Antelope Valley 

Air Quality Management District 

Final 

Staff Report 

Amendment of 

Rule 1124 – Aerospace Assembly and Component 

Manufacturing Operations

Adopted on 

August 20, 2013 

43301 DIVISION ST., SUITE 206,

LANCASTER, CALIFORNIA 93535-4649 

PHONE (661) 723-8070 

FAX (661) 723-3450 
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AVAQMD Rule 1124 TC-1

Final Staff Report, 09/20/13 

STAFF REPORT 

TABLE OF CONTENTS 

Rule 1124 – Aerospace Assembly and Component Manufacturing Operations 

I. PURPOSE OF STAFF REPORT ........................................................................................... 1

II. EXECUTIVE SUMMARY .................................................................................................... 1

III. STAFF RECOMMENDATION ............................................................................................ 2

IV. LEGAL REQUIREMENTS CHECKLIST .......................................................................... 3

V. DISCUSSION OF LEGAL REQUIREMENTS ................................................................... 4

A. REQUIRED ELEMENTS/FINDINGS .......................................................................... 4

1. State Findings Required for Adoption of Rules & Regulations ...................... 4

a. Necessity .............................................................................................. 4

b. Authority .............................................................................................. 4

c. Clarity .................................................................................................. 4

d. Consistency .......................................................................................... 4

e. Non-duplication ................................................................................... 4

f. Reference .............................................................................................. 4

g. Public Notice & Comment, Public Hearing ........................................ 5

2. Federal Elements (SIP Submittals, Other Federal Submittals) ........................ 5

a. Satisfaction of Underlying Federal Requirements ............................... 5

b. Public Notice and Comment ................................................................ 5

c. Availability of Document .................................................................... 5

d. Notice to Specified Entities ................................................................. 6

e. Public Hearing ...................................................................................... 6

f. Legal Authority to Adopt and Implement ............................................ 6

g. Applicable State Laws and Regulations Were Followed .................... 6

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ........................................ 6

C. ECONOMIC ANALYSIS .............................................................................................. 7

1. General ............................................................................................................. 7

2. Incremental Cost Effectiveness ...................................................................... 7

D. ENVIRONMENTAL ANALYSIS (CEQA) .................................................................. 7

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ................................................. 8

1. Potential Environmental Impacts ..................................................................... 8

2. Mitigation of Impacts ...................................................................................... 8

3. Alternative Methods of Compliance ................................................................ 8
TC-2 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

F. PUBLIC REVIEW .......................................................................................................... 8

VI. TECHNICAL DISCUSSION ............................................................................................... 8

A. SOURCE DESCRIPTION ............................................................................................. 8

1. Rule Applicability ........................................................................................ 8

2. Rule History ................................................................................................. 9

C. EMISSIONS ................................................................................................................... 9

D. CONTROL REQUIREMENTS ..................................................................................... 9

1. VOC Limitations ......................................................................................... 9

2. Control Equipment ..................................................................................... 10

E. PROPOSED RULE SUMMARY ................................................................................. 10

1. Section (A) – General ................................................................................ 10

2. Section (B) – Definitions ........................................................................... 10

3. Section (C) – Requirements ....................................................................... 14

4. Section (D) – Recordkeeping and Reporting Requirements ...................... 18

5. Section (E) – Compliance Procedures and Test Methods ......................... 18

6. Section (F) – Administrative Requirements .............................................. 18

E. 110(l) ANALYSIS ........................................................................................................ 19

F. SIP HISTORY ............................................................................................................... 20

1. SIP History..................................................................................................... 20

2. SIP Analysis................................................................................................... 20

Appendix A – Rule 1124 Iterated Version ................................................................................. A-1

Appendix B - Public Notice Documents ..................................................................................... B-1

Appendix C - Public Comments and Responses ......................................................................... C-1

Appendix D - California Environmental Quality Act Documentation ....................................... D-1

Appendix E - Bibliography .......................................................................................................... E-1
AVAQMD Rule 1124 1

Final Staff Report, 09/20/13

STAFF REPORT 

Rule 1124 – Aerospace Assembly and Component Manufacturing Operations

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Governing Board. This allows the members of the 

Governing Board to be fully informed before making any required decision. It also provides the 

documentation necessary for the Governing Board to make any findings, which are required by law to 

be made prior to the approval or adoption of a document. In addition, a staff report ensures that the

correct procedures and proper documentation for approval or adoption of a document have been 

performed. Finally, the staff report provides evidence for defense against legal challenges regarding

the propriety of the approval or adoption of the document. 

II. EXECUTIVE SUMMARY 

On July 1, 1997 the Antelope Valley Air Pollution Control District (AVAPCD) was created pursuant 

to statute (former H&S Code §40106, A.B. 266-Knight Ch. 542, statutes of 1996) and assumed all air 

pollution control responsibilities from the South Coast Air Quality Management District (SCAQMD) 

for the area of Los Angeles County outside the South Coast Air Basin (SCAB). The SCAQMD rules 

in effect within the jurisdiction of the AVAPCD remained in effect until the AVAPCD Governing 

Board superseded, amended, or rescinded them. On January 1, 2002 the Antelope Valley Air Quality 

Management District (AVAQMD) was created pursuant to statute (H&S Code §41300 et seq.) to 

replace the AVAPCD. Once again the rules in effect at the time of the change remained in effect until 

the AVAQMD Governing Board superseded, amended or rescinded them. Rule 1124 was last 

amended by the SCAQMD on December 13, 1996, and subsequently amended by the AVAQMD on 

March 20, 2007. 

The Federal Clean Air Act (FCAA) requires areas designated nonattainment for ozone and classified 

moderate and above to adopt and maintain Reasonably Available Control Technology (RACT) rules 

for source categories emitting Volatile Organic Compounds (VOC) and oxides of nitrogen (NOX) for 

which U.S. Environmental Protection Agency (USEPA) has issued a Control Techniques Guideline 

(CTG) document. In addition, such areas are required to adopt and maintain RACT rules for all other 

major stationary sources of VOCs and NOX (42 U.S.C. §7511a(b)(2); FCAA §182(b)(2)). The 

Antelope Valley area has been designated non-attainment for the eight hour ozone standard and 

classified as Severe-17. 

On March 10, 1998 USEPA adopted a CTG entitled Control of Volatile Organic Compound Emissions 

from Coating Operations at Aerospace Manufacturing and Rework Operations. In addition, USEPA 

also has promulgated and amended Maximum Achievable Control Technology (MACT) Standard for 

Aerospace Manufacturing and Rework Facilities (40 CFR 63 Subpart GG, commencing with §63.741). 

The AVAQMD most recently amended Rule 1124 on March 20, 2007 given the issuance of the CTG 

and amendments to the MACT Standard as well as technological advances in coatings use and 

technology. USEPA indicated that there were several specialty coatings from the CTG that were not 
2 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

included in the 2007 rule amendment. The proposed amendments are primarily designed to update the 

specialty coating categories and definitions to harmonize with the CTG as requested by USEPA. 

Definitions have been added for following the specialty coating categories: Ablative Coating; Bearing 

Coating; Bonding Maskant; Caulking and Smoothing Compound; Chemical Agent-Resistant Coating 

(CARC); Chemical Milling Maskant; Chemical Processing Maskant; Coating; Commercial Exterior 

Aerodynamic Structure Primer; Commercial Interior Adhesive; Compatible Substrate Primer; 

Corrosion Prevention System Compound; Critical Use and Line Sealer Maskant; Cryogenic Flexible 

Primer; Cryoprotective Coating; Cyanoacrylate Adhesive; Electrostatic Discharge and Electromagnetic 

Interference (EMI) Coating (Includes Space Vehicles); Elevated-Temperature Skydrol-Resistant 

Commercial Primer; Epoxy Polyamide Topcoat; Fastener; Fire-Resistant (Interior) Coating (Space); 

Flexible Primer; Insulation Covering; Intermediate Release Coating; Lacquer Coating; Part Marking 

Coating; Rocket Motor Bonding Adhesive; Rocket Motor Nozzle Coating; Rubber-based Adhesive; 

Screen Print Ink; Seal Coat Maskant; Silicone Insulation Material; Specialized Function Coating; 

Specialty Coating; Thermal Control Coating; and, Wet Fastener Installation Coating. VOC limits for 

specialty coatings have been updated to include categories in the CTG that were not covered by the 

previous rule amendment. The proposed amendment also conforms the formatting to the standard 

AVAQMD rule format, removes several unused definitions, updates several definitions for consistency 

with the CTG, removes an exemption for Temporary Marking Coatings and Materials Marking 

Coating for consistency with Part Marking Coating category, and cross references have been updated. 

This item was noticed on June 14, 2013 for the July 16, 2013 Governing Board meeting. Continuation 

of the proposed action was necessary to research and address received from the United States 

Environmental Protection Agency (USEPA). 

III. STAFF RECOMMENDATION 

Staff recommends that the Governing Board of the AVAQMD adopt the proposed amendments to Rule 

1124 – Aerospace Assembly and Component Manufacturing Operations and approve the appropriate 

California Environmental Quality Act Documentation. This action is necessary to update the rule and 

align specialty coating categories with the CTG dated December 1997 entitled Control of Volatile 

Organic Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework 

Operations. 

The Governing Board of the Antelope Valley Air Quality Management District amended Rule 1124 – 

Aerospace Assembly and Component Manufacturing Operations on August 20, 2013. 
AVAQMD Rule 1124 3

Final Staff Report, 09/20/13

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct amendment of 

Rule 1124 - Aerospace Assembly and Component Manufacturing Operations. Each item is discussed, 

if applicable, in Section V below. Copies of documents are included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS 

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Non-duplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

X Notice to Specified Entities (State, 

Air Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and 

implement the document. 

 X Applicable State laws and 

regulations were followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION 

X Elements as set forth in applicable 

Federal law or regulations. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT REQUIREMENTS 

(CEQA): 

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

 X Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS 

ONLY): 

X Environmental impacts of 

compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

X Written analysis of existing air 

pollution control requirements 

 X Economic Analysis 

 X Public Review 
4 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the proposed 

amendment of Rule 1124. These are actions, that need to be performed, and/or information, 

that must be provided in order to amend the Rule in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the AVAQMD Governing 

Board is required to make findings of necessity, authority, clarity, consistency, nonduplication, and reference based upon relevant information presented at the hearing. 

The information below is provided to assist the Board in making these findings. 

a. Necessity: 

The proposed amendment of Rule 1124 is necessary to update the rule and align 

specialty coating categories with the CTG.

b. Authority: 

AVAQMD has the authority pursuant to California Health and Safety Code 

(H&S Code) §40702 to adopt, amend or repeal rules and regulations. 

c. Clarity: 

The proposed amendments are clear in that they are written so that the persons 

subject to the rule can easily understand the meaning. 

d. Consistency: 

The proposed amendment of Rule 1124 is in harmony with, and not in conflict 

with or contradictory to, any state law or regulation, federal law or regulation, or 

court decisions because the amendment aligns specialty coating categories with 

the CTG. 

e. Non-duplication: 

The proposed amendment of Rule 1124 does not impose the same requirements 

as an existing state or federal law or regulation because the CTG is primarily a 

guidance document and requires rule action to implement its provisions. 

f. Reference: 

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or 

repeal rules and regulations. 
AVAQMD Rule 1124 5

Final Staff Report, 09/20/13

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the proposed amendment of Rule 1124 was 

published June 14, 2013 for the July 16, 2013 Governing Board meeting. This 

hearing was continued to August 20, 2013 to allow for time to research and address 

USEPA comments. See Appendix “B” for a copy of the public notice. See 

Appendix C for copies of comments, if any, and AVAQMD responses. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon the type 

of document submitted and the underlying federal law which requires the submittal. 

The information below indicates which elements are required for the proposed 

amendment of Rule 1124 and how they were satisfied.

a. Satisfaction of Underlying Federal Requirements: 

The FCAA requires areas designated nonattainment for ozone and classified 

moderate and above to adopt and maintain RACT rules for source categories 

emitting VOCs and NOX for which USEPA has issued a CTG document. In 

addition, such areas are required to adopt and maintain RACT rules for all other 

major stationary sources of VOCs and NOX (42 U.S.C. §7511a(b)(2); FCAA 

§182(b)(2)). Such RACT rules are required to be submitted into the State 

Implementation Plan (SIP) for the affected area. 

AVAQMD Rule 1124 was most recently amended on March 20, 2007 and was 

submitted for inclusion into the SIP1. USEPA indicated that there were several 

specialty coatings from the CTG that were not included in the 2007 rule 

amendment. This amendment will address these specialty coating categories, 

and it is expected that this amendment will replace the previous SIP submission. 

The criteria for determining completeness of SIP submissions are set forth in 40 

CFR Part 51 Appendix V, 2.0. This staff report and supporting adoption 

documentation will satisfy the completeness requirements. 

b. Public Notice and Comment: 

Notice for the public hearing for the proposed amendment of Rule 1124 was 

published June 14, 2013 for the July 16, 2013 Governing Board meeting. This 

hearing was continued to August 20, 2013 to allow for time to research and address 

USEPA comments. See Appendix “B” for a copy of the public notice. 

c. Availability of Document: 

Copies of proposed amended Rule 1124 and the accompanying draft staff report 

were made available to the public on May 22, 2013. 

 

1

 See section VI. F. for SIP history and analysis of Rule 1124. 
6 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

d. Notice to Specified Entities 

Copies of proposed amended Rule 1124 and the accompanying draft staff report 

were mailed to all affected agencies, including but not limited to CARB and 

USEPA on May 22, 2013. 

e. Public Hearing: 

A public hearing to consider the proposed amendment of Rule 1124 was set for 

July 16, 2013. This hearing was continued to August 20, 2013 to allow for time to 

research and address USEPA comments. 

f. Legal Authority to Adopt and Implement: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend, or repeal rules and regulations and to do such acts as may be necessary 

or proper to execute the duties imposed upon the AVAQMD. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 

have been followed. See Section (V)(A)(1) above for compliance with state 

findings required pursuant to H&S Code §40727. See Section (V)(B) below for 

compliance with the required analysis of existing requirements pursuant to H&S 

Code §40727.2. See Section (V)(C) for compliance with economic analysis 

requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for 

compliance with provisions of the California Environmental Quality Act 

(CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H&S Code §40727.2 requires air districts to prepare a written analysis of all existing federal air 

pollution control requirements that apply to the same equipment or source type as the rule 

proposed for modification by the district. 

