of vehicle(s) (length, width, and height), nu mber of vehicle(s) to be coated, time required to paint vehicle(s), estimated vol ume of coating(s) to be used, date when vehicle(s) or mobile equipment is to be coated, and VOC content of each coating used;

b. Such request shall be submitted ten calendar days prior to surface coating a motor vehicle or mobile equipment outside a spray booth. The APCO Control

Officer shall provide a written determinati on to the requester within five410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-9 Draft 3/13/2014 calendar days of proposed surface coati ng of the motor vehicle or mobile equipment; and

c. The APCO Control Officer may grant written approval for a specified time period, not to exceed one year.

C. Coating operations and/or facilities exempt from this Rule shall comply with all other applicable District prohibitory Rules.

D. Provisions of Subsections Sections I VI. C. through VI. G. and Section V II. shall not apply to coating of one vehi cle per twelve month period, by the registered owner of the vehicle being painted, provided the surface coating does not contain lead or chromium compounds.

E. Section VI.F, Surface Preparation and Equipment Cleanup Requirements, shall not apply to the use of surface pr eparation solvents to clean plastic parts just prior to coating or VOC-containing materials for the removal of wax and grease provided that nonaerosol, hand-held spray bottles are used with a maximum solvent VOC content of 780 g/l and the total volume of the solven t does not exceed 20 gallons per year per facility. Records of solvent usage shall be kept in accordance with Section VII.C.4 of

this Rule.

I V I . Requirements

A. VOC Content Limits : No person shall apply a coating to any motor vehicle, mobile equipment, or its associated parts and com ponents, with a VOC regulatory content, as calculated pursuant to Section IV.RR.1, in excess of the limits expressed in Table of

Standards

, except as provided in Sections VI.C and VI.J

. Except as provided by Subsection IV.C., effect ive on the dates specified, no person shall refinish, or spot/panel repair a ny Group I vehicle, or wher e color match is required, any Group II vehicle, Mobile Equipment, or parts and components of such vehicles or equipment, using a coating with VOC cont ent in excess of the following limits as applied:

TABLE OF STANDARDS

VOC CONTENT LIMITS FOR MOTOR VEHICLE COATINGS Content expressed in Grams per Liter (Pounds per Gallon) Less Water and Exempt Compounds

Coating Category VOC Limit

Adhesion Promoter 540 (4.5)

Cavity Wax 650 (5.4)

Clear Coating 250 (2.1)

Color Coating 420 (3.5)

Deadener 650 (5.4)

Gasket/Gasket Sealing Material 200 (1.7)410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-10 Draft 3/13/2014 Lubricating Wax/Compound 700 (5.8)

Multi-Color Coating 680 (5.7)

Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Sealer 650 (5.4)

Single-Stage Coating 340 (2.8)

Specialty Coating 540 (4.5)

Temporary Protective Coating 60 (0.5)

Truck Bed Liner Coating 200 (1.7)

Trunk Interior Coating 650 (5.4)

Underbody Coating 650 (5.4)

Uniform Finish Coating 540 (4.5)

Any other coating type 250 (2.1)

VOC Content Limits (Grams of VOC Per Liter of C oating Less Water and Less Exempt Compounds)

Coating Current Effective 1/1/96

Pretreatment 780 g/l 780 g/l

Wash Primer (6.5 lb/gal) (6.5 lb/gal)

Primer/Primer 340 250

Surface Precoat (2.8) (2.1)

Primer Sealer 420 420 (3.5) (3.5)

Multistage Topcoat 600 540 (5.0) (4.5)

Singlestage Topcoat 600 420 (5.0) (3.5)

Metallic/Iridescent 600 540 Topcoat (5.0) (4.5)

B. VOC Content Limits : Except as provided by Subsection IV.C., effective on the dates specified, where color ma tch is not required, no person sh all refinish or spot/panel repair any Group II vehicle, or Mobile Equipment, or parts and components of such vehicle or equipment using a coating with a VOC content in excess of the following limits as applied:

VOC Content Limits410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-11 Draft 3/13/2014 (Grams of VOC Per Liter of Coating Less Water and Less Exempt Compounds)

Coating Current Effective 1/1/96

Pretreatment 780 g/l 780 g/l

Wash Primer (6.5 lb/gal) (6.5 lb/gal)

Primer/Primer Surfaces 340 250

Primer Sealer/Precoat (2.8) ( 2.1)

Topcoat 420 420 (3.5) (3.5)

Metallic/Iridescent 420 420 Topcoat (3.5) (3.5)

Extreme Performance* 750 420 (6.2) (3.5)

Camouflage 420 420 Topcoat (3.5) (3.5) * Any person seeking to use an extreme performance coating in any ap plication subject to this Rule shall comply with requirements of Subsection V.A.