The FCAA requires areas designated non-attainment for ozone and classified moderate and 

above to adopt and maintain RACT rules to control the emissions of VOCs and NOX for 

categories which the USEPA has adopted a CTG or ACT and for all categories where there are 

major stationary sources of air pollution (42 U.S.C. §7511a(b)(2), FCAA 182(b)(2)). For 

purposes of the FCAA, the District has been designated non-attainment for ozone and classified 

severe-17. 

The proposed amendments to Rule 1124 update the rule and align specialty coating categories 

with the CTG dated December 1997 entitled Control of Volatile Organic Compound Emissions 

from Coating Operations at Aerospace Manufacturing and Rework Operations. The CTG is 

primarily a guidance document and requires rule action to implement its provisions. 
AVAQMD Rule 1124 7

Final Staff Report, 09/20/13

C. ECONOMIC ANALYSIS 

1. General 

The proposed amendments align new specialty coating categories with the aerospace 

CTG. Existing limits have not been lowered, and new categories have been added if 

they cannot be encompassed within existing rule categories. CTG VOC limits are 

presumptive RACT, and as such should be reasonably available. Coating users should 

not experience any increased cost for using product that are expected be readily 

available at this time. The additional coating categories also provide more specialized 

options for industry. 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the California 

Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) 

or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of 

sulfur. 

The proposed amendment of Rule 1124 is not subject to incremental cost effectiveness 

calculations because this rule does not impose BARCT or “all feasible measures”. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption would be 

the appropriate CEQA process for the proposed amendment of Rule 1124. 

1. The proposed amendment of Rule 1124 meets the CEQA definition of “project.” 

They are not “ministerial” actions. 

2. The proposed amendments to Rule 1124 are exempt from CEQA review 

because they will not create any adverse impacts on the environment. The 

proposed requirements in the amendment are more stringent because they will 

align specialty coating categories to those in the aerospace CTG by adding 

definitions and specialty coating categories that cannot be encompassed within 

existing rule categories. There are no changes to existing limits. The 

exemptions for materials marking coatings and temporary marking coatings 

have been removed for consistency with Part Marking Coating category. Since 

there is no potential that the amendments might cause the release of additional 

air contaminants or create any adverse environmental impacts, a Class 8 

categorical exemption (14 Cal. Code Reg. §15308) applies. 
8 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential adverse environmental impacts of compliance with the 

amendment of Rule 1124. Rule 1124 will expand the requirements of the rule to 

include all CTG specialty coating categories. Primers, adhesives, sealants, maskants, 

lubricants and “other” coatings should be reasonably available in commerce and should 

not cause additional usage of the products themselves, or of cleaning solvents. 

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B. 

VI. TECHNICAL DISCUSSION 

A. SOURCE DESCRIPTION 

1. Rule Applicability 

Rule 1124 generally applies to any operation associated with the manufacture and 

assembly of parts and products for aircraft and space vehicles. Affected industries 

include facilities which manufacture or rework commercial and military aircraft, 

satellite, space shuttle and rocket contractors and their subcontractors. Affected 

operations include, but are not limited to, manufacture, component manufacture, 

refinishing, repair maintenance and service of any type of commercial and military 

aircraft or spacecraft. This includes commercial and military airplanes, helicopters, 

dirigibles, balloons, missiles and spacecraft such as rockets, satellites and space 

shuttles. In general, Rule 1124 has similar applicability to the Maximum Achievable 

Control Technology (MACT) Standard for Aerospace Manufacturing and Rework 

Facilities (40 CFR 63 Subpart GG, commencing with §63.741). Materials regulated by 

this rule include primers, coatings, adhesives, sealants, maskants, lubricants, and others. 

Some of these materials are covered under a USEPA Control Techniques Guideline 

(CTG) entitled “Control of Volatile Organic Compound Emissions from Coating 

Operations at Aerospace Manufacturing and Rework Operations” (December 1997, 

EPA-453/R-97-004). 

Five facilities in the AVAQMD will be potentially be affected by the proposed 

amendments to Rule 1124. These facilities are Lockheed Martin Aeronautics 
AVAQMD Rule 1124 9

Final Staff Report, 09/20/13

Company, Northrop Grumman Systems Corp., The Boeing Company, Incotec 

Corporation, and Morton Manufacturing. 

2. Rule History 

On July 1, 1997 the AVAPCD was created pursuant to statute (former H&S Code 

§40106, A.B. 266-Knight Ch. 542, statutes of 1996) and assumed all air pollution 

control responsibilities from the SCAQMD for the area of Los Angeles County outside 

the South Coast Air Basin. The SCAQMD rules in effect within the jurisdiction of the 

AVAPCD remained in effect until the AVAPCD Governing Board superseded or 

amended them. Rule 1124 as amended by SCAQMD on December 13, 1996 was one 

of these rules. 

On January 1, 2002 the AVAQMD was created pursuant to statute (H&S Code §41300 

et seq.) to replace the AVAPCD. Once again the rules in effect at the time of the 

change remained in effect until the AVAQMD Governing Board superseded or 

amended them. The December 13, 1996 version of the SCAQMD rule was the effective 

version within the AVAQMD. The AVAQMD subsequently amended rule 1124 on 

March 20, 2007, and this is the current version of the rule in the rulebook. 

The version of the rule in the SIP for the AVAQMD is not the version contained in the 

rulebook. The March 20, 2007 version as amended by AVAQMD has not been 

approved into the SIP. Therefore, a SCAQMD version of Rule 1124 has been retained 

in the SIP. The December 13, 1996 SCAQMD version (which was the rule version 

retained in the AVAPCD rule book upon formation) was submitted as a SIP revision on 

August 1, 1997 after the creation of the AVAPCD. Therefore the SCAQMD 

submission could not be applied to the AVAPCD’s SIP and USEPA’s action on the 

SCAQMD submission recognized this fact. Thus, the version in the SIP for the area 

within the jurisdiction AVAQMD is the SCAQMD January 13, 1995 version. Please 

see section (F) below for a more detailed explanation of the SIP history. 

B. EMISSIONS 

There are no changes to existing VOC limits in the amendment of Rule 1124. The proposed 

requirements in the amendment are more stringent because they will align specialty coating 

categories to those in the CTG by adding definitions and categories previously not covered. 

There is no potential that the amendments might cause the release of additional air 

contaminants or create any adverse environmental impacts. 

C. CONTROL REQUIREMENTS 

1. VOC Limitations 

Rule 1124 provides a variety of VOC limits on primers, coatings, adhesives, sealants, 

maskants and lubricants used in the manufacturer and remanufacture of aerospace 

assembly and components. These are the primary control requirements in the rule (see 

rule subsection (C)(1)). The specific proposed amendments to various VOC limitations 
10 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

are indicated in the iterated version of the rule in Appendix “A” and section (VI)(B) 

above. 

2. Control Equipment 

In the alternative to VOC limits, Rule 1124 provides that a coating of any VOC amount 

may be used so long as it is vented to an air pollution control device with 95 percent 

destruction efficiency and 90 percent capture efficiency for an overall control efficiency 

of 85 percent (see rule subsection (C)(6)). 

D. PROPOSED RULE SUMMARY 

This section gives a brief overview of the proposed amendment to Rule 1124. 

1. Section (A) – General 

Defined terms have been capitalized for consistency with rule format. 

2. Section (B) – Definitions 

Defined terms have been capitalized within the rule for consistency with rule format. 

The following definitions have been added or updated: 

Subsection (B)(1) – “Ablative Coating” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(2) – “Adhesion Promoter” has been termed a coating rather than a 

primer for consistency with CTG nomenclature. 

Subsection (B)(4) – “Adhesive Bonding Primer” definition has been updated for 

consistency with the CTG definition. 

Subsection (B)(14) – “Bearing Coating” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(15) – “Bonding Maskant” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(16) – “Caulking and Smoothing Compound” definition has been added 

to reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(17) – “Chemical Agent-Resistant Coating (CARC)” definition has been 

added to reflect the CTG specialty coatings category of the same name in subsection 

(C)(1)(a). 

Subsection (B)(19) – “Chemical Milling Maskant” definition has been updated for 

consistency with the CTG. Previously defined as “Maskant for Chemical Milling.” 
AVAQMD Rule 1124 11

Final Staff Report, 09/20/13

Subsection (B)(20) – “Chemical Processing Maskant” definition has been reformatted 

for consistency. Previously defined as “Maskant for Chemical Processing.” 

Subsection (B)(22) – “Coating” definition has been added for consistency with the CTG 

and for clarity. 

Subsection (B)(24) – “Commercial Exterior Aerodynamic Structure Primer” definition 

has been added to reflect the CTG specialty coatings category of the same name in 

subsection (C)(1)(a). 

Subsection (B)(25) – “Commercial Interior Adhesive” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(26) – “Compatible Substrate Primer” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(28) – “Corrosion Prevention Compound System” definition has been 

added to reflect the CTG specialty coatings category of the same name in subsection 

(C)(1)(a). 

Subsection (B)(29) – “Critical Use and Line Sealer Maskant” definition has been added 

to reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Previously defined as “Line Sealer Maskant.” 

Subsection (B)(30) – “Cryogenic Flexible Primer” definition has been added to reflect 

the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Previously defined as “Line Sealer Maskant.” 

Subsection (B)(31) – “Cryoprotective Coating” definition has been added to reflect the 

CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(32) – “Cyanoacrylate Adhesive” definition has been added to reflect the 

CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(37) – “Electrostatic Discharge and Electromagnetic Interference (EMI) 

Coating” definition has been added to reflect the CTG specialty coatings category of the 

same name in subsection (C)(1)(a). 

Subsection (B)(38) – “Elevated-Temperature Skydrol-resistant Commercial Primer” 

definition has been added to reflect the CTG specialty coatings category of the same 

name in subsection (C)(1)(a). 

Subsection (B)(39) – “Epoxy Polyamide Topcoat” definition has been added to reflect 

the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(40) – “Exempt Compounds” definition has been modified to be 

consistent with District Tert-Butyl Acetate (tBA) policy. 
12 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

Subsection (B)(42) – “Fastener” definition has been has been added for clarification of 

the CTG specialty coatings category for Fastener Sealant in subsection (C)(1)(a). 

Subsection (B)(44) – “Fire Resistant (Interior) Coating” definition has been modified to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a) by 

including civilian, military and space applications. 

Subsection (B)(45) – “Flexible Primer” definition has been has been added to reflect the 

CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(54) – “Insulation covering” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(55) – “Intermediate Release Coating” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(56) – “Lacquer Coating” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(64) – “Part Marking Coating” definition has been added to reflect the 

CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(68) – “Prebonding Etchant” definition has been modified by combing 

definition with Wire Prebonding Etchant to reflect the CTG specialty coatings category 

of the same name in subsection (C)(1)(a). 

Subsection (B)(69) – “Pretreatment Primer” has been changed to “Pretreatment 

Coating” for consistency with the CTG category. 

Subsection (B)(75) – “Rocket Motor Bonding Adhesive” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(76) – “Rocket Motor Nozzle Coating” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(78) – “Rubber-based Adhesive” definition has been added to reflect the 

CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(80) – “Screen Print Ink” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(82) – “Seal Coat Maskant” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(83) – “Silicone Insulation Material” definition has been added to reflect 

the CTG specialty coatings category of the same name in subsection (C)(1)(a). 
AVAQMD Rule 1124 13

Final Staff Report, 09/20/13

Subsection (B)(87) – “Specialized Function Coating” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(88) – “Specialty Coating” definition has been added to reflect the CTG 

specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(95) – “Thermal Control Coating” definition has been added to reflect 

the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Subsection (B)(96) – “Topcoat” definition has been modified to CTG definition for 

clarification, and to include clear coating CTG category. 

Subsection (B)(103) – “Volatile Organic Compound (VOC)” definition has been 

modified for consistency with District Tert-Butyl Acetate (tBA) policy. 

Subsection (B)(104) – “Wet Fastener Installation Coating” definition has been added to 

reflect the CTG specialty coatings category of the same name in subsection (C)(1)(a). 

Definitions for the following definitions removed: 

Previous subsection (B)(21) – “Epoxy Based Fuel Tank Coating” has been removed. 

This category was combined with General Fuel Tank Coating in previous amendment. 

Previous subsection (B)(34) – “Line Sealer Maskant” has been removed. This category 

is combined with definition for Critical Use and Line Sealer Maskant. 

Previous subsection (B)(37) – “Maskant for Chemical Milling” definition has been 

redefined as Chemical Milling Maskant for consistency with definition format. 

Previous subsection (B)(38) – “Maskant for Chemical Processing” definition has been 

redefined as Chemical Processing Maskant for consistency with definition format. 

Previous subsection (B)(52) – “Repair Maskant” has been removed. This definition not 

specifically used. Critical Use and Line Sealer Maskant definition includes a repair 

provision. 

Previous subsection (B)(55) – “Rubber Solution Fuel Tank Coating” has been removed. 

Definition no longer used. See Fuel Tank Coating – General or – Rapid Cure. 

Previous subsection (B)(66) – “Temporary Marking Coating” has been removed. 

Definition no longer used. See Part Marking Coating. 

Previous subsection (B)(69) – “Touch Up Coating” has been removed. Definition not 

used. See definition for Touch-Up Operation. 

Previous subsection (B)(78) – “Wire Ink” has been removed. Definition not used. See 

subcategories of Wire Coating category. 
14 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

Previous subsection (B)(79) – “Wire Prebonding Etchant” has been removed. See 

Prebonding Etchant. 