B. Most Restrictive VOC Limit: If anywhere on the container of any automotive coating, or any label or sticker affixed to the container, or in any sales, advertising, or technical literature supplied by a person, any re presentation is made that indicates that the coating meets the definition of or is recommended for use for more than one of the coating categories listed in Table of Standards, then the lowest VOC content limit shall apply.

C. Alternate Emission Control : In lieu of complying with VOC content limits specified

in subsections IV.A. and IV.B. Table of Standards

, air pollution an emission control equipment system with a capture efficiency of at least 90% and a control efficiency of at least 90% may be used if it has been approved in writing by the Air Pollution Control Officer (APCO). Any approved emi ssion control system must be maintained and used in proper working condition at al l times. Use of a VOC emission control system shall not result in emissions in excess of those that would have been emitted had the operator complied with the provisions of Section V.A. with a capture efficiency of at least 85% and a control efficiency of at least 90% may be

used.

D. Spray booth Booth : All surface coatings subject to this Rule shall be applied within a permitted, properly maintained, and operational paint spray booth located at a site with proper city or county zoning.

E. Coating Application Methods Equipment Requirement s : No person shall coat apply

any coating to any Group I or Group II Vehicle, motor vehicle, or Mobile mobile410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-12 Draft 3/13/2014 Equipment equipment , or associated parts and components of such vehicles and equipment, unless one of the following application methods is used:

1. Brush, dip, flow, or roll coating conducted in accordance with manufacturer's recommendations,

2. Electrostatic or electrodeposition ap plication conducted in accordance with manufacturer's recommendations,

3. High Volume Low Pressure ( HVLP ) spray equipment operated in accordance with manufacturer's recommendations, or

4. Spray gun: If a spray gun is used, the end user must demonstrate that the gun

meets the HVLP definition in Section IV .T in design and use. A satisfactory

demonstration must be based on the manuf acturer's published technical material on the design of the gun and by a demonstr ation of the operation of the gun using an air pressure tip gauge from the manufacturer of the gun.

4 5

. Other Any alternative coating application method which has been demonstrated to achieve at least 65% transfer efficiency or the equivalent efficiency of an HVLP and a pproved, in writing, by APCO. , for example, flow or continuous coating

.

Section VI.E does not apply to underbody coat ings, graphic arts operations, truck bed liner coatings, or any coating use of less than one (1) fluid ounce (29.6 milliliters).

F. Surface Preparation and Equipment Cleanup Requirements : No person shall conduct surface preparation or equipment cleanup for act ivities subject to provisions of this Rule unless the following VOC limits are met and methods are used:

1. VOC content of surface preparation solvent shall not ex ceed 25 g/l (0.2 lb/gal), as calculated pursuant to Section IV .RR.3, unless Section V.E applies.

1. Surface C leaning : No material shall be used containing VOC in excess of 200 grams per liter (1.7 lb/gal) of material to remove dirt, oils, or other contaminants prior to application of su rface coatings or adhesives.

2. Stripping : No material shall be used contain ing VOC in excess of 200 grams per liter of material to strip any coating.

3 2 . Cleaning of Coatings Application Equipment : Solvents used for cleaning of coatings application equipment shall comply with both limits specified below:

a. Solvent shall have a VOC content of 950 grams or less per liter (7.9 lb/gal) of material; and

b. Solvent shall have a VOC composite pa rtial pressure of 35 mm Hg or less at 20/C (68/F).410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-13 Draft 3/13/2014 4. Cleaning of Polyester Resi n Application Equipment : Solvents used for cleaning pol yester resin application equipment sh all comply with one of the limits specified below:

a. Solvent shall have a VOC content of 200 grams or less per liter (1.7 lb/gal); or

b. Solvent shall have a VOC content of 1100 grams or less per liter (9.2 lb/gal) and a VOC composite partial pressure of 1.0 mm Hg or less at 20/C (68/F).