3. Section (C) – Requirements 

Subsection (C)(1)(a) table has been modified to incorporate specialty coating categories 

that were added in the definition section. Several coatings have been relocated for 

consistency with definitions in the CTG. Categories in Lubricant section have been 

specified for clarity by when the coating is applied, either at time of manufacture or 

installation. 

SPECIALTY COATING VOC LIMITS 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

AEROSPACE MATERIALS 

VOC 

Limit 

[Explanatory Comments, not a 

part of rule]

 

PRIMERS -- 

General 350 SIP category.

Adhesion Promoter 850 

Moved to coating category for 

consistency with CTG definition.

Adhesive Bonding Primers -- 

See AVAQMD 3/20/07 Staff 

Report for discussion of this 

category. 

 Commercial Aircraft 250 

 Military Aircraft 805 

Commercial Exterior Aerodynamic Structure Primer 650 

New CTG category. Not a 

subcategory of pretreatment 

primer.

Compatible Substrate Primer 780 

New CTG category. Not a low 

solids corrosion resistant primer.

Cryogenic Flexible Primer 645 

New CTG category. Not a 

subcategory of pretreatment 

primer.

Elevated Temperature Skydrol-Resistant Commercial Primer 740 

New CTG category. Not a 

subcategory of pretreatment 

primer.

Flexible Primer 640 

New CTG category. Not a 

subcategory of pretreatment 

primer.

Low Solids Corrosion Resistant Primer 350 

Added in 3/20/07 amendment. 

CTG category.

Pretreatment Primer 780 

Moved to coating category for 

consistency with CTG definition.

Primer Compatible with Rain Erosion-Resistant Coating 850 SIP category.

 

COATINGS -- 
AVAQMD Rule 1124 15

Final Staff Report, 09/20/13

Ablative Coating 600 New CTG category.

Adhesion Promoter Coating 850 

Moved from primer category for 

consistency with CTG definition.

Antichafe Coating 420 SIP Category.

Bearing Coating 620 

New CTG category, not a 

subcategory of Fastener 

Lubricative or non-fastener 

lubricative coating.

Chemical Agent-Resistant Coating 550 

New specialized CTG category, 

resistant to chemical warfare 

agents, not a subcategory of 

topcoat.

Conformal Coating 750 SIP Category.

Cryoprotective Coating 600 

New CTG category, not specific 

to space vehicles. Prevents ice 

formation.

Electric- or Radiation-Effect Coating 800 SIP Category.

Electrostatic Discharge and Electromagnetic Interference (EMI) 

Coating 800 

New CTG category, not specific 

to space vehicles.

Fire-Resistant (Interior) Coating -- 

 Civilian 650 SIP Category.

 Military 800 SIP Category.

 Space 800 

Sub-category split out to conform 

to CTG definition.

Flight-Test Coating -- 

 Used on Missiles or Single Use Target AircCraft 420 SIP Category.

 All Other 840 SIP Category.

Fuel-Tank Coating -- 

See AVAQMD 3/20/07 Staff 

Report for discussion of this 

category. 

 General 420 

 Rapid Cure 720 

High-Temperature Coating 850 SIP Category.

Impact-Resistant Coating 420 SIP Category.

Intermediate Release Coating 750 New CTG category. 

Lacquer Coating 830 

New CTG category. Lacquer is 

not always a topcoat.

Metallized Epoxy Coating 700 SIP Category.

Mold Release Coatings 780 

Added in 3/20/07 amendment. 

CTG category.

Optical Anti-Reflection Coating 700 SIP Category.

Part Marking Coating 850 

New CTG category. Part 

marking can be permanent or 

temp. Remove exemption (G)(9) 

and (G)(11).
16 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

Pretreatment Coating 780 

Moved from primer category for 

consistency with CTG definition.

Rain Erosion-Resistant Coating 800 SIP Category.

Rocket Motor Nozzle Coating 660 

New CTG category. Not a 

subcategory as it is very specific 

to withstand heat, pressure and 

magnetic forces.

Scale Inhibitor Coating 880 SIP Category.

Space-Vehicle Coatings, Other, not including Electric Discharge 

and EMI Protection Coating or Fire Resistant (Interior) Coating 1000 

CTG does not distinguish between 

space and other. SIP category.

 Electrostatic Discharge and Electromagnetic Interference 

(EMI) Protection Coating 800 

This category is not specific to 

space vehicles. Alphabetized into 

general table. 

 Fire-Resistant (Interior) Coating 800 

This category is not specific to 

space vehicles. Alphabetized into 

general table. 

 Other Space-Vehicle Coating 1000 

Specialized Function Coating 890 New CTG category.

Temporary Protective Coating 250 SIP Category.

Thermal Control Coating 800 New CTG category.

Topcoat -- 

Definition updated to include 

clear coating category from CTG.

 Clear 520 SIP category.

 Epoxy Polyamide 660 New CTG category.

 Other 420 

Reorganized for consistency with 

rest of table format.

Unicoat Coating 420 SIP category.

Wet Fastener Installation Coating 675 New CTG category.

Wing Coating 750 SIP Category.

Wire Coatings SIP Categories.

 Electronic Wire Coating 420 

 Anti-Wicking 420 

 Pre-Bonding Etchant 420 

 Phosphate Ester Resistant Ink 925 

 

ADHESIVES -- 

Commercial Interior Adhesive 760 

New CTG category, not covered 

by non-structural category.

Cyanoacrylate Adhesive 1020 New CTG category.

Fuel-Tank Adhesive 620 SIP category.

Non-Structural Adhesive 250 SIP category.

Rocket Motor Bonding Adhesive 890 

New CTG category, not covered 

by space vehicle adhesive.
AVAQMD Rule 1124 17

Final Staff Report, 09/20/13

Rubber-based Adhesive 850 New CTG category.

Space Vehicle Adhesive 800 SIP category.

Structural Adhesive -- 

See AVAQMD 3/20/07 Staff 

Report for discussion of this 

category. 

 Autoclavable 50 

 High Temperature - Autoclavable 650 

 Non-Autoclavable 850 

 

SEALANTS -- 

Extrudable, Rollable, or Brushable or Extrudable Sealant 280 

Added in 3/20/07 amendment. 

CTG category.

Fastener Sealant 675 

Inadvertently removed by 

SCAQMD. This limit is in SIP 

version of Rule.

Other 600 SIP category.

 

MASKANTS -- 

Bonding Maskant 1230 

New CTG category. Definition of 

Chemical Milling Maskants says 

it is not bonding maskant. 

Critical Use and Line Sealer Maskant 750 

Renamed Touch-up, Line-sealer 

Maskant category for consistency 

with CTG.

For Chemical Milling Maskant 

Added in 3/20/07 amendment. 

CTG category.

 For use with Type I Etchant 250 

 For use with Type II Etchant 160 

 For Chemical Processing *Less water, exempt compounds and 

perchloroethylene (PERC) 250* 

Photolithographic Maskant 850 SIP category.

Touch-up, Line-Sealer Maskant 750 

Becomes Critical Use and Line 

Sealer Maskant.

* Less water exempt compounds and perchloroethylene (PERC). Moved to category line.

Seal Coat Maskant 1230 

New CTG category. Definition of 

Chemical Milling Maskants says 

it is not bonding maskant. 

 

LUBRICANTS -- 

Fastener Installation Lubricant (applied at time of 

aircraft/component assembly) -- Clarification. SIP categories.

 Solid-Film Lubricant 880 

 Dry Lubricative Material 675 
18 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

Fastener Lubricative Coating (applied at time of fastener 

manufacture) -- Clarification. SIP categories.

 Solid-Film Lubricant 250 

 Dry Lubricative Material 120 

 Barrier Coating 420 

Non-Fastener Lubricative Coatings (applied at time of nonfastener manufacture) -- Clarification. SIP categories.

 Solid-Film Lubricant 880 

 Dry Lubricative Materials 675 

 

OTHER -- 

Caulking and Smoothing Compound 850 New CTG category.

Corrosion Prevention Compound System 710 New CTG category.

Insulation Covering 740 New CTG category.

Screen Print Ink 840 

New CTG category not covered 

specifically by graphic arts rules.

Silicone Insulation Material 850 

New CTG category for aerospace 

industry specific material.

Rule titles added to referenced rules. 

4. Section (D) – Recordkeeping and Reporting Requirements 

Rule title added to referenced rule. 

5. Section (E) – Compliance Procedures and Test Methods 

Equations have been updated using equation tool. 

Subsection (E)(2) and (E)(3) updated to include ASTM and SCAQMD test method 

titles. 

Subsection (E)(3)(d) test method updated and rule citation corrected pursuant to 

USEPA comment. 

6. Section (F) – Administrative Requirements 

Rule title added to referenced rule. 

7. Section (G) - Exemptions 

Subsections (G)(9) and (G)(11) have been removed for consistency with CTG Part 

Marking Coating category. 
AVAQMD Rule 1124 19

Final Staff Report, 09/20/13

E. 110(l) ANALYSIS 

The version of Rule 1124 shown in the AVAQMD SIP is SCAQMD Rule 1124 – Aerospace 

Assembly and Component Coating Operations as amended on January 13, 1995 (61 FR 20136, 

05/06/96). Therefore, the District will perform the 110(l) determination based upon differences 

between the January 13, 1995 version and the current proposed amendments. 

Rule 1124 was amended by SCAQMD subsequent to the January 13, 1995 SIP version on 

December 13, 1996. The December 13 1996 SCAQMD amendment is the version that was 

retained in the rule book by the AVAPCD upon creation on July 1, 1997. This amendment 

redefined adhesion promoter as an adhesive bonding primer and extended the compliance dates 

for: several types of adhesive bonding primers, fuel-tank coatings, solid-film lubricants and 

primer coatings from 1997 to either 1998, 1999, 2000, or 2002, because compliant coatings had 

not been qualified by all major aerospace companies. In addition, the VOC limits were 

decreased for dry lubricative coatings. The fastener sealant category was included in the 

December 13, 1995 amendment, but was inadvertently eliminated and replaced with dry 

lubricative materials in the December 13, 1996 amendment. The fastener sealant category has 

been added back in to the proposed amendment to correct this typographical error. The 

amendment was a strengthening of the rule rather than a relaxation and no 110(l) determination 

was necessary. 

AVAQMD again amended Rule 1124 on March 20, 2007. This amendment was designed to 

harmonize coating categories and definitions with the CTG and MACT Standard. This 

amendment increased the VOC limit in the following categories: Adhesion Promoters, 

Adhesion Bonding Primer (Military), Fuel tank Coating (Rapid Cure), and High Temperature 

Structural Adhesive (Autoclavable). The amendment also contained a decrease in the VOC 

limits for: Antichafe Coatings, Extrudable, Rollable and Brushable Sealants, and Maskants for 

Use with Type II Etchants. The amendments also added limits for several unregulated 

coatings, namely Low Solids Corrosion Resistant Primer and Mold Release Coatings. This 

amendment was designed such that increases and decreases resulted in no emissions increase 

overall from coatings subject to 1124.2

 The AVAQMD obtained coatings usage data from the 

two (2) major sources in the aerospace manufacturing source category and was able to show a 

reduction in emissions by 2,690 lbs/yr.3

 This rule amendment did not interfere with attainment 

and reasonable further progress, or any other FCAA requirement. 

The District is proposing to add additional specialty coating categories which were previously 

unregulated that will align the rule with the CTG. This rule amendment did not interfere with 

attainment and reasonable further progress, or any other FCAA requirement because the 

AVAQMD has determined that all limits and requirements contained in the proposed 

amendments are as stringent or more stringent that in the SIP version of the rule. 

 

2

 Staff report for the Proposed Amendment to Rule 1124 – Aerospace Assembly and Component 

Manufacturing Operations for adoption on March 20, 2007, D2 2/12/07. 

3

 Ibid., p. 10. 
20 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

F. SIP HISTORY 

1. SIP History. 

Prior to July 1, 1997 the Antelope Valley was contained within the South Coast Air 

Quality Management District (SCAQMD). On July 1, 1997 the Antelope Valley Air 

Pollution Control District (AVAPCD) replaced the SCAQMD as the agency with 

jurisdiction over the Los Angeles County portion of the Mojave Desert Air Basin 

(MDAB). On January 1, 2001 the AVAPCD was replaced by the AVAQMD. Pursuant 

to both statutory changes, the rule and regulations of the predecessor district were 

retained until the Governing Board adopted, amended or rescinded them. At the first 

meeting of the both the AVAPCD and the AVAQMD, the respective Governing Boards 

reaffirmed all the rules and regulations in effect at the time the agency changed. 

The jurisdiction of the AVAPCD and the AVAQMD were specified in the statutes as 

the portion of the Los Angeles County contained within the MDAB. The MDAB was 

formerly known as the Southeast Desert Air Basin (SEDAB). In 1997 the SEDAB was 

split into the MDAB and the Salton Sea Air Basin. Descriptions of these air basins can 

be found in 17 Cal. Code Regs. §§60109 and 60144. Since USEPA adopts SIP 

revisions in California as effective within jurisdictional boundaries of local air districts, 

when the local air district boundaries change the SIP as approved by USEPA for that 

area up to the date of the change remains as the SIP in that particular area. Thus, upon 

creation of the AVAPCD on July 1, 1997 the AVAPCD acquired the SIP applicable to 

the Antelope Valley portion of the SCAQMD that was affected as of June 30, 1997. 

Likewise the AVAQMD acquired the SIP that was effective in the jurisdiction of the 

AVAPCD as of December 31, 2000. Therefore, the SIP history for this region is based 

upon the rules adopted, effective, and approved for the Antelope Valley by SCAQMD. 

2. SIP Analysis. 

Rule 1124 was originally adopted on July 6, 1979 by SCAQMD and submitted as a SIP 

revision to USEPA. USEPA approved that submittal on September 28, 1981 (46 FR 

47451; 40 CFR 52.220(c)(58)(88)(B)). Rule 1124 was thereafter amended by 

SCAQMD on May 7, 1982 and January 6, 1984. The 1984 revision was approved into 

the SIP by USEPA on January 24, 1985 (50 FR 3338; 40 CFR 52.220(c)(154)(vii)(A)). 