5 2 . Cleaning Devices and Methods Requirements : No person shall perform solvent cleaning operations unless one of the following cleaning devices or

methods is used:

a. Wipe cleaning;

b. Spray bottles or containers with a maximum capacity of 16 fluid ounces from which solvents are applied wit hout a propellant-induced force;

c. Cleaning equipment having a clos ed solvent container during cleaning operations, except when depositing and removing objects to be cleaned, and closed during nonoperation except during maintenance and repair of the cleaning equipment itself;

d. Remote reservoir cold cleaner operated in conformance with District Rule

410.3 , Organic Solvent Degreasing Operations ;

e. System totally enclosing spray guns , cups, nozzles, bowls, and other parts during washing, rinsing, a nd draining procedures;

f. Non-atomized solvent flow method co llecting cleaning solvent in a container or a collection system closed except fo r solvent collection openings and, if necessary, openings to avoid excessive pr essure build-up inside the container;

or

g. Solvent flushing method discharging cl eaning solvent into a container closed except for solvent collection openings and, if necessary, openings to avoid excessive pressure build-up inside the container. Discharged solvent from such equipment shall be collected into containers without atomizing into open air. Solvent may be flushed through the sy stem by air or hydraulic pressure, or by pumping.

G. Storage and Disposal : Regardless of VOC content, all automotive coating components, automotive coatings, and solvents VOC

- containing materials used in solvent cleaning operations, su ch as solvents, and cloth and paper moistened with

solv ents , shall be stored in non-absorbent, non

- leaking vapor-tightcontainers kept closed at all times except when filling or emptying.

H. Prohibition of Sale or Manufacture : No person shall manufacture, blend, repackage for sale, supply, sell, offer for sale or sell distribute within the District any coating

with a VOC content in excess of th e limits specified in Section VI.A.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-14 Draft 3/13/2014 Notwithstanding the provisions of this section, a person may manufacture, blend, repackage for sale, supply, sell, offer for sale, or distribute a coating with a VOC content in excess of the limits specifi ed in section VI.A under the following circumstances and provided all of the requi rements of section V II.C.6 are also met:

if such product is prohibite d by any provisions of this Ru le. This prohibition shall apply to sale of any coating to be applied at any physical location within the District. 1. The coating is used exclusively within an emission control system as allowed in Section VI.C, or

2. Coating is exempt under one or more of the provisions of Section V.A.

I. Prohibition of Specification : No person shall solicit or require for the use of, or specify the application of a or use of any coating or solvent on a Group I Vehicle or Group II Vehicle motor vehicle and or Mobile mobile Equipment equipment, or its

associated parts and components, if such use or application results in a violation of provisions of this Rule. This prohibition shall appl y to all written or oral contracts

, including but not limited to, job orders, under the terms of which any coating or solvent subject to provisions of this Rule is to be applied . This prohibition shall not apply to coatings or solven ts that meet the criteria specified in Section VI.H. to any vehicle, mobile equipment or part or component at any physical lo cation within the

District.

J. Sell-Through/Existing Stock of Coati ngs: A coating manufactured prior to amendment date of this rule, that complied with the VOC Content limit(s) in effect at that time, may be sold, supplied, or offered for sale for 12 months after rule adoption date. Such a coating may be applied at a ny time, both before and after adoption date, provided manufacture Date-Code and VOC C ontent is clearly printed on coating

container.

J. Specialty Coatings : No person shal l u se any specialty coating with a VOC content in excess of 840 g/l (7.0 lbs/gal), excluding water and exempt compounds. Where use of specialty coatings, except antiglare/safety coatings, exceeds one gallon per day, use of such coatings shall not exceed 5. 0 percent of all coatings applied on a daily basis.

V II . Administrative Requirements

A. Compliance Statement Requirement

1. For each individual automotive coating or automotive coating component, the manufacturer and repackag er shall include the following information on product data sheets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in grams per liter;

b. The weight percentage of vola tiles, water, and exempt compounds;

c. The volume percentage of water and exempt compounds; and,410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-15 Draft 3/13/2014 d. The density of the material (in grams per liter).

2. For each individual ready to spray mi xture (based on the manufacturer’s and repackager’s stated mix ratio), the manuf acturer and repackager shall include the following information on product data sh eets, or an equivalent medium:

a. The VOC actual for coatings and VOC regulatory for coatings, expressed in grams per liter;

b. The weight percentage of vola tiles, water, and exempt compounds;

c. The volume percentage of water and exempt compounds; and,

d. The density of the material (in grams per liter).

3. The manufacturer and repackager of solven ts subject to this rule shall include the VOC content as supplied, calculated pursu ant to section IV.RR.3, expressed in grams per liter, on product data sheets, or an equivalent medium.