SCAQMD further amended Rule 1124 on June 1, 1984, January 9, 1987, February 6, 

1987, April 3, 1987, May 5, 1989, March 2, 1990, April 4, 1990, June 1, 1990, 

November 2, 1990, December 7, 1990, August 2, 1991, March 6, 1992, December 4 

1992, and December 10, 1993. Many, if not all, of these amendments were submitted as 

SIP revisions, but USEPA action on such submissions is unknown. SCAQMD further 

amended Rule 1124 on January 13, 1995 and USEPA approved this amendment as a 

SIP revision on May 6, 1996 (61 FR 20136; 40 CFR 52.220(c)(215)(i)(A)(5)). 

SCAQMD further amended Rule 1124 on December 13, 1996; however, that rule 

amendment was not submitted to USEPA until August 1, 1997 after the creation of the 

AVAPCD. Thus, the submittal of the December 13, 1996 rule and its subsequent 

approval by USEPA (8/17/98 63 FR 43884; 40 CFR 52.220(c)(248)(i)(B)(1)) is not 
AVAQMD Rule 1124 21

Final Staff Report, 09/20/13

effective for the jurisdiction of the AVAPCD and its successor agency the AVAQMD. 

The AVAQMD subsequently amended rule 1124 on March 20, 2007, and this is the 

current version of the rule in the rulebook. This amendment has not been approved into 

the SIP because USEPA indicated that there were several specialty coating categories 

from the CTG that were not included in the rule amendment. Therefore, the current 

version in the AVAQMD SIP of this rule is the SCAQMD rule as amended on January 

13, 1995. 

 
22 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

This page intentionally left blank. 
AVAQMD Rule 1124 A-1

Final Staff Report, 09/20/13

APPENDIX "A"

Rule 1124 - Aerospace Assembly and Component Manufacturing Operations

Iterated Version 

The iterated version is provided so that the changes to an existing rule may be easily found. The manner 

of differentiating text is as follows: 

1. Underlined text identifies new or revised language. 

2. Lined out text identifies language which is being deleted. 

3. Normal text identifies the current language of the current rule which will remain unchanged by the 

adoption of the proposed amendments. 

4. Italicized text identifies explanatory material that is not part of the proposed language. 
A-2 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

This page intentionally left blank. 
(Adopted: 07/06/79; Amended: 5/07/82; Amended: 01/06/84; 

Amended: 06/01/84; Amended: 01/09/87; Amended: 2/06/87; 

Amended: 04/03/87; Amended 05/05/89; Amended: 03/02/90; 

Amended: 04/06/90; Amended: 06/01/90; Amended: 11/02/90; 

Amended: 12/07/90; Amended: 08/02/91; Amended 03/06/92; 

Amended: 12/04/92; Amended: 12/10/93; Amended: 1/13/95; 

Amended: 12/13/96; Amended: 03/20/07; Amended: mm/dd/yy) 

AVAQMD Rule 1124 1124-1

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

RULE 1124 

Aerospace Assembly and 

Component Manufacturing Operations 

(A) General 

(1) Purpose 

(a) To reduce Vvolatile Oorganic Ccompounds (VOC) emissions from aerospace 

assembly and component manufacturing operations.

(2) Applicability 

(a) This rule applies to any operation associated with manufacturing and assembling 

products for Aaircraft and Sspace Vvehicles. The affected industries include 

commercial and military Aaircraft, satellite, space shuttle and rocket 

manufacturers and their subcontractors.

(b) This rule also applies to maskant applicators, Aaircraft refinishers, Aaircraft 

Ffastener Mmanufacturers, Aaircraft operators, and Aaircraft maintenance and 

service facilities. 

(B) Definitions 

For the purpose of this rule, the following definitions shall apply:

[Unless otherwise indicated, new definitions are derived from “Control of Volatile Organic 

Compound Emissions from Coating Operations at Aerospace Manufacturing and Rework 

Operations,” EPA-453/R-97-004, December 1997.]

(1) Ablative Coating – A coating that chars when exposed to open flame or extreme 

temperatures, as would occur during the failure of an engine casing or during 

aerodynamic heating. The ablative char surface serves s an insulative barrier, protecting 

adjacent components from the heat or open flame. 
1124-2 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(21) Adhesion Promoter Coating – A Coatingprimer that is used to promote wetting and 

form a chemical bond with a subsequently applied Ssealant or other elastomer. [Moved 

from primer category for consistency with the CTG definition.]

(32) Adhesive - Any substance that is used to bond one surface to another surface by 

attachment. 

(43) Adhesive Bonding Primer - A Pprimer applied in a thin film to Aaerospace 

Ccomponents for the purpose of corrosion inhibition andto increased adhesive or 

adhesive film bond strength by attachment. 

(54) Aerosol Coating Product - A pressurized coating product containing pigments or resins 

that is dispensed by means of a propellant, and is packaged in a disposable can for 

hand-held application. 

(65) Aerospace Component - The raw material, partial or completed fabricated part, 

assembly of parts, or completed unit of any Aaircraft or Sspace Vvehicle and includes 

integral equipment such as models, mock-ups, prototypes, molds, jigs, tooling, 

hardware jackets, and test coupons. 

(76) Aerospace Material – any coating, Pprimer, Aadhesive, Ssealant, maskant, lubricant, 

Sstripper or hand-wipe cleaning or clean-up solvent used during the manufacturing, 

assembly, refinishing, maintenance or service of an Aerospace Component.]

(87) Air Brush Operations – Application of Aerospace Material with equipment operating at 

air pressure between 25 psi and 116 psi and an air volume of 0.7 cfm and 1.75 

respectively.

(98) Aircraft - Any machine designed to travel through the air, without leaving the earth's 

atmosphere, whether heavier or lighter than air, including airplanes, balloons, dirigibles, 

helicopters, and missiles. 

(109) Air Pollution Control Officer (APCO) – The person appointed to the position of Air 

Pollution Control Officer of the District pursuant to the provisions of California Health 

& Safety Code §40750 and his or her designee.

(110) Antichafe Coating - A coating applied to areas of moving Aaerospace Ccomponents 

which may rub during normal operation. 

(121) Anti-Wicking Wire Coating - The outer coating of a wire which prevents fluid wicking 

into insulation of the wire. 

(132) Barrier Coating - A coating applied in a thin film to fasteners to inhibit dissimilar metal 

corrosion and to prevent galling.
AVAQMD Rule 1124 1124-3 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(14) Bearing Coating – A coating applied to an antifriction bearing, a bearing housing, or the 

area adjacent to such bearing in order to facilitate bearing function or to protect be 

material from excessive wear. A material shall not be classified as a Bearing Coating if 

it can also be classified as a dry lubricative material or a solid-film lubricant. 

(15) Bonding Maskant – A temporary coating used to protect selected areas of aerospace 

parts from strong acid or alkaline solutions during processing for bonding. 

(16) Caulking and Smoothing Compound – Semi-solid materials which are applied by Hand 

Application Methods and are used to aerodynamically smooth exterior vehicle surfaces 

or fill cavities such as bolt hole accesses. A material shall not be classified as a 

Caulking and Smoothing Compound if it can also be classified as a Sealant. 

(17) Chemical Agent-Resistant Coating (CARC) – An exterior Topcoat designed to 

withstand exposure to chemical warfare agents or the decontaminants used on these 

agents. 

(183) Chemical Milling - The removal of metal by chemical action of acids or alkalis.

(19) Chemical Milling Maskant - A coating applied directly to aluminum components to 

protect surface areas when Chemical Milling the component with a Type I or Type II 

Etchant. Type I Chemical Milling Maskants are used with a Type I Etchant and Type II 

Chemical Milling Maskants are used with a Type II Etchant. This definition does not 

include Bonding Maskants, Critical Use and Line Sealant Maskants, and Seal Coat 

Maskants. Additionally, maskants that must be used with a combination of Type I or II 

Etchants and any of the above types of maskants (I.e., Bonding, Critical Use and Line 

Sealer, and Seal Coat) are not included. Maskants that are defined as Specialty 

Coatings are not included in this definition. [Definition updated to CTG definition for 

clarity of categories.]

(20) Chemical Processing Maskant - A coating applied directly to an Aerospace Component 

to protect surface areas when anodizing, aging, bonding, plating, etching, and/or 

performing other chemical surface operations on the component.

(1421) Clear Topcoat - A Ttopcoat that contains no visible pigments and is uniformly 

transparent when applied.

(22) Coating – A material that is applied to the surface of an aerospace vehicle or component 

to form a decorative, protective, or functional solid film, or the solid film itself.

(2315) Coating Application Equipment - Equipment used for applying coating to a substrate. 

Coating Aapplication Eequipment includes coating distribution lines, coating hoses, 

pressure-pots, spray guns, and hand-application equipment, such as hand-rollers, 

brushes, daubers, spatulas, and trowels.
1124-4 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(24) Commercial Exterior Aerodynamic Structure Primer – A Primer used on aerodynamic 

components and structures that protrude from the fuselage, such as wings and attached 

components, control surfaces, horizontal stabilizers, vertical fins, wing-to-body fairings, 

antennae, and landing gear and doors, for the purpose of extended corrosion protection 

and enhanced adhesion. 

(25) Commercial Interior Adhesive – Materials used in the bonding of passenger cabin 

interior components. These components must meet the FAA fireworthiness 

requirements. 

(26) Compatible Substrate Primer – Either compatible epoxy primer or adhesive primer. 

Compatible epoxy primer is primer that is compatible with the filled elastomeric coating 

and is epoxy based. The compatible substrate primer is an epoxypolyamide primer used 

to promote adhesion of elastomeric coatings such as impact-resistant coatings. 

Adhesive primer is a coating that (1) inhibits corrosion and serves as a primer applied to 

bare metal surfaces or prior to adhesive application, or (2) is applied to surfaces that can 

be expected to contain fuel. Fuel tank coatings are excluded from this category. 

(2716) Conformal Coating - A coating applied to electrical conductors and circuit boards to 

protect them against electrical discharge damage and/or corrosion.

(28) Corrosion Prevention Compound System – A coating system that provides corrosion 

protection by displacing water and penetrating mating surfaces, forming a protective 

barrier between the metal surface and moisture. Coatings containing oils or waxes are 

excluded from this category. 

(29) Critical Use and Line Sealer Maskant – A temporary coating, not covered under other 

maskant categories, used to protect selected areas of aerospace parts from strong acid or 

alkaline solutions such as those used in anodizing, plating, Chemical Milling and 

processing of magnesium, titanium, or high-strength steel, high-precision aluminum 

Chemical Milling of deep cuts, and aluminum Chemical Milling of complex shapes. 

Materials used for repairs or to bridge gaps left by scribing operations (i.e., line sealer) 

are also included in this category. 

(30) Cryogenic Flexible Primer – A Primer designed to provide corrosion resistance, 

flexibility, and adhesion of subsequent coating systems when exposed to loads up to and 

surpassing the yield point of the substrate at cryogenic temperatures (-275°F and 

below). 

(31) Cryoprotective Coating – A coating that insulates cryogenic or subcooled surfaces to 

limit propellant boil-off, maintain structural integrity of metallic structures during 

ascent or re-entry, and prevent ice formation. 

(32) Cyanoacrylate Adhesive – A fast-setting, single component Adhesive that cures at room 

temperature. Also known as “super glue.” 
AVAQMD Rule 1124 1124-5 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(33) District – The Antelope Valley Air Quality Management District, the geographical area 

of which is described in District Rule 103. 

(3417) Dry Lubricative Materials -Coatings consisting of lauric acid, cetyl alcohol, waxes or 

other non-cross linked or resin bound materials which act as a dry lubricant or 

protective coat. 

(18) District – The Antelope Valley Air Quality Management District, the geographical area 

of which is described in District Rule 103. [Alphabetized.]

(3519) Electric- oOr Radiation-Effect Coatings - Include electrically conductive coatings and 

radiation effect coatings and coating systems the uses of which may include prevention 

of radar detection.

(3620) Electronic Wire Coating - The outer electrical insulation coating applied to tape 

insulation of a wire specifically formulated to smooth and fill edges.

(37) Electrostatic Discharge and Electromagnetic Interference (EMI) Coating – A coating 

applied to Space-Vehicles, missiles, aircraft radomes, and helicopter blades to disperse 

static energy or reduce electromagnetic interference. 

(38) Elevated-Temperature Skydrol-resistant Commercial Primer – Primer applied primarily 

to commercial Aircraft (or commercial Aircraft adapted for military use) that must 

withstand immersion in phosphate-ester (PE) hydraulic fluid (Skydrol 500b or 

equivalent) at the elevated temperature of 150°F for 1,000 hours. 

(21) Epoxy Based Fuel-Tank Coating - Acoating that contains epoxy resin that is applied to 

a fuel tank of an aircraft to protect it from corrosion and/or bacterial growth. [Definition 

deleted. This category was combined with General Fuel Tank Coating in previous 

amendment which has same VOC limit.] 

(39) Epoxy Polyamide Topcoat – Coating used where harder films are required or in some 

areas where engraving is accomplished in camouflage colors. 

(4022) Exempt Compounds - A compound identified as exempt in 40 CFR 51.100(s)(1). 

[Definition modified to be consistent with District Tert-Butyl Acetate (tBA) policy.]

(4123) Facility - Any permit unit, group of permit units, non-permitted equipment or any 

combination thereof which emits or may emit an Air Pollutant; and belongs to a single 

major industrial group in the Standard Industrial Classification manual; and is located 

on a single parcel of land or on contiguous property within the District; and which is 

owned or operated by the same person or by persons under common control.

(42) Fastener – Any of various devices, including but not limited to, pins, collars, blots, nuts, 

and rivets for holding together two (2) or more objects or parts. 
1124-6 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(4324) Fastener Manufacturer - A Ffacility that coats Aaircraft fasteners, such as pins, collars, 

bolts, nuts, and rivets, with Ssolid-Ffilm Llubricants for distribution to other facilities.