A B . Labeling Requirements

1. VOC Content : The manufacturer and repackager of automotive coatings or automotive coating components shall include on all containers the applicable use category(ies), and the VOC actual for coat ings and VOC regulatory for coatings, as supplied, expressed in grams per liter. Each container (or accompanying data sheet) of any coating subj ect to this Rule and ma nufactured after May 6, 1992 shall display maximum VOC content of the coati ng as applied, including coating components and after any thinning as recommended by the manufacturer. VOC content shall be displayed as grams of VOC per liter less water and exempt compounds. VOC content displayed shall be determined using Subsection VI.A.

test methods or calculated using product formulation data if U.S. EPA approves this as equivalent to Subsection VI.A.

2. Thinning Recommendations : The manufacturer and repackager of solvents subject to this rule shall include on all co ntainers the VOC content for solvents, as supplied, expressed in grams per liter. Each container (or accompanying data sheet) of any coating subj ect to this Rule and ma nufactured after May 6, 1992 shall display a statement of manufacturer's recommendation regarding thinning of the coating. This requirement shall not a pply to thinning of coatings with water.

B C . Record Keeping Requirements

Any person who uses coatings or solvents, subject to this rule, shall maintain and have the following available on site at all times: subject to Section IV. or Subsection

V.B. shall maintain and have available during an inspection:

1. A current list of all VOC containing products in use that includes containing all

any data necessary to evaluate compliance, including but not limited to, the following information

, as applicable:410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-16 Draft 3/13/2014 a. Material name and manu facturer's identification,

b. Application method,

c. Material type (coating as listed in Table of Standards) and specific use instructions, for examp le, "Group I single stage topcoat or precoat shall be applied to bare metal and followed with compliant primer"

,

d. Specific mixing instructions,

e. Maximum VOC actual and VOC regulatory for content of coating s, as applied, or VOC content for solvent in cluding thinning solvents, hardeners, etc., excluding water and exempt compounds , and

f. Coating composition and density

.

2. Daily coating and solvent use records, including the following information for

each:

a. Volume of each coating/solvent mix ratio,

b. VOC content in grams/liter (or pounds/gallon) as applied/used,

c. Volume of each coating/solvent in liters (or gallons) applied/used.

d. Type and amount of solvent used for cleanup and surface preparation.

If purchase records are used to determ ine the amount of solvents used, then

records and manifests of the amounts of solven ts disposed of or sent to a recycler

must also be maintained and made available to the APCO upon request.

3. Current manufacturer specification sheets, material safety data sheets, technical data sheets, or air quality data sheets, which list the VOC actual for coatings and VOC regulatory for coatings of each r eady-to-spray coating (based on the manufacturer’s stated mix ratio) , and VOC content of each solvent.

4. Purchase records identifying the coating t ype (as listed in Table of Standards), name, and volume of coatings and solvents.

5. Alternate Emissions Control Records: Any person using an emission control system shall maintain daily records of key system operating parameters which will demonstrate continuous operation and compliance of the emission control system during periods of VOC emissi on producing activitie s. “Key system operating parameters” are those paramete rs necessary to ensure or document compliance with Section VI.C., including, but not limited to, temperatures, pressure drops, and air flow rates.

6. Record Keeping Requirements for Prohibi tion of Sale: Any person claiming an exception specified in Section VI.H shall keep a detailed log of each automotive410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-17 Draft 3/13/2014 coating component and automotive coa ting manufactured, blended, repackaged for sale, supplied, sold, offered fo r sale, or distributed showing:

a. The quantity manufactured, blended, repackaged for sale, supplied, sold, offered for sale, or distributed, includ ing size and number of containers;

b. The VOC regulatory for coatings;

c. The VOC actual for coatings;

d. To whom they were supplied, sold, o ffered for sale, or distributed, or for whom they were manufactured, blended, or repackaged for sale including the name, address, phone number; and,

e. The specific exception being utilized under Section VI.C.

7. Record Retention: Record s required by this Rule shall be retained for a minimum of three years and made availa ble to the APCO upon request.

2. Daily job and coating and solvent us e records, including the following

information:

a. Each type of vehicle, equipment, part or component coated. Vehicle types are the following:

1) Group I Vehicle, 2) Group I Vehicle with lacquer, 3) Group II Vehic le and Mobile Equipment with color match, or 4) Group II Vehicle and Mobile Eq uipment with no color match;

b. Specific coatings used on each job, e.g. pretreatment wash primer, precoat,

topcoat;

c. Volume in liters (or gallons) of each component and m ix ratio;

d. VOC content in grams/liter (or pounds/gallon) as applied/used;

e. Specific solvents used;

f. Volume of each solvent used in liters (or gallons); and

g. Primers and primer surfacers mixed for use on multiple vehicles may be

recorded as s ingle line item including all info rmation required in Subsections V.2.c. through V.2.f., above.

3. Capture and control equipment operating records, if applicable, including:

a. Periods of operation corresponding to us e records kept for Subsection V.B.2

. showing control equipment was used as necessary,410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-18 Draft 3/13/2014 b. Key system operating parameters showing operation as required to comply with this Rule and as intended by manufacturer,

c. Date performed, and description of all control system maintenance.

4. Pur chase records showing date, type, and amount of VOC containing material. All records shall be maintained for three y ears and made available for inspection by the Control Officer upon request.

VI II . Test Methods

The following test methods are incorporated by re ference herein, and sha ll be used to test emission sources subject to the pr ovisions of this rule. A source is in violation of this rule if any measurement by any of the listed appli cable test methods exceeds any standard of

this rule.

E A

. Measurem ent of Acid Content :

- Measure of Acid acid content of Pre

- Treatment

Wash Primers shall be conducted and reported in accordance with determined by using ASTM D1613- 85 03 “ Standard Test Method for Acidity in Volatile Solvents

and Chemical Intermediates use d Used in Paint, Varnish, Lacquer, and Related

Products ” (October 2003)

.

A B . Analysis of Samples :

- Samples of VOC as specified in this Rule shall be analyzed by U.S. EPA Method 24 as set forth in Appendix A of Title 40 of the Code of Federal Regulations (40 CFR) Part 60, “D etermination of Volati le Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings”. and analysis Analysis of halogenated exempt compo unds shall be conducted using

CARB Method 432 422, “Determination of Volatile Organic Compounds in Emissions from Stationary Sources” (September 12, 1990). or ASTM D4457

- 85 and be consistent with provisions set forth in the Federal Register (FR. Vol. 56, No. 52, March 18, 1991).

C. Alternative Test Methods: The use of other test methods which are determined to be equivalent or better and approved, in writing, by the AP CO, ARB, and EPA may be used in place of the test me thods specified in this rule.

D. Control and Capture Efficiency: Capture and control efficiency of emission control systems shall be determined as specifie d in EPA’s “Guidelines for Determining Capture Efficiency,” (January 9, 1995) and 40 CFR 51, Appendix M, Methods 204- 204f as applicable. Total organic emissions of emission control systems shall be determined using EPA Method 25, 25A or 25B.

B E . Determination of Emissions : - Emissions of VOC shall be measured by U.S. EPA Method 25, 25A, or 25B, as applicable

. and analysis of halogenated exempt compounds shall be conducted using CARB Method 432, “Determination of Dichloromethane and 1,1,1- Trichloroethane in Paints and Coatings” (September 12, 1998).

C

. Determination of Capture Efficiency

- Where add

- on control equipment is utilized, capture efficiency shall be dete rmined in accordance with 40 CFR 52.741.410.4A Final Staff Report – St rikeout and Underline Amended Rule

Appendix B B-19 Draft 3/13/2014 F. Exempt Organic Compound Content of Coatings: The exempt organic compound content of coatings or solvents shall be determined using ASTM Method D 6133- 02, Standard Test Method for Acetone, p-Chlor obenzotrifluoride, Met hyl Acetate, or tButyl Acetate Content of Solventborne and Waterborne Paints, Coatings, Resins, and Raw Materials by Direct Injection into a Chromatograph. Exempt organic compound content, other than as determined above , shall be determined by using CARB Method 422, CARB Method 432, or South Coast AQMD Method 303-91, “Determination of Exempt Compounds” (February 1993).

G. HVLP Equivalency: Spray Equipment HVLP equivalency shall be determined by using South Coast Air Quality Management District’s “Guidelines for Demonstrating Equivalency with District Approved Transfer Efficient Spray Guns” (September 26, 2002).

D H

. Quantification of Metallic Content /Iridescent Topcoat :

- Quantification of coating as The a metallic /iridescent topcoat content of a coating shall be determined by South Coast Air Quality Management District " Test Method 311 318

- 91 95 " , " Determination of Weight Percent Elemen tal Metal in Coatings by X-ray” (July 1996). Analysis of percent Metals in Meta llic Coatings by Spectrographic Method"

.

F I

. Demonstration of Transfer Efficiency :

- Spray equipment transfer Transfer efficiency

shall be demonstrated determined by using South Coast Air Quality Management District Method "Spray Equipment Transfer Efficiency Test Procedure for Equipment

User" , (May 24, 1989)

.