(4425) Fire-Resistant (Interior) Coating - A cabin interior coating that meets for civilian 

aircraft the Federal Aviation Administration-required Ohio State University Heat 

Release, Fire and Burn Tests; for military aircraft, Aircraft Structure Integrity Program 

in MIL-STD-1530A and MIL-A-87221 (Northrop's MS-445-3.3.2.1 and MS-445-

3.3.2.2). 

(a) For civilian Aircraft, Fire-Resistant Interior Coatings are used on passenger 

cabin interior parts that are subject to FAA fireworthiness requirements. 

(b) For military Aircraft, Fire-Resistant Interior Coatings are used on parts that are 

subject to the flammability requirements of MIL-STD-1630A and MIL-A87721. 

(c) For space applications, Fire-Resistant Interior Coatings are used on parts that are 

subject to the flammability requirements of SE-R-0006 and SSP 30233. 

(45) Flexible Primer – A Primer that meets flexibility requirements such as those needed for 

adhesive bond primed fastener heads or on surfaces expected to contain fuel. The 

flexible coating is required because it provides a compatible, flexible substrate over 

bonded sheet rubber and rubber-type coatings as well as a flexible bridge between the 

fasteners, skin, and skin-to-skin joints on outer aircraft skins. This flexible bridge 

allows more topcoat flexibility around fasteners and decreases the chance of the topcoat 

cracking around the fasteners. The result is better corrosion resistance. 

(4626) Flight-Test Coating - A coating applied to an Aaircraft prior to flight testing to protect 

the Aaircraft from corrosion and to provide required marking during flight test 

evaluation. 

(4727) Fuel-Tank Adhesive - An Aadhesive used to bond components exposed to fuel that 

must be compatible with Ffuel-Ttank Ccoatings.

(4828) Fuel-Tank Coating, General -– A coating applied to a fuel tank of an Aaircraft to protect 

it from corrosion and/or bacterial growth. 

(4929) Fuel-Tank Coating, Rapid Cure – A fuel tank coating with shortened curing times and 

decreased sensitivity to low humidity during the curing process. 

(5030) Hand Application Method - The application of Aerospace Materials by manually held, 

non-mechanically operated equipment. Such equipment includes paint brushes, hand 

rollers, caulking guns, trowels, spatulas, syringe daubers, rags, and sponges.
AVAQMD Rule 1124 1124-7 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(5131) High-Temperature Coating - A coating that must withstand temperatures of more than 

350oF. 

(5232) High-Volume, Low-Pressure (HVLP) Spray - An Aerospace Materials application 

system which is operated with air pressure of between 0.1 and 10 pounds per square 

inch gauge (psig).

(5333) Impact-Resistant Coating - A flexible coating that protects Aaerospace Ccomponents, 

such as Aaircraft landing gear, and landing gear compartments, and other surfaces 

subject to impact and abrasion from runway debris.

(54) Insulation Covering – Material that is applied to foam insulation to protect the 

insulation from mechanical or environmental damage.

(55) Intermediate Release Coating – A thin coating applied beneath Topcoats to assist in 

removing the Topcoat in depainting operations and generally to allow the use of less 

hazardous depainting methods. 

(56) Lacquer Coating – A clear or pigmented coating formulated with a nitrocellulose or 

synthetic resin to dry by evaporation without a chemical reaction. Lacquers are 

resoluble in their original solvent.

(5734) Line-Sealer Maskant - A maskant used to cover scribe lines in maskant in order to 

protect against etchant in multi-step etching processing. [See Critical Use and Line 

Sealer Maskant.]

(5835) Low-Solids Adhesive Coating, Primer oOr Sealant - An Aadhesive coating, Pprimer or 

Ssealant which has less than one pound of solids per gallon of material. Such solids are 

the non-volatiles remaining after a sample is heated at 230oF (110oC) for one hour.

(5936) Low-Solids Corrosion Resistant Primer - A corrosion resistant polyurethane compatible 

Pprimer with enhanced adhesion and rain erosion resistance which contains no more 

than 45 percent (45%) solids, by weight, as applied. 

 (37) Maskant For Chemical Milling - A coating applied directly to an aerospace component 

to protect surface areas when chemically milling the component. [Formatted for 

consistency. See Chemical Milling Maskant.] 

(38) Maskant For Chemical Processing - A coating applied directly to an aerospace 

component to protect surface areas when anodizing, aging, bonding, plating, etching, 

and/or performing other chemical surface operations on the component. [Formatted for 

consistency. See Chemical Processing Maskant.]

(6039) Metallized Epoxy Coating - A coating that contains relatively large quantities of flake 

pigmentation for appearance and/or added protection. 
1124-8 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(6140) Mold Release Coating – A coating applied to the surface of a mold to prevent the 

molded component from sticking to the mold as it is removed.

(6241) Non-Structural Adhesive - An Aadhesive that bonds non-load-carrying Aaircraft 

components in non-critical applications and is not covered in any other specialty 

Aadhesive categories.

(6342) Optical Anti-Reflection Coating - A coating with a low reflectance in the infrared and 

visible wavelength range and is used for anti-reflection on or near optical and laser 

hardware.

(64) Part Marking Coating – Coatings or inks used to make identifying markings on 

materials, components, and/or assemblies. These markings may be either permanent or 

temporary.

(6543) Phosphate Ester Resistant Ink – A coating that is used for surface identification or 

marking which inhibits phosphate ester fluid corrosion. 

(6644) Photolithographic Maskant - A coating applied by Pphotoresist Ooperation(s) directly to 

printed circuit boards, and ceramic and similar substrates to protect surface areas from 

Cchemical Mmilling or Cchemical Pprocessing. 

(6745) Photoresist Operation - A process for the application or development of photoresist 

masking solution on a substrate, including preparation, soft bake, develop, hard bake, 

and stripping, and can be generally subdivided as follows: 

(a) Negative Photoresist Operation is a process where the maskant hardens when 

exposed to light and the unhardened maskant is stripped, exposing the substrate 

surface for Cchemical Mmilling or Cchemical Pprocessing. 

(b) Positive Photoresist Operation is a process where the maskant softens when 

exposed to light and the softened maskant is stripped, exposing the substrate 

surface for Cchemical Mmilling or Cchemical Pprocessing. 

(4668) Pre-bonding Bonding Etchant – An acid or basic substance that is used to increase the 

strength of an adhesive bond by chemically altering the substrate surface morphology to 

increase the bonding surface area of aerospace wire coatings to the underlying 

insulation layer. [Modified by combining Prebonding Etchant and Wire Prebonding 

Etchant definitions.]

(6947) Pretreatment Primer Coating - A Coatingprimer which contains no more than 12 percent 

(12%) solids, by weight and at least 0.5 percent (0.5%) acid by weight, to provide 

surface etching and is applied directly to metal surfaces to provide corrosion resistance, 

adhesion, and ease of stripping. [Moved from primer category for consistency with the 

CTG definition.]
AVAQMD Rule 1124 1124-9 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(7048) Primer - A coating applied directly to an Aaerospace Ccomponent for purposes of 

corrosion prevention, protection from the environment, functional fluid resistance 

and/or adhesion of subsequent coatings, Aadhesives, or Ssealants. 

(7149) Primer Compatible wWith Rain Erosion Resistant Coating - A Pprimer to which rain 

erosion resistant Ttopcoat is applied. 

(7250) Rain Erosion-Resistant Coating - A coating that protects leading edges, flaps, 

stabilizers, and engine inlet lips against erosion caused by rain impact during flight. 

(7351) Repair Coating - A coating used to recoat portions of a product which has sustained 

mechanical damage to the coating following normal painting operations. 

(52) Repair Maskant - A maskant used to cover imperfections in the maskant coat. [Specific 

definition not used. Critical Use and Line Sealer Maskant definition includes a repair 

provision.]

(7453) Rework - The inspection, repair, and reconditioning of Aaerospace Ccomponents 

subject to this rule.

(75) Rocket Motor Bonding Adhesive – Adhesive used in rocket motor bonding 

applications. 

(76) Rocket Motor Nozzle Coating – A catalyzed epoxy coating system used in elevated 

temperature applications on rocket motor nozzles.

(7754) Rollable, Brushable or Extrudable Sealant – A single or multi-component polymeric 

material used to seal many types of joints, gaps, removable panels, and windows where 

moderate movement is expected. Such material may be applied by rolling brushing 

extruding or daubing.

(78) Rubber-based Adhesive – A quick setting contact cement that provides a strong, yet 

flexible bond between two mating surfaces that may be of dissimilar materials.

(55) Rubber Solution Fuel-Tank Coating - A fuel-tank coating which performs as a sealant 

and protects the tank from corrosion and/or bacterial growth and is formulated with a 

butadiene acrylonitrile copolymer. [Definition no longer used. See Fuel Tank CoatingGeneral or –Rapid Cure.]

(7956) Scale Inhibitor Coating - A coating that is applied to the surface of a part prior to 

thermal processing to inhibit the formation of tenacious scale.

(80) Screen Print Ink – An ink used in screen printing processes during fabrication of 

decorative laminates and decals.
1124-10 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(8157) Sealants - Viscous semisolid materials that fill voids in order to seal out water, fuel, and 

other liquids and solids, and in some cases, air movement.

(82) Seal Coat Maskant – An overcoat applied over a maskant to improve abrasion and 

chemical resistance during production operations. 

(83) Silicone Insulation Material – An insulating material applied to exterior metal surfaces 

for protection from high temperatures caused by atmospheric friction or engine exhaust. 

These materials differ from Ablative Coatings in that they are not “sacrificial.”

(8458) Solid-Film Lubricant - A very thin coating consisting of a binder system containing as 

its chief pigment material one or more of the following: molybdenum disulfide, 

graphite, polytetrafluoroethylene (PTFE), or other solids that act as a dry lubricant 

between faying surfaces. 

(8559) South Coast Air Quality Management District (SCAQMD) – The air quality district 

created pursuant to Division 26, Part 3, Chapter 5.5 of the California Health & Safety 

Code (commencing with §40400). 

(8660) Space -Vehicle - A vehicle designed to travel beyond the earth's atmosphere. 

(87) Specialized Function Coating – A coating that fulfills extremely specific engineering 

requirements that are limited in application and are characterized by low volume usage. 

This category excludes coatings covered in other Specialty Coating categories. 

(88) Specialty Coating – A coating that, even though it meets the definition of a Primer, 

Topcoat, or self-priming Topcoat, has additional performance criteria beyond those of 

Primers, Topcoats, and self-priming Topcoats for specific applications. These 

performance criteria may include, but are not limited to, temperature or fire resistance, 

substrate compatibility, antireflection, temporary protection or marking, sealing, 

adhesively joining substrates, or enhanced corrosion protection.

(8961) Stencil Coating – An ink or coating that is rolled, sprayed with an airbrush or touch-up 

gun, or brushed while using a template to add identifying letters and or numbers to 

Aerospace Components.

(9062) Stripper - A volatile liquid applied to remove cured Aerospace Material or their 

residues.

(9163) Structural Adhesive - Autoclavable - An Aadhesive used to bond load-carrying 

Aaircraft components and is cured by heat and pressure in an autoclave. 

(9264) Structural Adhesive, High Temperature – Autoclavable – An Aadhesive used to bond 

load-carrying Aaircraft components which is cured by heat and pressure in an 

autoclave, and can withstand service temperatures above 450° F (232° C). 
AVAQMD Rule 1124 1124-11 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(9365) Structural Adhesive - Non-Autoclavable - An Aadhesive cured under ambient 

conditions and is used to bond load-carrying Aaircraft components or other critical 

functions, such as nonstructural bonding in the proximity of engines. 

 (66) Temporary Marking Coating - An ink or a coating used to make identifying markings, 

and is removed prior to delivery of the aerospace component and/or assembly. 

[Definition removed. See Part Marking Coating.] 

(9467) Temporary Protective Coating - A coating applied to an Aaerospace Ccomponent to 

protect it from mechanical and environmental damage during manufacturing.

(95) Thermal Control Coating – A coating formulated with specific thermal conductive or 

radiative properties to permit temperature control of the substrate.

(9668) Topcoat - A coating applied over a Pprimer or other coating on an aerospace vehicle or 

component for purposes such as appearance, identification, camouflage, or protection. 

Topcoats that are defined as specialty coatings are not included in this definition. 

[Definition modified to CTG definition for clarification pursuant to USEPA comment, 

and so definition will also include clear coating CTG category.]

(69) Touch-Up Coating - A coating used to cover minor coating imperfections appearing 

after the main coating operation. [Definition not used. See Touch-Up Operation.]

(9770) Touch-Up Operation – The application of Aerospace Materials by brush, air brush, 

detail HVLP spray equipment outside of a permitted paint enclosure to repair minor 

surface damage and imperfections after the main coating process. [See exemption 

(G)(6) for affected area exempted.]

(9871) Transfer Efficiency - The ratio of the weight or volume of coating solids adhering to an 

object to the total weight or volume, respectively, of coating solids used in the 

application process, expressed as a percentage. 

(9972) Type I Etchant – A Cchemical Mmilling etchant that contains varying amounts of 

dissolved sulfur and does not contain amines. 

(10073) Type II Etchant – A Cchemical Mmilling etchant that is a strong sodium 

hydroxide solution containing amines. 

(10174) Unicoat - A coating which is applied directly to an Aaerospace Ccomponent for 

purposes of corrosion protection, environmental protection, and functional fluid 

resistance that is not subsequently Ttopcoated. 

(10275) United States Environmental Protection Agency (USEPA) – The United States 

Environmental Protection Agency, the Administrator of the USEPA and his or her 

authorized representative. 
1124-12 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(10376) Volatile Organic Compound (VOC) - Any volatile compound containing the 

element carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, 

metallic carbides or carbonates, ammonium carbonate, and Eexempt Ccompounds as 

listed in 40 CFR 51.100(s)(1). [Definition modified for consistency with District TertButyl Acetate (tBA) policy.]

(104) Wet Fastener Installation Coating – A Primer or Sealant applied by dipping, brushing, 

or daubing to fasteners that are installed before the coating is cured. 

(10577) Wing Coating - A corrosion-resistant coating that is resilient enough to 

withstand the flexing of the wings. 