G J

. Determination of VOC Composite Partial Pressures :

- VOC composite partial pressures shall be determined using eith er manufacturer's information regarding formulation or using ASTM Methods E168

- 92, E169- 93 04

, Standard Practices for General Techniques of Ultraviolet-Visible Quantitative Analysis or E260- 91 96, Standard Practice for Packed Column Gas Chromatography for determination of mole fractions and then summing products of each VOC component's vapor pressure and

its mole fraction. For materials containing no non-VOC components, VOC composite partial pressure can be m easured directly by ASTM Method D2879- 86 10 Standard Test Method for Vapor Pressure -Temperature Relationship and Initial Decomposition Temperature of Liquids by Isoteniscope.

H K

. Deter mination of VOC Emissions From from Spray Gun Cleaning Systems :

- VOC emissions shall be determined using South coast Coast Air Quality Management district AQMD "General Test Method for Determining Solvent Losses from Spray Gun Cleaning Systems" (October 3, 1989)

.

Remainder of Page Intentionally Left Blank

## APPENDIX C

AMENDED RULE 410.4A

MOTOR VEHICLE AND MO BILE EQUIPMENT

REFINISHING OPERATIONS

RESPONSE TO COMMENTS410.4A Final Staff Report - Response to Comments

Appendix C C-1 Draft 3/13/2014 On November 6, 2013 the District held a public rule development workshop at the Mojave Veteran's Building in Mojave, CA to present proposed revisions of Rule 410.4A, Motor Vehicle and Mobile Equipment Re finishing Operations. The District submitted copies of the proposed revision to the Air Resources Board (ARB) and the Region IX office of the U. S. Environmental Protection Agency (EPA) in October, 2013 for an initial 30-day review.

Upon completion of review EPA offe red comments and suggested changes to District staff regarding the proposed revision of Rule 410.4A. ARB did not provide comments or suggested changes but responded to the District that they would wait to review the rule upon subm ission of the final draft.

Industry representatives pr esent at the 11/6/2013 works hop asked various questions regarding the proposed amendments and s ubmitted written comments within 30- days following the workshop. Appendix C addresses comments, questions, and suggested changes regarding the proposed revision of Rule 410.4A.

Appendix C is separated into two sections based on EPA comments and suggested changes and industry/public comments and questions.



### I. EPA COMMENTS

The following changes were made to the 8/1/2013 proposed revision of Rule 410.4A in response to EPA comments.

Section III, Definitions

1. EPA commented: P,Q,R,S, should be reorganiz ed in alphabetical order

District corrected this issue.

2. EPA commented: OO: The limit of nine square feet is an addition to the
SJVAPCD's definition. This se ems excessive for touch-up.

District revised to match Rules 410.4 and 410.8

Section V, Requirements

1. EPA commented: C. Consider raising the capture efficiency requirement to 90%.
SJVAPCD Rule 4602 has an overall c apture and control efficiency of 90%.

District revised per suggestion.410.4A Final Staff Report - Response to Comments

Appendix C C-2 Draft 3/13/2014 2. EPA commented: J. How will this prohibition of possession be enforced?

District: This provision has been remov ed and sell through provision added (see Section VI.J of Appendix A)

Section VII, Admini strative Requirements

1. EPA commented: C-4: Although this rule requires the use of compliant coatings and solvents only, consider requiring daily records similar to that in SJVAPCD's

Rule 4602.

District revised this subsection to match Rule 410.4 recordkeeping requirements in order to maintain rule consistency.

Section VIII, Test Methods

In order to maintain District Rule cons istency, Section VIII, Test Methods has been revised to closely match Section V II, Test Methods of Rule 410.4.

1. EPA commented: B. Include the title and date (September 12, 1989) for CARB's

Method 432 in this first instance. The ti tle in subsection H may be eliminated.
Include the title for ASTM D4457-85.

District revised this section to match Rule 410.4 Analysis of Samples, Section

VII.B.

2. EPA commented: F. Add the SCAQMD test me thod date: October 3, 1989.

District revised this section to match Rule 410.4.

3. EPA commented: G. Later versions of ASTM D2879 have been approved by EPA. If appropriate, use -96, -97 or -10.

District revised per suggestion.

4. EPA commented: H. See comment in subsection B. Also the EPA-approved CARB Method 422 is dated Sept. 12, 1990 and the EPA-approved SCAQMD Method 303-91 is dated August 1996.

District revised per suggestion.410.4A Final Staff Report - Response to Comments

Appendix C C-3 Draft 3/13/2014 

### II. INDUSTRY/PUBLIC COMMENTS

The following comments were made by indust ry representatives at, and following the 11/6/2013 workshop in Mojave, CA.

American Coatings Association American Coatings Association (ACA) submitted the following written comments regarding Rule 41 0.4A on 12/6/2013.

Section II, Applicability

1. ACA commented: Effective dates: ACA suggests that a cl early defined regulatory

effective date be added to the rule. As draf ted, the proposed regulations do not
have an effective date. Other California Air Districts have listed an effective date per Coating Category in t he VOC Content Limits For Motor Vehicle Coatings table. Additionally, an effective date c an be listed by a separate statement. ACA suggest a one-year transition period, prior to the new VOC limits taking effect.

District added the following language to Section II, Applicability “provisions of this Rule are enforceable upon amendment date” and a 12-month sell-through provision (see Section VI.J).

Section IV, Definitions

1. ACA commented: The following definitions are not mentioned in the proposed regulations and should be removed fr om the definition section: i. Catalyst
ii. Color Match iii. Stationary Coat ing Operation.

District revised per suggestion.

2. ACA commented: The definition of specialty coati ng should specifically include “cut in” or “jambing clear” coatings.

District revised per suggestion.

3. ACA commented: The definition of Spot/Panel is redundant. To clarify this definition, the language “to a predamanged condition” should be removed.

District revised per suggestion.410.4A Final Staff Report - Response to Comments

Appendix C C-4 Draft 3/13/2014 4. ACA commented: The definition of Reducer/Thi nner should be removed. The
definition of Solvent should be revised to read as follows: “A VOC-containing fluid used to perform cleaning operations or to reduce the viscosity of a coating.”

District removed Reducer/Thinner and revi sed Solvent definition to match rules

410.4 and 410.8.

5. ACA commented: The following language should be re moved from the definition of Precoat: “For compliance with this ru le, any precoat shall be followed by a water-based primer coat.” Compliance with this proposed rule should be based solely on VOC content stated in the Vo latile Organic Compound (VOC) Content

Limits for Motor Vehi cle Coating Table.

District revised per suggestion.

Section V, Exemptions

1. ACA commented: Consistent with the CARB SCM, ACA suggests including an exemption for “assembly lines, as follows: “Any coating applied to motor vehicles or mobile equipment, or their as sociated parts and components, during manufacture on an assembly line.”

District added exemption (see Se ction V.A.5. of Appendix A).

Section VI, Requirements

1. ACA commented: Sell Through Provision: ACA re spectfully requests that a clearly expressed sell through provision be added to the rule. The addition of a sell through would allow businesses to sell or use products manufactured before the effective date for a specified period of time. ACA suggests a sell through period of one year after the effective date.

District revised per suggestion (see Section VI.J).

2. ACA commented: VOC Limit for Specialty Coatings: The proposed regulations contain VOC limits of 540 g/ l for two types of specialty coatings: 1) Adhesion Promoters, and 2) Uniform Finish Coat ings. ACA urges the Eastern Kern APCD to extend this VOC limit of 540 g/l to all specialty coatings, and to remove the specific specialty coatings categories for Adhesion Promoters and Uniform Finish Coatings.

District revised per suggestion.410.4A Final Staff Report - Response to Comments

Appendix C C-5 Draft 3/13/2014 3. ACA commented: Section VI: Requirements E(5) reads as follows: “Any alternative coating applic ation method which has been demonstrated to achieve
at least 65% transfer effi ciency or the equivalent efficiency of an HVLP and approved, in writing, by the EPA and APCO.” Under the National Auto Refinish Rules, there is no requirement for approv al by EPA, and multiple agency reviews will put an unnecessary burden on manufac turers. ACA urges Eastern Kern revise Section IV: Requirements E(5) by replacing “EPA” with “the California Air Resources Board (CARB)” or another lo cal or state Air Q uality Authority.

District removed “EPA”. APCO written approval remains, APCO will make determination based on information provided by ARB, EPA, or other air districts testing data and approvals.

Section VII, Admini strative Requirements

1. ACA commented: Administrative Requirements B( 1) reads as follows: “Coatings: The manufacturer and repackager of automot ive coatings or automotive coating components shall include on all containers the applicable use category(ies), and the VOC actual for coatings and VOC r egulatory for coatings, as supplied, expressed in grams per liter.” Automoti ve coatings components do not fit into categories and VOC content is not relevant for compliance. The VOC content of the ready to spray coating is relevant for compliance. Therefore, ACA suggests that section VII(B)(1) be revised to r ead as follows: “Coatings: The manufacturer and repackager of automotive coatings shall include on all containers the applicable use category(ies), and the VOC actual as supplied and VOC regulatory as supplied, expressed in grams per liter.”