(78) Wire Ink - The surface identification stripe and mark on aerospace wire or cable which 

serves as an electrical insulator in the presence of high humidity. [Definition not used. 

See subcategories of Wire Coating Category.]

(79) Wire Prebonding Etchant - A non-additive surface treatment process to provide 

bondability of aerospace wire coatings to the underlying insulation layer [See 

“Prebonding Etchant” definition.]

(C) Requirements 

(1) VOC Content of Coatings 

(a) A person shall not apply to Aaerospace Ccomponents any Aerospace Materials, 

including any VOC-containing materials added to the original Aerospace 

Materials supplied by the manufacturer, which contain VOC in excess of the 

limits specified below: 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

Aerospace Materials: VOC Limit 

PRIMERS -- 

General 350 

Adhesion Promoter 850 

Adhesive Bonding Primers -- 

 Commercial Aircraft 250 

 Military Aircraft 805 

Low Solids Corrosion Resistant Primer 350 

Pretreatment Primer 780 

Primer Compatible with Rain Erosion-Resistant Coating 850 

COATINGS -- 

Antichafe Coating 420 

Conformal Coating 750 
AVAQMD Rule 1124 1124-13 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

Electric- or Radiation-Effect Coating 800 

Fire-Resistant Coating -- 

 Civilian 650 

 Military 800 

Flight-Test Coating -- 

 Used on Missiles or Single Use Target Craft 420 

All Other 840 

Fuel-Tank Coating -- 

 General 420 

 Rapid Cure 720 

High-Temperature Coating 850 

Impact-Resistant Coating 420 

Metallized Epoxy Coating 700 

Mold Release Coatings 780 

Optical Anti-Reflection Coating 700 

Rain Erosion-Resistant Coating 800 

Scale Inhibitor 880 

Space-Vehicle Coatings -- 

 Electrostatic Discharge Protection Coating 800 

 Other Space-Vehicle Coating 1000 

Temporary Protective Coating 250 

Topcoat 420 

 Clear Topcoat 520 

Unicoat 420 

Wing Coating 750 

Wire Coatings -- 

 Electronic Wire Coating 420 

 Anti-Wicking 420 

 Pre-Bonding Etchant 420 

 Phosphate Ester Resistant Ink 925 

ADHESIVES -- 

Fuel-Tank Adhesive 620 

Non-Structural 250 

Space Vehicle Adhesive 800 

Structural Adhesive -- 

 Autoclavable 50 

 High Temperature - Autoclavable 650 

 Non-Autoclavable 850 

SEALANTS 

 Extrudable, Rollable or Brushable 280 

 Other 600 

MASKANTS -- 

For Chemical Milling 

 For use with Type I Etchant 250 
1124-14 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

 For use with Type II Etchant 160 

For Chemical Processing 250* 

Photolithographic Maskant 850 

Touch-up, Line-Sealer Maskant 750 

* Less water exempt compounds and perchloroethylene (PERC). 

LUBRICANTS -

-

Fastener Installation -

-

 Solid-Film Lubricant 8

8

0

 Dry Lubricative Material 6

7

5

Fastener Lubricative Coating -

-

 Solid-Film Lubricant 2

5

0

 Dry Lubricative Material 1

2

0

 Barrier Coating 4

2

0

Non-Fastener Lubricative Coatings -

-

 Solid-Film Lubricant 8

8

0

 Dry Lubricative Materials 6

7

5

SPECIALTY COATING VOC LIMITS 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

AEROSPACE MATERIALS [Explanatory Comments, not a part of 

rule] VOC Limit 

 

PRIMERS -- 

General [SIP category] 350 

Adhesion Promoter [ 

Moved to coating category for consistency with CTG definition] 850 

Adhesive Bonding Primers [See AVAQMD 3/20/07 Staff Report for 

discussion of this category] -- 
AVAQMD Rule 1124 1124-15 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

 Commercial Aircraft 250 

 Military Aircraft 805 

Commercial Exterior Aerodynamic Structure Primer [New CTG category. 

Not a subcategory of pretreatment primer] 650 

Compatible Substrate Primer [New CTG category. Not a low solids 

corrosion resistant primer] 780 

Cryogenic Flexible Primer [New CTG category. Not a subcategory of 

pretreatment primer] 645 

Elevated Temperature Skydrol-Resistant Commercial Primer [New CTG 

category. Not a subcategory of pretreatment primer] 740 

Flexible Primer [New CTG category. Not a subcategory of pretreatment 

primer] 640 

Low Solids Corrosion Resistant Primer [Added in 3/20/07 amendment. 

CTG category] 350 

Pretreatment Primer [Moved to coating category for consistency with CTG

definition] 780 

Primer Compatible with Rain Erosion-Resistant Coating [SIP category] 850 

 

COATINGS -- 

Ablative Coating [New CTG category] 600 

Adhesion Promoter Coating [Moved from primer category for consistency 

with CTG definition] 850 

Antichafe Coating [SIP category] 420 

Bearing Coating [New CTG category, not a subcategory of Fastener 

Lubricative or non-fastener lubricative coating] 620 

Chemical Agent-Resistant Coating [New specialized CTG category, 

resistant to chemical warfare agents, not a subcategory of topcoat] 550 

Conformal Coating [SIP Category] 750 

Cryoprotective Coating [New CTG category, not specific to space 

vehicles. Prevents ice formation] 600 

Electric- or Radiation-Effect Coating [SIP category] 800 

Electrostatic Discharge and Electromagnetic Interference (EMI) Coating 

[New CTG category, not specific to space vehicles] 800 

Fire-Resistant (Interior) Coating -- 

 Civilian [SIP category] 650 

 Military [SIP category] 800 

 Space [Sub-category split out to conform to CTG definition] 800 

Flight-Test Coating -- 

 Used on Missiles or Single Use Target AircCraft [SIP category] 420 

 All Other [SIP category] 840 

Fuel-Tank Coating [See AVAQMD 3/20/07 Staff Report for discussion of -- 
1124-16 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

this category] 

 General 420 

 Rapid Cure 720 

High-Temperature Coating [SIP category] 850 

Impact-Resistant Coating [SIP category] 420 

Intermediate Release Coating [New CTG category] 750 

Lacquer Coating [New CTG category. Lacquer is not always a topcoat] 830 

Metallized Epoxy Coating [SIP category] 700 

Mold Release Coatings [Added in 3/20/07 amendment. CTG category] 780 

Optical Anti-Reflection Coating [SIP category] 700 

Part Marking Coating [New CTG category. Part marking can be 

permanent or temp. Remove exemption (G)(9) and (G)(11)] 850 

Pretreatment Coating [Moved from primer category for consistency with 

CTG definition] 780 

Rain Erosion-Resistant Coating [SIP category] 800 

Rocket Motor Nozzle Coating [New CTG category. Not a subcategory as 

it is very specific to withstand heat, pressure and magnetic forces] 660 

Scale Inhibitor Coating [SIP category] 880 

Space-Vehicle Coatings, Other: does not include Electric Discharge and 

EMI Protection Coating or Fire Resistant (Interior) Coating [CTG does 

not distinguish between space and other. SIP category] 1000 

 Electrostatic Discharge and Electromagnetic Interference (EMI) 

Protection Coating [This category is not specific to space vehicles. 

Alphabetized into general table] 800 

 Fire-Resistant (Interior) Coating [This category is not specific to space 

vehicles. Alphabetized into general table] 800 

 Other Space-Vehicle Coating [See Space Vehicle Coatings, Other, 

above] 1000 

Specialized Function Coating [New CTG category] 890 

Temporary Protective Coating [SIP category] 250 

Thermal Control Coating [New CTG category] 800 

Topcoat [Definition updated to include clear coating category from CTG] -- 

 Clear [SIP category] 520 

 Epoxy Polyamide [New CTG category] 660 

 Other [Reorganized for consistency with rest of table format] 420 

Unicoat Coating [SIP category] 420 

Wet Fastener Installation Coating [New CTG category] 675 

Wing Coating [SIP category] 750 

Wire Coatings [SIP categories] 
AVAQMD Rule 1124 1124-17 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

 Electronic Wire Coating 420 

 Anti-Wicking 420 

 Pre-Bonding Etchant 420 

 Phosphate Ester Resistant Ink 925 

 

ADHESIVES -- 

Commercial Interior Adhesive [New CTG category, not covered by nonstructural category] 760 

Cyanoacrylate Adhesive [New CTG category] 1020 

Fuel-Tank Adhesive [SIP category] 620 

Non-Structural Adhesive [SIP category] 250 

Rocket Motor Bonding Adhesive [New CTG category, not covered by 

space vehicle adhesive] 890 

Rubber-based Adhesive [New CTG category] 850 

Space Vehicle Adhesive [SIP category] 800 

Structural Adhesive [See AVAQMD 3/20/07 Staff Report for discussion of

this category] -- 

 Autoclavable 50 

 High Temperature - Autoclavable 650 

 Non-Autoclavable 850 

 

SEALANTS -- 

Extrudable, Rollable, or Brushable or Extrudable Sealant [Added in 

3/20/07 amendment. CTG category. Restructured to match order in 

definition]] 280 

Fastener Sealant [Inadvertently removed by SCAQMD. This limit is in SIP 

version of Rule] 675 

Other [SIP category] 600 

 

MASKANTS -- 

Bonding Maskant [New CTG category. Definition of Chemical Milling 

Maskants says it is not bonding maskant] 1230 

Critical Use and Line Sealer Maskant [Renamed Touch-up, Line-sealer 

Maskant category for consistency with CTG] 750 

For Chemical Milling Maskant [Added in 3/20/07 amendment. CTG 

category] 

 For use with Type I Etchant 250 

 For use with Type II Etchant 160 

 For Chemical Processing *Less water, exempt compounds and 

perchloroethylene (PERC) 250* 
1124-18 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

VOC LIMIT 

Grams Per Liter of Coating Less Water and Less Exempt Compounds 

Photolithographic Maskant [SIP category] 850 

Touch-up, Line-Sealer Maskant 750 

* Less water exempt compounds and perchloroethylene (PERC). 

Seal Coat Maskant [New CTG category. Definition of Chemical Milling 

Maskants says it is not bonding maskant] 1230 

 

LUBRICANTS -- 

Fastener Installation Lubricant (applied at time of aircraft/component 

assembly) [Parenthetical is for clarification. SIP categories] -- 

 Solid-Film Lubricant 880 

 Dry Lubricative Material 675 

Fastener Lubricative Coating (applied at time of fastener manufacture) 

[Parenthetical is for clarification. SIP categories] -- 

 Solid-Film Lubricant 250 

 Dry Lubricative Material 120 

 Barrier Coating 420 

Non-Fastener Lubricative Coatings (applied at time of non-fastener 

manufacture) [Parenthetical is for clarification. SIP categories] -- 

 Solid-Film Lubricant 880 

 Dry Lubricative Materials 675 

 

OTHER -- 

Caulking and Smoothing Compound [New CTG category] 850 

Corrosion Prevention Compound System [New CTG category] 710 

Insulation Covering [New CTG category] 740 

Screen Print Ink [New CTG category not covered specifically by graphic 

arts rules] 840 

Silicone Insulation Material [New CTG category for aerospace industry 

specific material] 850 

[Added “Other” category to include materials that do not conform to existing 

categories. 

New categories for consistency with CTG: Commercial Exterior Aerodynamic Structure 

Primer; Compatible Substrate Primer; Cryogenic Flexible Primer; Elevated 

Temperature Skydrol-Resistant Commercial Primer; Flexible Primer; Ablative 

Coating; Adhesion Promoter; Bearing Coating; Chemical Agent-Resistant Coating 

(CARC); Cryoprotective Coating; Electrostatic Discharge and Electromagnetic 
AVAQMD Rule 1124 1124-19 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

Interference (EMI) Coating; Fire-Resistant Coating (Space); Intermediate Release 

Coating; Lacquer; Part Marking Coating; Pretreatment Coating; Rocket Motor Nozzle 

Coating; Specialized Function Coating; Thermal Control Coating; Topcoat (Epoxy 

Polyamide); Wet Fastener Installation Coating; Commercial Interior Adhesive; 

Cyanoacrylate Adhesive; Rocket Motor Bonding Adhesive; Rubber-based Adhesive; 

Fastener Sealant; Bonding Maskant; Critical Use and Line Sealer Maskant; Seal Coat 

Maskant; Caulking and Smoothing Compound; Corrosion Prevention System 

Compound; Insulation Covering; Screen Print Ink; Silicone Insulation Material. 

Changes and clarifications derived from CTG Control of Volatile Organic Compound 

Emissions from Coating Operations at Aerospace Manufacturing and Rework 

Operations, EPA-453/R-97-004, December 1997 unless otherwise noted.]

(b) Documents shall be provided to the the APCO demonstrating that the Unicoat is 

being used in lieu of the application of a Pprimer and Ttopcoat, and the 

applicant must receive written approval for the use of the Unicoat specifying the 

conditions of application from the APCO. 

(c) For Llow-Ssolids Aadhesives, Ccoatings, Pprimers or Ssealants, the appropriate 

limits in subparagraph (Cc)(1)(a) shall be expressed in grams of VOC per liter 

of material. 

(2) Solvent Use, Clean Up, and Stripping 

(a) A person shall not use VOC-containing materials for cleaning or clean up, 

excluding coating stripping and equipment cleaning unless: 

(i) The VOC composite partial pressure is 45 mm Hg or less at a 

temperature of 20oC (68oF); or 

(ii) The material contains 200 grams or less of VOC per liter of material. 

(b) A person shall not use Sstripper on Aaerospace Ccomponents unless: 

(i) It contains less than 300 grams of VOC per liter of material; or 

(ii) The VOC composite partial pressure is 9.5 mm Hg (0.18 psia) or less at 

20oC (68oF). 

(c) A person shall not atomize any solvent into open air. 

(3) Equipment Cleaning Operations 

Cleaning of Ccoating Aapplication Eequipment shall comply with provisions of Rule 

1171 – Solvent Cleaning Operations. 

(4) Storage of VOC-Containing Materials 
1124-20 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

All VOC containing material, used or unused, including but not limited to surface 

coatings, thinners, cleanup solvents, or surface preparation materials, and all solvent 

laden cloth and paper, shall be stored in non-absorbent, non-leaking containers which 

shall be kept closed at all times except during extraction or introduction of material for 

mixing, use or storage. 

(5) Transfer Efficiency 

No person or Ffacility shall apply Aerospace Materials unless it is applied with properly 

operating equipment or controlled, according to operating procedure specified by the 

equipment manufacturer or the APCO, and by the use of one of the following methods: 

(a) Eelectrostatic application; or

(b) Fflow coater; or

(c) Rroll coater; or

(d) Ddip coater; or

(e) Hhigh-Vvolume, Llow-Ppressure (HVLP) Sspray; or

(f) Hhand Aapplication Mmethods; or 

(g) Ssuch other alternative application methods as are demonstrated to the APCO, 

using District-approved procedures, to be capable of achieving at least 

equivalent Ttransfer Eefficiency to method (C)(5)(e) and for which written

approval of the APCO has been obtained; or 

(h) Approved air pollution control equipment under paragraph (C)(6). 

(6) Control Equipment 

Owners and/or operators may comply with provisions of paragraphs (C)(1), (C)(2), and 

(C)(5) by using approved air pollution control equipment provided that the VOC 

emissions from such operations and/or materials are reduced in accordance with 

provisions of (a) and (b) below. 

(a) The control device shall reduce emissions from an emission collection system 

by at least 95 percent (95%), by weight, or by reducing the output of the air 

pollution control device to less than 50 PPM ppm calculated for carbon with no 

dilution. 

(b) The owner/operator demonstrates that the system collects at least 90 percent 

(90%), by weight, of the emissions generated by the sources of emissions. 
AVAQMD Rule 1124 1124-21 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(7) Prohibition of Solicitation of Violations 

(a) A person shall not solicit or require any other person to use, in the District, any 

Aerospace Material or combination of Aerospace Materials to be applied to any 

Aaircraft component subject to the provisions of this rule that does not meet the 

limits and requirements of this rule, or of an Alternative Emission Control Plan 

(AECP) approved pursuant to the provisions of (C)(8). 

(b) The requirements of this paragraph shall apply to all written or oral agreements 

executed or entered into after April 3, 1987.

(8) Alternative Emission Control Plans 

(a) An owner/operator may comply with the provisions of paragraph (C)(1) by 

means of an Alternative Emission Control Plan pursuant to Rule 108 – 

Alternative Emission Control Plans. 

(D) Recordkeeping and Reporting Requirements 

(1) Recordkeeping 

(a) Records shall be maintained pursuant to the requirements of Rule 109 – 

Recordkeeping for Volatile Organic Compound Emissions. 

(2) Reporting 

(a) Persons who perform qualification acceptance testing on Aerospace Materials 

with a future compliance date for use in the District shall, on January 1 and July 

1 of each year, submit a status report describing the progress toward the 

development of Aerospace Materials which satisfy future compliance dates. 

These reports shall contain, at a minimum:

(i) Manufacturer, product number, VOC content, and applicable coating 

category for each of the test candidates; 

(ii) Test expenditures for the period; 

(iii) Progress on candidates tested during this period;.

(iv) Approvals received for coatings which comply with future compliance 

dates; and.

(v) Volume of coatings used in each coating category for which there is a 

future compliance date. 

(b) Facilities testing coatings in the same coating category may submit joint status 

reports. Once compliance with future compliance dates is achieved and a status 

report is submitted documenting such, no further status reports need be 

submitted. 
1124-22 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(E) Compliance Procedures and Test Methods 

(1) Calculations 

(a) For the purpose of determining compliance with VOC content limits specified in 

section (C), grams of VOC per liter of Aerospace Material shall be determined 

by using the following formulas as applicable: 

(i) For Aerospace Mmaterials not containing reactive diluents, grams of

VOC per liter of coating, less water and less Eexempt Ccompounds shall 

be determined as follows: 

  ⁄ =

	
 − 	 − 	



 −  − 



Grams of VOC per Liter of Ws – Ww – Wes

Coating, Less Water and Less = 

Exempt Compounds Vm – Vw - Ves

Where: 

G_(VOC⁄LoC) = Grams of VOC per Liter of 

Coating, Less Water and Less 

Exempt Compounds 

Ws = Weight of volatile compounds in 

grams. 

Ww = Weight of water in grams. 

Wes = Weight of Eexempt Ccompounds in 

grams. 

Vm = Volume of material in liters. 

Vw = Volume of water in liters. 

Ves = Volume of Eexempt Ccompounds 

in liters. 

(ii) For Aerospaces Materials that contain reactive diluents, grams of VOC 

per liter of coating, less water and less Eexempt Ccompounds shall be 

determined as follows:

Grams of VOC per Liter of Ws – Ww – Wes

Coating, Less Water and Less = 

Exempt Compounds Vm – Vw - Ves

Where: 

Ws = Weight of volatile compounds evolved 

during curing and analysis, in grams. 
AVAQMD Rule 1124 1124-23 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

Ww = Weight of water evolved during curing 

and analysis, in grams. 

Wes = Weight of Eexempt Ccompounds evolved 

during curing and analysis, in grams. 

Vm = Volume of material prior to reaction, in 

liters. 

Vw = Volume of water evolved during curing 

and analysis, in liters. 

Ves = Volume of Eexempt Ccompounds evolved 

during curing and analysis, in liters. 

(b) Total grams of VOC per liter of Aerospace Material shall be determined using 

the following formula: 

Grams of VOC per Liter of Ws – Ww – Wes

Coating = 

 Vm 

Where: 

Ws = Weight of volatile compounds in grams. 

Ww = Weight of water in grams. 

Wes = Weight of Eexempt Ccompounds in grams. 

Vm = Volume of material in liters. 

(c) The VOC composite partial pressure shall be determined as follows:

 = 

	

	

× 

	

	

+

	


	


+ ∑

	

	

!

"#

!

"#

 Wi 

 x VPi

 

 n MWi

 

PPc = Σ 

 i=1 Ww We n Wi

 + + Σ

 MWw MWe i=1 MWi

Where: 

Wi = Weight of the “i”th VOC compound, in grams. 

Ww = Weight of water, in grams. 

We = Weight of Eexempt Ccompound, in grams 

MWi = Molecular weight of the “i”th VOC compound, in 
1124-24 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

grams per gram-mole. 

MWe = Molecular weight of Eexempt Ccompound in grams per 

gram-mole. 

PPc = VOC composite partial pressure at 20°C, in mm Hg. 

VPi = Vapor pressure of the “i”th VOC compound at 20°C, in 

mm Hg. 

(2) VOC Content of Aerospace Materials 

(a) To determine the physical properties of an Aerospace Material in order to 

perform the calculations in subsection (E)(1) , the following reference methods 

shall be used: 

(i) EPA Reference Method 24 (Determination of Volatile Matter Content, 

Water Content, Density Volume Solids, and Weight Solids of Surface 

Coatings, Code of Federal Regulations Title 40, Part 60, Appendix A). 

a. Analysis done according to EPA Method 24 shall utilize ASTM 

Method D-2369-95 (Standard Test Method for Volatile Content 

of Coatings), referenced in EPA Method 24. [Complete title 

added to meet the enforceability requirement of CAA

110(a)(2)(A) per EPA’s “Little Blue Book” pursuant to USEPA 

comment 4/23/13.]

b. The exempt solvent content shall be determined using SCAQMD 

Test Methods 302-91 (Distillation of Solvents from Paints, 

Coatings and Inks, February 1993) and 303-91 (Determination of 

Exempt Compounds, August 1996) (SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual) or;

[Complete title added to meet the enforceability requirement of 

CAA 110(a)(2)(A) per EPA’s “Little Blue Book” pursuant to 

USEPA comment 4/23/13.]

(ii) SCAQMD Test Methods 302, 303, and 304 (SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual). 

(b) The following classes of compounds listed below will be analyzed as Eexempt 

Ccompounds for compliance with subdivision (C), only at such time as 

manufacturers specify which individual compounds are used in the coating 

formulations and identify the test methods, which, prior to such analysis, have 

been approved by the USEPA and the SCAQMD, that can be used to quantify 

the amounts of each Eexempt Ccompound. 

(i) Cyclic, branched, or linear, completely fluorinated alkanes; cyclic, 

branched, or linear, completely fluorinated ethers with no unsaturations; 

cyclic, branched, or linear, completely fluorinated tertiary amines with 
AVAQMD Rule 1124 1124-25 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

no unsaturations; and sulfur-containing perfluorocarbons with no 

unsaturations and with sulfur bonds only to carbon and fluorine.

(3) Test Methods 

(a) Efficiency of the control device shall be determined according to EPA Method 

25, 25A, or SCAQMD Test Method 25.1 (Total Gaseous Non-Methane 

Emissions, February 1991) or SCAQMD Test Method 25.3 (Clean-Fueled 

Combustion Sources, March 2000). Emissions determined to exceed any limits 

established by this rule through the use of either of the above-referenced test 

methods shall constitute a violation of this rule. [Complete title added to meet 

the enforceability requirement of CAA 110(a)(2)(A) per EPA’s “Little Blue 

Book” pursuant to USEPA comment 4/23/13.]

(b) The capture efficiency of the emissions collection system shall be determined by 

the USEPA method 204A-F and the most recent version of USEPA’s 

Guidelines for Determining Capture Efficiency or any other method approved by 

the USEPA, the California Air Resources Board, and the SCAQMD. 

(c) The Ttransfer Eefficiency of alternative coating application methods shall be 

determined in accordance with the SCAQMD method "Spray Equipment 

Transfer Efficiency Test Procedure for Equipment User, May 24, 1989". 

(d) The identity and quantity of components in solvents shall be determined in 

accordance with SCAQMD test method 308-91 (Quantitation of Compounds by 

Gas Chromatography, February 1993) contained in the SCAQMD "Laboratory 

Methods of Analysis for Enforcement Samples" manual. The VOC composite 

partial pressure is calculated using the equation in paragraph (b)(63)(E)(1)(c).

[Complete title added to meet the enforceability requirement of CAA 

110(a)(2)(A) per EPA’s “Little Blue Book” pursuant to USEPA comment 

4/23/13. Cross reference corrected pursuant to USEPA comment 4/23/13.]

(e) Multiple Test Methods 

(i) When more than one test method or set of test methods are specified for 

any testing, a violation of any requirement of this rule established by any 

one of the specified test methods or set of test methods shall constitute a 

violation of the rule. 

(f) Any applicable alternative test method may be used so long as such method has 

been approved by USEPA, CARB and the APCO. 
1124-26 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(F) Administrative Requirements 

(1) Rule 442 Applicability 

(a) Any Aerospace Material or Ffacility which is exempt from all or a portion of 

this rule, shall comply with the provisions of Rule 442 – Usage of Solvents. 

[Title added pursuant to USEPA comment 4/23/13.]

(G) Exemptions 

(1) The provisions of paragraph (C)(1) of this rule shall not apply to Aerospace Materials 

with separate formulations that are used in volumes of less than 20 gallons per year 

provided that the total of all such formulations applied annually at a Ffacility is less 

than 200 gallons.

(2) The provisions of subdivision (C) of this rule shall not apply to a Ffacility which uses a 

total of less than three gallons of VOC-containing Aerospace Materials on each and 

every day of operation. 

(3) The provisions of paragraphs (C)(1) and (C)(5) of this rule shall not apply to incidental 

corrosion maintenance Rrepair Ccoating operations at military Ffacilities, provided that 

the coating use at any maintenance repair location within the Ffacility does not exceed 

1.5 gallons per day, and the total coating usage for such operations at the Ffacility does 

not exceed five (5) gallons per day. 

(4) The provisions of subparagraph (C)(2)(a) shall not apply to Sspace Vvehicle 

manufacturing. 

(5) The provisions of paragraph (C)(1) shall not apply to clear or translucent coatings 

applied on clear or transparent substrates. 

(6) The provisions of paragraph (C)(5) shall not apply to Touch-up Operations and Sstencil 

Ccoatings provided that the Touch-up Operations and Sstencil Ccoatings do not exceed 

25 sq. ft. per Aaircraft. [This exemption further defines Touch-up Operations by 

defining the affected area.

(7) The provisions of paragraph (C)(1) shall not apply to the recoating of assembled 

Aaircraft at Rrework facilities if original coating formulations are used. 

(8) The provisions of paragraph (C)(1) shall not apply to Aadhesives with separate 

formulations that are used in volumes of less than ten gallons per year. 
AVAQMD Rule 1124 1124-27 

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

(9) The provisions of paragraph (C)(5) shall not be applied to the application of materials 

marking coatings. [Exemption removed for consistency with CTG category of Part 

Marking Coating, pursuant to USEPA comment 4/23/13.]

(109) The provisions of subdivision (C) shall not apply to laboratories which apply Aerospace 

Materials to test specimens for purposes of research, development, quality control, and 

testing for production-related operations. 

(11) The provisions of subdivision (C) shall not apply to the application of temporary 

marking coatings. [Exemption removed for consistency with CTG category of Part 

Marking Coating.] 

(1210) The provisions of paragraph (C)(2) of this rule do not apply to the surface cleaning of 

solar cells, fluid systems, avionic equipment, and laser optics. 

(1311) The provisions of subdivision (D)(1) and (C)(5) shall not be applied to the application 

of materials that contain less than 20 g/L of VOC per liter of material.

(1412) The provisions of paragraph (C)(5) shall not apply to the use of materials dispensed 

from airbrush operations provided that the paint reservoir on the air brush is 8 oz or less 

and that the total amount of coating used for Aair Bbrush Ooperations at the Facility 

does not exceed five (5) gallons per year. 

(1513) The provisions of this rule shall not apply to Aaerosol Ccoating Pproducts. 