District removed “Coatings” and “Solvents” were removed from Subsections VII.B.1. and VII.B.2. Language from both S ubsections are word for word from
ARB’s SCM.

2. ACA commented: Section VII: Administrative Requirements C(6) reads as follows: “Record Keeping Requirements fo r Prohibition of Sale: Any person claiming an exception specified in Secti on VI.H shall keep a detailed log of each automotive coating component and automot ive coating manufactured, blended, repackaged for sale, supplied, sold, offer ed for sale, or distributed showing:

a. The quantity manufactured, blended, r epackaged for sale, supplied, sold, offered for sale, or distributed, incl uding size and number of containers; b. The VOC regulatory for coatings; c. The VOC actual for coatings; d. To whom they were supplied, sold, offe red for sale, or distri buted, or for whom they were manufactured, blended, or repackaged for sale including the name, address, phone number, retail tax license number, and valid district permit number; and, e. The specific exception being utilized under Section VI.C.410.4A Final Staff Report - Response to Comments

Appendix C C-6 Draft 3/13/2014 Requiring the manufacturer to keep reco rds maintaining the retail tax license number and valid district permit number is an unnecessary burden for both
manufacturers and distributors. ACA reco mmends the removal of the retail tax license number and valid district permit nu mber from section C(6)(d) and section (e) in its entirety – “the specific exception being ut ilized under Section VI.C.”

District removed “Coatings” and “Solvents” were removed from Subsections VII.B.1. and VII.B.2. Language from both S ubsections are word for word from
ARB’s SCM.

District: Requested change sounds reas onable, revised per suggestion.

3. ACA commented: To give facilities adequate time to gather requested information, ACA recommends the follo wing change to the rule language: “Records required by this Rule shall be retained for a minimum of three years
and made available to the APC O within 90 days after request.”

District did not make change; Facility permi t conditions usually require records to be held on premises and made available to the District upon Inspector/APCO request.

PPG
PPG submitted the follo wing written comments r egarding Rule 410.4A on
11/19/2013.

Section II, Applicability

1. PPG commented: am concerned that I did not s ee a date of implementation for this revision. While products are availabl e & accepted in the 13 air districts that have already implemented a CARB SCM type rule, the technology required will take time for painters in Eastern Kern APCD to learn how to correctly apply. Hands-on training is strongly reco mmended for the waterborne basecoats considered critical to compliant technol ogies as these products handle differently

than solvent borne. Also there will be ti me needed to flush the old technology higher VOC products out of the system. Coatings are expensive; shops will not want to waste even partial containers. Disposal of serviceable products would only place an extra unneeded burden on waste facilit ies. In the other districts that have updated their regulations, typically up to 12 months have been allowed to

transition.

District added the following language to Section II, Applicability “provisions of this Rule are enforceable upon amendment date” and a 12-month sell-through provision (see Section VI.J).410.4A Final Staff Report - Response to Comments

Appendix C C-7 Draft 3/13/2014 Section VI, Requirements

1. PPG commented: Solvents used for spray gun cleaners set at 25 g/L maximum

will force formulators to use a limited number of exempt compounds which may not offer the best qualities desired in a gun cleaner. Obviously there are high exempt content products available, but there could be better options. I would suggest the approach used by Bay Area AQMD which does not set a limit for this category. As these products are requir ed to be used in an enclosed device, they will be contained for eventual recycling. Us e of exempt formulations will almost certainly require costlier formulations that will not deliver the efficient cleaning properties offered by the full selection of VOC containing solvents. Used in a proper device there will be limited releases to the environment and with recycling
& reuse of solvents deriv ed no need to set a VOC limit for this category.

District: limit for surface preparation will remain at 25 g/l and limits for Application Equipment Cleaning will remain at 950 gram s or less per liter (7.9 lb/gal) of material with a VOC composite partial pre ssure of 35 mm Hg or less at 20/C (68/F). (See Section VI.F. of Appendix A)

Edwards Air Force Base Edwards Air force Base (Edwards) s ubmitted the following written comments regarding Rule 41 0.4A on 12/6/2013.

We request EKAPCD revise the sell-through dat e to 12 months after effective date
of the rule.

District: Sell-through provisio n was added (Section VI.J.).

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