See SIP Table at http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=921 

[SIP: Submitted as amended 3/20/07 on _____; Submitted as amended 12/13/96 on 8/1/97 and 

approved for SCAQMD area only 8/17/98, 63 FR 43884; Approved 5/6/96, 61 FR 20136, 40 CFR 

52.220(c)(215)(I)(A)(5); Approved 1/24/85, 50 FR 3338, 40 CFR 52.220(c)(154)(vii)(A); Approved 

9/28/81, 46 FR 47451, 40 CFR 52.220(c)(58)(ii)(B)] 

 
1124-28 AVAQMD Rule 1124

Aerospace Assembly and 

Component Manufacturing Operations 

D2: 06/26/13 

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AVAQMD Rule 1124 B-1

Final Staff Report, 09/20/13

APPENDIX "B" 

PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing – Antelope Valley Press, 6/14/2013 
B-2 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

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AVAQMD Rule 1124 

B-3

Final Staff Report, 09/20/13
B-4 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

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AVAQMD Rule 1124 C-1

Final Staff Report, 09/20/13 

APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. Preliminary USEPA comment email, 4/23/2013 

2. Transmittal of EPA Rule Review Comments, June 13, 2013 

3. ARB Staff Rule Review Results, June 18, 2013 
C-2 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

This page intentionally left blank. 

 
AVAQMD Rule 1124 C-3

Final Staff Report, 09/20/13 

Hi Tracey, 

Here are my preliminary comments. I will formalize in a comment letter. Please let me know if there is anything that you want 

to discuss before I do that: 

• Section (A) General : No Comments 

• Section (B) Definitions: We note that several new definitions, many directly from the CTG, have been added. The 

following are our comments: 

1. Subsection (54) Metalized Epoxy Coating – CARB comment from 6/29/01 has not been addressed 

2. Subsection (56) Non-Structural Adhesive – CARB comment from 6/29/01 has not been addressed 

3. Subsection (83) Stencil – CARB definition from 6/29/01 comment indicates a limited airbrush capacity of 8 oz. 

Consider adding this to definition 

4. Subsection (90) Topcoat – The definition in the CTG adds a caveat that “specialty coatings are not included in 

the definition of topcoat. Consider adding this clarification. 

• Section (C) Requirements: We note that several new categories from the CTG, have been added. A table outlining 

the categories and how the limits compare to either the CTG or the SCAQMD rule 1124 is attached for your 

reference. We have no further comments on the limits table but recommend that all CTG categories be included in 

the event that these coatings may be used in the District in the future. Other comments on this section are as 

follows: 

1. (C)(6)(b) - CARB comment from 6/29/01 asking that the method of determining 90% collection be added has 

not been addressed 

• Section (E) Compliance Procedures and Test Methods: Several of our previous comments have not been 

addressed: 

1. (E)(2)(a) a – Please add the complete title of the ASTM D2369-95, “Standard Test Method for Volatile Content 

of Coatings”. This information is required to meet the enforceability requirement of CAA 110(a)(2)(A) per 

EPA’s “Little Blue Book.” 

2. (E)(2)(a) b – Please use the complete EPA version number of the SQACMD methods and include the complete 

title for SCAQMD Method 302-91, “Distillation of Solvents from Paints, Coatings and Inks,” February 1993 and 

SCAQMD Method 303-91, “Determination of Exempt Compounds,” August 1996. This information is required to 

meet the enforceability requirement of CAA 110(a)(2)(A) per EPA’s “Little Blue Book.” 

3. (E)(3)(a) – Please use the complete EPA version number of the SQACMD methods and include the complete 

title for SCAQMD Method 25.1, “Total Gaseous Non-Methane Emissions,” February 1991 and SCAQMD 

Method 25.3, “Clean-Fueled Combustion Sources,” March 2000. This information is required to meet the 

enforceability requirement of CAA 110(a)(2)(A) per EPA’s “Little Blue Book.” 

4. (E)(3)(d) – Please use the complete EPA version number of the SQACMD methods and include the complete 

title for SCAQMD Method 308-91, “Quantitation of Compounds by Gas Chromatography,” February 1993. This

information is required to meet the enforceability requirement of CAA 110(a)(2)(A) per EPA’s “Little Blue 

Book.” 

5. (E)(3)(d) - Please correct the erroneous reference to “...using the equation in paragraph (E)(1)(c).” 

• (F)(1)(a) – Please provide the title of referenced Rule 442: “Usage of Solvents.” 

• Section (G) Exemptions: 

1. (G)(6) – We note that the limitations of touchups have been defined as < 25 sq. ft. This may satisfy the CARB 

request to further define “Touch-Up Coating” (now changed to “Touch-Up Operations”) since it defines the 

affected area. 

2. (G)(9) – Although this exemption is the same as that in the SCAQMD Rule 1124, it is noted that the exemption 

for “Temporary Part Marking” has been removed since the category of “Part Marking” coating has been added 

to (C)(1). Doesn’t this also apply to the materials part marking coatings of this paragraph? 

All best regards, 

Adrianne 

AIR-4 

 

1. EPA Preliminary Comments, 4/23/13 
C-4 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

Section (B) 

1. Upon review of this CARB comment made to the SCAQMD, SCAQMD responded in the 

following manner: The appendix to 40 CFR-Chapter I-Part 63 (Aerospace NESHAP) also defines a 

metallized epoxy coating as a coating that contains relatively large quantities of flake pigmentation for 

appearance and/or added protection. Staff would prefer delaying a change to this definition until such 

time that it can be further developed with input from U.S. EPA and industry to make it more definitive. 

EPA agreed that this comment does not need to be addressed at this time based on the SCAQMD 

response. 

2. Upon review of this CARB comment to the SCAQMD, SCAQMD responded in the following 

manner: The appendix to 40 CFR-Chapter I-Part 63 (Aerospace NESHAP) also defines a nonstructural adhesive in the same manner, however, it adds the language that these adhesives are among 

those that are "not covered in any other specialty adhesive categories". Staff recommends appending 

the definition to include the above EPA language for added clarity. 

The language from the SCAQMD response is already included in our rule version. 

3. Rule subsection (G)(6) provides parameters for touch-up operations and stencil coating 

operations exemption as applies to transfer efficiency. 

4. Recommended language has been added to definition of “Topcoat” (B)(90). 

Section (C) 

All CTG categories have been included unless it is shown that they are covered by an existing category

in the rule. 

1. Subsection (E)(3)(b) provides a reference for determining capturing efficiency of the emissions 

collection system. 

Section (E) 

1. Title has been added as requested. 

2. Version numbers and titles have been added as requested. 

3. Version numbers and titles have been added as requested. 

4. Version numbers and titles have been added as requested. 

5. Rule citation has been corrected. 

1. District Response to EPA Preliminary Comments, 4/23/13 
AVAQMD Rule 1124 C-5

Final Staff Report, 09/20/13 

Section (F)(1)(a) 

Rule title has been added. 

Section (G) 

1. AVAQMD agrees that this limitation helps satisfy the CARB request made to the SCAQMD to 

further define touch-up operations. 

2. Both exemptions have been removed for consistency with the part marking coating category as 

requested. 

 
C-6 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

1.

4.

5.

2.

3.

2. Transmittal of EPA Rule Review Comments, 06/13/13 
AVAQMD Rule 1124 C-7

Final Staff Report, 09/20/13 

1. MDAQMD Rule 1118 – Aerospace Vehicle Parts and Products Coating Operations as adopted 

10/28/96 has a limit of 700 grams/liter for Structural Non-autoclavable Adhesive. According to the 

Staff Report for this rule adoption, the definition and VOC limit for this category were derived from 

SCAQMD Rule 1124 as amended January 13, 1995. The VOC limit in SCAQMD Rule 1124 as 

amended January 13, 1995 for Adhesives, Structural, Non-Autoclavable was 850 grams/liter (the 

coating category in SCAQMD Rule 1124 below Adhesives, Structural, Non-Autoclavable is Optical 

Anti-Reflective Coating with a VOC limit of 700, and the District assumes there was a typographical 

error when the Structural Non-autoclavable Adhesive was input). It is not evident that there is any 

basis for the lower VOC limit of 700 for Structural Non-autoclavable Adhesives in MDAQMD Rule 

1118, including no use basis by sources in the MDAQMD. The limit of 850 for this category is 

included in the current SIP approved versions of SJVUAPCD Rule 4605 (76 FR70886, 11/16/2011), 

SCAQMD Rule 1124 (67 FR 52611, 8/13/2002), SBCAPCD Rule 337 (78 FR 21538, 4/11/2013), as 

well as the CTG. These approvals are subsequent to the MDAQMD SIP approval (63 FR 43884, 

8/17/1998). The AVAQMD will retain the existing limit of 850 grams/liter for Structural Nonautoclavable Adhesive based on these conclusions. 

2. Generally, The AVAQMD is not required to use SCAQMD or SJVUAPCD limits because both of 

these districts are extreme nonattainment for ozone and require BACT level rules. Unless these are 

clearly RACT limits, the AVAQMD chooses to retain the existing limit of 850 grams/liter for 

Adhesion Promoter Coating. 

3. MDAQMD Rule 1118 – Aerospace Vehicle Parts and Products Coating Operations as adopted 

10/28/96 has a limit of 500 grams/liter for Chemical Agent-Resistant Coating. According to the Staff 

Report for this rule adoption, the definition and VOC limit for this category were derived from the 

CTG. The VOC limit in the CTG for Chemical Agent-Resistant Coating is 550 grams/liter. The 

District assumes there was a typographical error when the Chemical Agent-Resistant Coating limit was 

input. It is not evident that there is any basis for the lower VOC limit of 500 grams/liter for Chemical 

Agent-Resistant Coating, including no use basis by sources in the MDAQMD. The limit of 550 

grams/liter for this category is included in the current SIP approved versions of SJVUAPCD Rule 

4605, SBCAPCD Rule 337, and the CTG (no limit for CARC in SCAQMD Rule 1124). These 

approvals are subsequent to the MDAQMD SIP approval (63 FR 43884, 8/17/1998). The AVAQMD 

will retain the existing limit of 550 grams/liter for Chemical Agent-Resistant Coating based on these 

conclusions. 

4. Generally, The AVAQMD is not required to use SCAQMD or SJVUAPCD limits because both of 

these districts are extreme nonattainment for ozone and require BACT level rules. Unless these are 

clearly RACT limits, the AVAQMD chooses to retain the existing limit of 840 grams/liter for Flight 

Test Coating – All Other. 

5. A comparison of SJVUAPCD and AVAQMD Lubricant limits below indicate that the coating 

categories and limits are identical (except for the additional category of Fastener Installation Lubricant 

(applied at time of aircraft/component assembly) - Dry Lubricative Material in the AVAQMD rule). 

2. District response to EPA Rule Review Comments, 06/13/13 
C-8 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

The AVAQMD does not agree that the coating limits are different for the Solid-Film subcategory of 

the Fastener Installation category between the SJVUAPCD and AVAQMD rules. See table below. 

 

SJVUAPCD Coating Category SJVUAPCD 

4605 AVAQMD Coating Category AVAQMD 1124 

Barrier Topcoat (Coating) 420 Fastener Lubricative Coating 

(applied at time of fastener 

manufacture) - Barrier Coating 

420 

Dry Lubricative Materials 

a. Fastener Manufacturing 120 Fastener Lubricative Coating 

(applied at time of fastener 

manufacture) - Dry Lubricative 

Material 

120 

b. Nonfastener Manufacturing 675 Non-Fastener Lubricative 

Coatings (applied at time of 

non-fastener manufacture) -Dry 

Lubricative Materials 

675 

 Fastener Installation Lubricant 

(applied at time of 

aircraft/component assembly) - 

Dry Lubricative Material 

675 

Solid Film Lubricants 

a. Fastener Manufacturing 250 Fastener Lubricative Coating 

(applied at time of fastener 

manufacture) - Solid-Film 

Lubricant 

250 

b. Fastener Installation 880 Fastener Installation Lubricant 

(applied at time of 

aircraft/component assembly) - 

Solid-Film Lubricant 

880 

c. Nonfastener Manufacturing 880 Non-Fastener Lubricative 

Coatings (applied at time of 

non-fastener manufacture) -

Solid-Film Lubricant 

880 

USEPA appears to be confusing Solid Film Lubricants applied at the time of aircraft component 

assembly or Non-fastener manufacture limits (currently 880 grams/liter) with Fastener Lubricative 

Coatings applied at time of manufacture (currently 250 grams/liter). 

 
AVAQMD Rule 1124 C-9

Final Staff Report, 09/20/13 

 

3. ARB Staff Rule Review Results, 06/18/13 
C-10 AVAQMD Rule 1124 

Final Staff Report, 09/20/13

No response required. 

3. District Response to ARB Staff Rule Review Results, 06/18/13 
AVAQMD Rule 1124 D-1

Final Staff Report, 09/20/13 

APPENDIX "D" 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

DOCUMENTATION

(to be included as available) 

1. Notice of Exemption – Los Angeles County 
D-2 AVAQMD Rule 1124 

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AVAQMD Rule 1124 

D-3

Final Staff Report, 09/20/13 
D-4 AVAQMD Rule 1124 

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AVAQMD Rule 1124 E-1

Final Staff Report, 09/20/13 

APPENDIX "E" 

BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report and the proposed 

amendment of Rule 1124: 

1. SCAQMD Rule 1124 – Aerospace Assembly and Component Manufacturing Operations, 

Amended January 13, 1995. 

2. SCAQMD Rule 1124 – Aerospace Assembly and Component Manufacturing Operations, 

Amended December 13, 1996. 

3. SCAQMD Staff Report: Proposed Amended Rule 1124 – Aerospace Assembly and 

Component Manufacturing Operations, August 2001. 

4. AVAQMD Rule 1124 – Aerospace Assembly and Component Manufacturing Operations, 

Amended March 20, 2007. 

5. Control of Volatile Organic Compound Emissions from Coating Operations at Aerospace 

Manufacturing and Rework Operations, EPA-453/R-97-004, December 1997. 

6. Subpart GG – National Emission Standards for Aerospace and rework Facilities, 60 FR 

45956, September 1, 1996. 
E-2 AVAQMD Rule 1124 

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